The CRA Podcast with Linda Ezuka

In this episode of the CRA Today Podcast, I’m joined by George Earhart and Lizann Lightfoot from GoVA Foundation, a dynamic organization delivering financial literacy resources to service members, veterans, and their families through a digital platform called The Edge.At CRA Today, our mission is to support community development professionals in transforming CRA compliance into meaningful, measurable impact. This conversation highlights how a strategic, tech-driven partnership with GoVA can help financial institutions meet CRA objectives while serving an often-overlooked low- to moderate-income (LMI) population: military families.We explore how military households face unique financial challenges due to frequent relocations, deployment-related stress, and limited access to tailored financial education. George and Lizann share firsthand insights about their community and how their platform is helping close critical financial gaps.We also discuss what makes GoVA a strong CRA partner, with case studies from successful bank collaborations across the country.💬 Key Quotes “Financial readiness is mission readiness.”“Financial literacy isn’t just about knowledge—it’s about confidence and readiness, especially for families serving our country.”“This work is about showing up for a community that gives so much, and often asks for so little.”“Banks are realizing that LMI doesn’t always look the same. The military is one of those invisible communities where the need is real, and the impact is measurable.”🌐 Connect with GoVA FoundationGoVA Website: https://www.govafoundation.org/ GoVA LinkedIn: https://www.linkedin.com/company/gova-foundation/GoVA Facebook: @myGoVAGoVA X (formerly Twitter): @myGoVA_comGoVA Instagram: @mygova_com🌐 Connect with CRA TodayCRA Today Website: https://cratoday.com/CRA Hub: https://cratoday.com/hub/CRA Today, LinkedIn: https://www.linkedin.com/company/cra-today/ Linda Ezuka, LinkedIn: https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2025 by CRA Today LLCAll rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.

As most of you know, the public file is a straightforward requirement of the CRA. Its purpose is to disclose basic information about your bank, its products and services, and how you serve the community. The file includes a wide variety of information, and here I discuss the technical requirements, what not to include, and recommendations around best practices. Tips include putting together a checklist so you don’t miss any necessary requirements. I also go over additional information you should make available to the public, the two typical versions of a public file, how to handle requests for copies of your public file, and how to cut down on unnecessary clutter. CRA Today Website: https://cratoday.com/ CRA Hub: https://cratoday.com/hubLinda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2023 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.

On October 12, 2023, we marked the 46th anniversary of the CRA. As we reflect on the past, I challenge you to consider your role in extending opportunity within your community. Here, I share a special message with our bankers who are forging an impact in our local communities. I also share a personal story about how my mother received an opportunity that changed our lives forever.While we all have different opinions on these regulations, it’s still a beautiful opportunity to change people’s lives and leverage capital for the greater good. Many come to CRA today looking to uplevel their programs, learn about best practices, and enhance their CRA training. However, once we settle in, it’s important to recommit to both the technical aspects of the CRA and the opportunity we have to provide life-changing experiences and resources to others. Here is the link to the original video message on YouTube: https://youtu.be/AJe3jCJeD9o?si=ALy85RFyyD-yAu5hCRA Today Website: https://cratoday.com/ CRA Hub: https://cratoday.com/hubLinda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2023 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.

In a recent CRA fundamentals office hours session, we discussed current practices around community development services. One bank professional asked why, at her last bank, they counted the number of hours of qualified community development services, but at her current bank, they count both the number of occurrences and hours. Both of those banks were FDIC regulated. In the past, I was with an FDIC bank, and we counted services by hours. If you’re confused, you’re not alone. Here, I explain how to look at your bank’s performance evaluation and past exams for context. I also talk about how to think about instances, how to ask regulators for guidance, and how to proceed if you want to make changes in the future. If you want to explore similar CRA compliance questions in a community of CRA professionals, you may want to consider joining the CRA Hub. It is our flagship CRA training and is the place to master the CRA, get exam ready and learn how to leverage capital for the greater good. CRA Hub: https://cratoday.com/hubCRA Today Website: https://cratoday.com/ Linda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2023 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.

