How to Use the Community Reinvestment Act (CRA) to Promote Housing and Economic Opportunity in Your Community Why is the Community Reinvestment Act (CRA) important? CRA is a federal law that imposes an affirmative obligation on banks to serve the credit needs of low- and moderate-income communities and to take steps to provide equal access to responsible financial products and services to traditionally underserved populations. Thanks to CRA, banks have actively promoted housing and economic opportunity for underserved groups by providing affordable mortgage programs, small business loan products, community development financing, funding for non-profit housing and economic development programs, etc. Banks are regularly examined by the federal government to determine if they are meeting their CRA obligations. Because an unsatisfactory CRA rating or questions about CRA performance can result in delays or denials of mergers, acquisitions or the expansion of services, banks often look for ways to maintain or improve their CRA records. How can I or my agency maximize the benefits of CRA to promote housing and economic opportunity in my community? To maximize the benefits of CRA within local communities, NCRC encourages community stakeholders to develop a CRA strategy that involves a combination of any or all of the following activities: Submit written comments on the community reinvestment performance of banks in your local area when these banks undergo their regular CRA examinations; Monitor bank mergers, acquisitions and expansions to identify strategic opportunities to encourage banks in your local area to improve their community reinvestment records; Meet periodically with banks operating in your local area, even if they are performing well on their CRA exams, to discuss your community’s credit/capital/bank service needs and to suggest actions a bank can take to better meet those needs; Meet with bank regulators to discuss the performance of specific banks, as well as improvements to the CRA exam process; Encourage your local government or other local institutions with substantial bank accounts (e.g., churches, foundations, etc.) to establish a linked deposit program to ensure that only those banks with reasonable community reinvestment records are eligible to benefit from a financial relationship with major local depositors; and Become a shareholder advocate – owning even a small number of shares in a publicly-held bank allows you to introduce, vote on and/or speak at shareholder meetings about shareholder resolutions that address community reinvestment concerns. Remember to contact NCRC if you need assistance implementing any of these CRA-related activities. How can I or my agency participate in the CRA exam process to benefit my community and clients? Comments made by community stakeholders (including non-profits, local government agencies and individuals) that highlight strengths or weaknesses in a bank’s performance with regard to lending, investments or service provision that benefit underserved groups can have a strong influence on a bank’s CRA rating, as well as on the ongoing actions a bank takes to promote housing, financial and economic opportunity for traditionally underserved populations. You can submit comments on a bank’s community reinvestment performance at any time. If a bank is not undergoing a CRA exam at the time you submit your comments, simply instruct the bank and its federal regulator to place your CRA comments in the bank’s public file. The next time a CRA exam occurs, the federal examiner is required to look at comments in the public file and the bank is required to report how it responded to any concerns raised. NCRC can provide guidance and data analysis to help you develop your comments on a bank’s CRA record. Why should community stakeholders meet regularly with banks to discuss CRA-related activities? Community agencies and other stakeholders can approach banks, particularly those that receive poor CRA ratings, to suggest ways that financial institutions can improve their community reinvestment performance. The development of mutually beneficial relationships between banks and community stakeholders has resulted in funding for housing counseling programs; new loan products that better serve small business entrepreneurs; increases in the number of bank branches in underserved neighborhoods; investments in local community and economic development loan programs and projects; financing for affordable mortgage products; sound credit alternatives to predatory payday loan products; etc. To see if there are any specific issues you may want to discuss with a bank, you can check the results of that bank’s last CRA exam at http://www.ffiec.gov/craratings/default.aspx or you can contact NCRC for an analysis of a bank’s CRA-related performance. NCRC can also help you prepare for your meetings with banks. Why do bank mergers, acquisitions and expansions present a strategic opportunity to encourage banks to enhance their product/service offerings and/or to support programs that benefit traditionally underserved groups? If valid questions about a bank’s CRA performance record are raised when financial institutions are engaged in a merger, acquisition or expansion process (particularly if the bank received a low CRA score on it’s last exam) federal regulators may delay or deny the merger, acquisition or expansion application involving that bank. To avoid such costly delays, the financial institution(s) involved will often work with community stakeholders to develop a community reinvestment plan that addresses the problem(s) and that identifies specific funding and/or new products, services or investments the bank will offer in order to promote housing and economic opportunity for traditionally underserved groups. To find out if there are any pending merger, acquisition or expansion applications that may impact your community and/or for assistance in preparing your response, call NCRC’s Membership Department at (202) 628-8866. How can NCRC help me or my agency prepare CRA-related comments or engage in CRA-related discussions with banks? NCRC can provide a detailed analysis of a financial institution’s community reinvestment record that addresses how well the bank serves the needs of low- and moderate-income and/or minority households through its basic banking, lending and investment services. This analysis is provided FREE to NCRC members. NCRC staff can also provide guidance on how to prepare CRA-related comment letters and engage in negotiations with financial institutions to secure funding, products and services that promote housing and economic opportunity for low- and moderate-income and minority clients. Staff can help members frame and support their appeal and determine what community investment commitments it might be appropriate to ask a bank to make (e.g., develop new products that better serve small business entrepreneurs, fund housing counseling programs, invest in a housing/community development or small business loan fund, etc.). In addition, NCRC members can communicate with other coalition members via our listserv to find out what has worked in other communities, see examples of comment letters written to regulatory bodies and, of course, elicit support from other allies for their CRA-related activities. How can I or my agency get help from NCRC to support our CRA-related activities? Staff from NCRC’s Membership, Research and Legislative/Regulatory Affairs Departments are available to provide you with the support you need to utilize CRA to promote housing and economic opportunity in your community. To start the process, contact NCRC at (202) 628-8866 or membership@ncrc.org. How