In a recent webinar, I received some great tips from a panel of women who shared their journeys in leading their CRA program. I was inspired to pass them along here and share the importance of building a solid team around you in your own program.I start with a story about a private client who had to pull together her own team and the challenges that she faced. I share the three lines of defense CRA officers should put into place and the importance of reflecting on the current state of your CRA program.I also discuss why running a CRA program is like a relay, why charitable donations to market leaders could lead to more buy-in, and how assembling a working group to talk about CRA helps you look at things from different vantage points. Another great tip is to hold smaller, weekly meetings with key stakeholders to share CRA program wins and hot topics. Additionally, bringing market presidents to exit meetings helps them understand how their work impacts the ultimate CRA rating. For more information on Kadince Webinars: https://kadince.com/webinarsCRA Today Website: https://cratoday.com/ CRA Hub: https://cratoday.com/hubLinda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2023 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.

In case you missed it, I recently published an article in the ABA Compliance Magazine earlier this year. It was all about preparing for your CRA exam in the midst of regulatory uncertainty. We sure do have a lot of uncertainty swirling around these days. Although it’s easy to get distracted, I recommend you stay laser-focused on your CRA program and finish strong with your current exam cycle.Your bank will likely have one more exam under the current rules-do you know where your strengths and gaps are in each of your assessment areas? Here, I provide a couple of suggestions on how to prepare for your exam at the most basic level. I discuss where to place your focus when it comes to gathering information, cultivating a culture of compliance, and conducting a self-assessment. I also talk about CRA data integrity and why it’s so important. American Bankers Association Bank Compliance Magazine article: https://cratoday.com/finish/CRA Today Website: https://cratoday.com/ CRA Hub: https://cratoday.com/hubLinda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2023 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.

I recently walked a CRA officer through a potential loan transaction in partnership with a community development corporation, otherwise known as a CDC. As a CRA professional, you may be approached by CDCs directly, or CDCs might approach your lenders first. Either way, these mission based organizations are great partners in community development.It is estimated that there are 4,500 CDCs nationwide, and there’s likely one or several in your state. Here, I cover what CDCs are, how they came about, and what they focus on. I discuss how they partner with other community development initiatives to drive local impact. Community Development Corporations (CDCs) Resources:The term "community development corporation" means a private, nonprofit corporation whose board of directors is comprised of business, civic, and community leaders, and whose principal purpose includes the provision of low-income housing or community economic development projects that primarily benefit low-income individuals and communities. 34 U.S. Code § 12211https://www.naceda.org/index.php?option=com_dailyplanetblog&view=entry&category=bright-ideas&id=25%3Awhat-is-a-community-development-corporation-&Itemid=171https://case.edu/ech/articles/c/community-development-corporationshttps://www.urban.org/sites/default/files/publication/60731/410638-Community-Development-Corporations-and-their-Changing-Support-Systems.PDFHere is one of my favorite resources mentioned in this episode:https://www.dallasfed.org/~/media/documents/cd/pubs/craloan.pdfHere is another article that highlights the importance of partnering with your lenders to drive community development impact:https://cratoday.com/driving-impact-and-building-trust-the-power-of-collaboration-between-compliance-professionals-and-lenders-in-community-development-lending/CRA Today Website: https://cratoday.com/ CRA Hub: https://cratoday.com/hubLinda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2023 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.

Sarah Hope Marshall joins me here to reflect upon digital inequity in place-based community revitalization. Our discussion focuses on digital inequity and how community development professionals can revisit this as they revisit their community development programs. Here are some key quotes from our conversation:“It made me pause and ask, wait a minute. This neighborhood that we’re in has a really rich history of community organizing and groups working together. There’s been books written about it. In my research, I’d done work studying the first-ever tenant buyout of a HUD affordable building that was turned into co-ops in this neighborhood I was working in. And so, I started asking the question, What happens when technology allows people to be more mobile, to be less attached to the community in the place they’re in?”“If you think about the trajectory of where we are, CRA and the CDFI fund and the way that was initiated really came about because of place-based community organizing. And now, we’ve come to a place where technology has really expanded our social networks so that we’re constantly communicating with people all over the country.”“It’s a different dynamic, and we adopt things slowly, so we don’t always pause to say, wait. How has my world changed because of technology?”“I’ve been excited to see things that have developed and researchers who are working on things like tech ethics, digital equity, and the digital divide, but there’s still just a lot that’s unknown in terms of how technology’s really impacting our socioeconomic mobility and the choices that we have.”“There’s an initiative called the National Collaborative for Digital Equity that has started a campaign called One Percent for Digital Equity, and the call is to ask CRA officers to commit one percent of their CRA budget to digital equity. It’s opened up a really powerful funding stream for organizations who are trying to do this work.” “Digital equity really doesn’t have to be a new project, program, or strategic plan, but an overlay. Because if we think about the way technology really overlays everything we do and how we function as a society and our roles, it’s just a matter of pausing to ask those questions and encouraging the people that we interact and work with to ask those hard questions so that we’re achieving the goals that we set out to achieve.” Contact Info for Sarah:Sarah Hope Marshall1-773-595-0974sarahhope@profoundhopeindustries.comsubdomain.profoundhopeindustries.com/digital-equityArticle: Reckoning with Digital Inequity in Place-Based Community Revitalization: https://www.jpna.org/index.php/jpna/article/view/8731% for Digital Equity Campaign: https://www.digitalequity.us/1-for-digital-equity/Article Abstract:Place-based community development in America has a rich history. Practices and procedures for successful redevelopment are supported by lobbying efforts, public administration, policy, federal funding, and the efforts of non-profits dedicated to neighborhood revitalization. Community revitalization work is often centered around specific geographic locations, while in recent decades modern technology has caused social networks to become increasingly geographically disparate. Social networks have been demonstrated to support the economic mobility that community development strives to create. However, the impact of modern technology on place-based community development has not been clearly understood. Increasing digitalization has impacted the effectiveness of place-based social equity efforts such as community organizing, affordable housing and economic development, and financial capability interventions. This essay explores how place-based community organizing led to the creation of current policies that govern community development, how technology has impacted urban communities and how these changes may subsequently affect social equity objectives in public administration.CRA Today Website: https://cratoday.com/ CRA Hub: https://cratoday.com/hubLinda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2023 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.

Your previous CRA exam may not have included pandemic activities, but your next one is likely to include activity around the SBA’s Paycheck Protection Program, or PPP. You can get credit for participating in the PPP under your CRA program, which translates into CRA lending performance. Your next exam would highlight your participation in the program, and you would also account for the individual loans that were deployed under the program, either as small business lending performance or community development loan activities. Here, I share how to classify these PPP loans and how to tell if your PPP loans count as community development loans. I also discuss mining for other community development loans and “hooks”. Make sure to check out the SBA’s guidance on PPP loans, linked below.Frequently Asked Questions (FAQs) on the Small Business Administration’s Paycheck Protection Program – March 3, 2021: https://www.fdic.gov/coronavirus/smallbusiness/faq-sb.pdfCRA Today Website: https://cratoday.com/ CRA Hub: https://cratoday.com/hubLinda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2023 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.

Recently, I was approached by a CRA professional in the industry who was about to be examined. They were working on compiling all their community development loans, and they got a bit turned around when reviewing their loans to nonprofit organizations as asked for guidance.I advise bankers to conduct a 100% review of a bank’s loans to nonprofit organizations due to the charitable nature of the nonprofit entities. This doesn’t guarantee community development qualification but I find many of these loans are prospects to dig deeper into. In this episode, I break down each community development hook, including affordable housing, community services, economic development and revitalization. I also walk through how to properly document non-profit loans if they fall under one of these community development categories. We spend a lot of time within the CRA Hub vetting community development loan prospects and work together to find the most appropriate and most defensible community development “hook” that will withstand examiner scrutiny. Enjoy the episode and happy CD loan mining! CRA Today Website: https://cratoday.com/ CRA Hub: https://cratoday.com/hubLinda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2023 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.