to Use the Community Reinvestment Act (CRA) to Promote Housing and Economic Opportunity in Your Community Why is the Community Reinvestment Act (CRA) important? CRA is a federal law that imposes an affirmative obligation on banks to serve the credit needs of low- and moderate-income communities and to take steps to provide equal access to responsible financial products and services to traditionally underserved populations. Thanks to CRA, banks have actively promoted housing and economic opportunity for underserved groups by providing affordable mortgage programs, small business loan products, community development financing, funding for non-profit housing and economic development programs, etc. Banks are regularly examined by the federal government to determine if they are meeting their CRA obligations. Because an unsatisfactory CRA rating or questions about CRA performance can result in delays or denials of mergers, acquisitions or the expansion of services, banks often look for ways to maintain or improve their CRA records. How can I or my agency maximize the benefits of CRA to promote housing and economic opportunity in my community? To maximize the benefits of CRA within local communities, NCRC encourages community stakeholders to develop a CRA strategy that involves a combination of any or all of the following activities: Submit written comments on the community reinvestment performance of banks in your local area when these banks undergo their regular CRA examinations; Monitor bank mergers, acquisitions and expansions to identify strategic opportunities to encourage banks in your local area to improve their community reinvestment records; Meet periodically with banks operating in your local area, even if they are performing well on their CRA exams, to discuss your community’s credit/capital/bank service needs and to suggest actions a bank can take to better meet those needs; Meet with bank regulators to discuss the performance of specific banks, as well as improvements to the CRA exam process; Encourage your local government or other local institutions with substantial bank accounts (e.g., churches, foundations, etc.) to establish a linked deposit program to ensure that only those banks with reasonable community reinvestment records are eligible to benefit from a financial relationship with major local depositors; and Become a shareholder advocate – owning even a small number of shares in a publicly-held bank allows you to introduce, vote on and/or speak at shareholder meetings about shareholder resolutions that address community reinvestment concerns. Remember to contact NCRC if you need assistance implementing any of these CRA-related activities. How can I or my agency participate in the CRA exam process to benefit my community and clients? Comments made by community stakeholders (including non-profits, local government agencies and individuals) that highlight strengths or weaknesses in a bank’s performance with regard to lending, investments or service provision that benefit underserved groups can have a strong influence on a bank’s CRA rating, as well as on the ongoing actions a bank takes to promote housing, financial and economic opportunity for traditionally underserved populations. You can submit comments on a bank’s community reinvestment performance at any time. If a bank is not undergoing a CRA exam at the time you submit your comments, simply instruct the bank and its federal regulator to place your CRA comments in the bank’s public file. The next time a CRA exam occurs, the federal examiner is required to look at comments in the public file and the bank is required to report how it responded to any concerns raised. NCRC can provide guidance and data analysis to help you develop your comments on a bank’s CRA record. Why should community stakeholders meet regularly with banks to discuss CRA-related activities? Community agencies and other stakeholders can approach banks, particularly those that receive poor CRA ratings, to suggest ways that financial institutions can improve their community reinvestment performance. The development of mutually beneficial relationships between banks and community stakeholders has resulted in funding for housing counseling programs; new loan products that better serve small business entrepreneurs; increases in the number of bank branches in underserved neighborhoods; investments in local community and economic development loan programs and projects; financing for affordable mortgage products; sound credit alternatives to predatory payday loan products; etc. To see if there are any specific issues you may want to discuss with a bank, you can check the results of that bank’s last CRA exam at http://www.ffiec.gov/craratings/default.aspx or you can contact NCRC for an analysis of a bank’s CRA-related performance. NCRC can also help you prepare for your meetings with banks. Why do bank mergers, acquisitions and expansions present a strategic opportunity to encourage banks to enhance their product/service offerings and/or to support programs that benefit traditionally underserved groups? If valid questions about a bank’s CRA performance record are raised when financial institutions are engaged in a merger, acquisition or expansion process (particularly if the bank received a low CRA score on it’s last exam) federal regulators may delay or deny the merger, acquisition or expansion application involving that bank. To avoid such costly delays, the financial institution(s) involved will often work with community stakeholders to develop a community reinvestment plan that addresses the problem(s) and that identifies specific funding and/or new products, services or investments the bank will offer in order to promote housing and economic opportunity for traditionally underserved groups. To find out if there are any pending merger, acquisition or expansion applications that may impact your community and/or for assistance in preparing your response, call NCRC’s Membership Department at (202) 628-8866. How can NCRC help me or my agency prepare CRA-related comments or engage in CRA-related discussions with banks? NCRC can provide a detailed analysis of a financial institution’s community reinvestment record that addresses how well the bank serves the needs of low- and moderate-income and/or minority households through its basic banking, lending and investment services. This analysis is provided FREE to NCRC members. NCRC staff can also provide guidance on how to prepare CRA-related comment letters and engage in negotiations with financial institutions to secure funding, products and services that promote housing and economic opportunity for low- and moderate-income and minority clients. Staff can help members frame and support their appeal and determine what community investment commitments it might be appropriate to ask a bank to make (e.g., develop new products that better serve small business entrepreneurs, fund housing counseling programs, invest in a housing/community development or small business loan fund, etc.). In addition, NCRC members can communicate with other coalition members via our listserv to find out what has worked in other communities, see examples of comment letters written to regulatory bodies and, of course, elicit support from other allies for their CRA-related activities. How can I or my agency get help from NCRC to support our CRA-related activities? Staff from NCRC’s Membership, Research and Legislative/Regulatory Affairs Departments are available to provide you with the support you need to utilize CRA to promote housing and economic opportunity in your community. To start the process, contact NCRC at (202) 628-8866 or membership@ncrc.org.