I recently received a question from someone newer to the CRA within an intermediate small bank (ISB). They knew they didn’t have to report their lending data but wanted to know if they needed to actually review it. Additionally, if they did need to review it, they wanted to know how they would do so. I referred them to the Banker’s Quick Reference Guide I’ve linked below. It’s one of my favorites because it’s a quick review of all performance standards and shows you how examiners evaluate performance.Here, I outline the best practices I shared in response to this question. Although ISBs aren’t required to report, it’s important for you to know what your performance is before the examiners. Pulling your data on at least an annual basis and reflecting on some of the key performance standards is highly recommended.A Banker’s Quick Reference Guide to CRA, Federal Reserve Bank of Dallas: https://www.dallasfed.org/~/media/documents/cd/pubs/quickref.pdfCRA Today Website: https://cratoday.com/ CRA Hub: https://cratoday.com/hubLinda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2023 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.

Naturally occurring affordable housing (NOAH) are residential rental properties that are affordable, but unsubsidized by any federal program. The rents are relatively low compared to regional housing markets. From a CRA standpoint, we might be mining for community development loans, so it’s important to look at our commercial real estate portfolios, which may include NOAH.Here, I cover the questions to ask while reviewing commercial real estate transactions. I also cover the two measures to use to determine if rents are affordable for low to moderate income people. It’s important to work closely with your commercial real estate lenders to uncover transactions in a portfolio that would qualify as a community development loan. HUD Fair Market Rents: https://www.huduser.gov/portal/datasets/fmr.html McKinsey & Co Report re Naturally Occurring Affordable Housing: https://www.mckinsey.com/industries/public-sector/our-insights/preserving-the-largest-and-most-at-risk-supply-of-affordable-housing OCC Community Development Fact Sheet re Community Development Activities: https://www.occ.gov/publications-and-resources/publications/community-affairs/community-developments-fact-sheets/pub-fact-sheet-cra-comm-dev-loans-invest-svcs-jan-2019.pdf CRA Today Website: https://cratoday.com/ CRA Hub: https://cratoday.com/hubLinda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2023 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.

In the past, regulations narrowly defined the provision of financial services. To qualify a community development service, it has to have a primary purpose of community development, be offered on behalf of the bank, and must be related to the provision of financial services. Back then, this meant traditional banking, like creating a spreadsheet or something financial in nature. Here, we cover the updated definition of the provision of financial services to expand eligible community development service activities.Interagency Questions and Answers Regarding Community Reinvestment: https://www.govinfo.gov/content/pkg/FR-2016-07-25/pdf/2016-16693.pdfThe specific citation from the above linked resources referenced within this podcast episode is the following: § ll.12(i)–3: What are examples of community development services? A3. Examples of community development services include, but are not limited to, the following: • Providing technical assistance on financial matters to nonprofit, tribal, or government organizations serving low and moderate-income housing or economic revitalization and development needs • Providing technical assistance on financial matters to small businesses or community development organizations, including organizations and individuals who apply for loans or grants under the Federal Home Loan Banks’ (FHLB) Affordable Housing Program • Lending employees to provide financial services for organizations facilitating affordable housing construction and rehabilitation or development of affordable housing • Providing credit counseling, homebuyer and home maintenance counseling, financial planning or other financial services education to promote community development and affordable housing, including credit counseling to assist low- or moderate-income borrowers in avoiding foreclosure on their homes • Establishing school savings programs or developing or teaching financial education or literacy curricula for low- or moderate-income individuals; and • Providing foreclosure prevention programs to low- or moderate-income homeowners who are facing foreclosure on their primary residence with the objective of providing affordable, sustainable, long-term loan modifications and restructurings. [Specific examples related to the provision of financial services] Examples of technical assistance activities that are related to the provision of financial services and that might be provided to community development organizations include • serving on the board of directors • serving on a loan review committee • developing loan application and underwriting standards• developing loan-processing systems • developing secondary market vehicles or programs • assisting in marketing financial services, including development of advertising and promotions, publications, workshops and conferences • furnishing financial services training for staff and management • contributing accounting/ bookkeeping services • assisting in fund raising, including soliciting or arranging investments; and • providing services reflecting a financial institution’s employees’ areas of expertise at the institution, such as human resources, information technology, and legal services. Refer to Q&A §ll.24(a)—1 for information about how retail services are evaluated under the large institution service test. Community Development Financial Institutions are also mentioned in this episode. Community development financial institutions (CDFIs) are lenders with a mission to provide fair, responsible financing to rural, urban, Native, and other communities that mainstream finance might not traditionally reach. CDFIs specialize in lending to individuals, organizations, and businesses in under-resourced communities, offering clients financial education, business coaching, and low-interest rate loans that increase economic potential and help build wealth.CDFI lending leads to small businesses and homeownership, creates living wage jobs, supports the development of schools, grocery stores, and health care centers, finances climate change solutions, and so much more: https://www.ofn.org/what-is-a-cdfi/CRA Today Website: https://cratoday.com/ CRA Hub: https://cratoday.com/hubLinda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2023 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.

I received an email from a CRA officer who recently took over a CRA program. Although this individual is a seasoned compliance professional, she’s new at running a CRA program, and the exam was right around the corner. Here, I share her journey and tips to document community development activities. When it comes to community development services documentation, there isn’t a one-size-fits-all solution. Many of our bankers will use various annual reports, tax returns, and even websites to gather the information they need. I recommended that this CRA officer go back and embed a process, so she gets what she needs to prove the primary purpose of community development. This helps when time is of the essence and you need to pull information together quickly. Shoring up your program prevents scrambling at the last minute. When we get that notice of the CRA exam, proper documentation can be a lifesaver. Interagency Questions & Answers Regarding Community Reinvestment (Questions and Answers) were released by the staffs of the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency on July 15, 2016, to provide guidance to financial institutions and the public.Guidestar.org is also a good resource to learn more about nonprofit organizations, their mission, and even review their IRS Form 990 (their version of a tax return).Outstanding: A Practitioner's Guide to CRA Exam Readiness: https://a.co/d/cRze5F1CRA Today Website: https://cratoday.com/ CRA Hub: https://cratoday.com/hubLinda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2023 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.

As referenced in the episode, you may want to download our free regulatory change checklist: https://cratoday.com/regulatory-change-checklist/We created this checklist to support your focus on the most pressing issues faced by your bank and to spark critical conversations with key stakeholders within the bank to determine your path forward.There are several operational and financial risks associated with the new proposed CRA rules. First, you’ll need to formalize our compliance documentation and map out your CRA framework. Taking a bird’s eye view of your CRA program from a compliance management system "CMS" standpoint will help you make sure you have proper oversight and integration.You’ll also need to address your systems and vendor reliance to adjust to the proposed increase in reporting and performance analytics. Staffing turnover, the higher cost of talent, and additions to staff also need to be taken into careful consideration. There will be an increased cost of compliance within business units, and certainly within your CRA program, so it’s important to have conversations with executive management and key stakeholders.Make sure your bank is adequately resourced to maintain CRA performance and increase the proposed provisions. Planning now will help you finish strong in the current regulatory environment and adapt to upcoming regulatory changes. Download the checklist today and continue to explore the implications of regulatory changes. We also have the CRA Hub to support your path through regulatory change! We’ve got you! CRA Today Website: https://cratoday.com/ CRA Hub: https://cratoday.com/hubLinda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2023 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.

Regulators are continuing to enhance their focus on oversight, supervision, and enforcement, and the CRA is no exception. We expect this increased scrutiny to ramp up throughout 2023. What was acceptable before is no longer acceptable in today’s environment, and the bar has been raised. Embedded CRA rating deflation in the new proposed CRA rule opens us up to more reputational risk if we aren’t able to get out and serve our communities.There’s increased pressure on banks to defend their current banking practices and the way they redeploy capital into local communities in an equitable way. This translates into more community input and expectations, which increase reputational risk. We need to consider this as we work to build out our CRA strategic plans and adapt to the new rule once it’s implemented. Included here are some strategic discussion points that you may wish to have with your key stakeholders.Listen in to part two of this three part series on regulatory change. I have also compiled a free resource that will support you as you start to prepare your bank for this monumental shift in managing risk and your CRA program. Get the CRA Regulatory Change Checklist here: https://cratoday.com/regulatory-change-checklist/CRA Today Website: https://cratoday.com/ CRA Hub: https://cratoday.com/hubLinda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2023 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.

It’s going to be a year-end like no other, and regulatory change continues to be front and center. There are several key compliance risks to be aware of and elements to reflect upon as a CRA officer. Regulators will continue to enhance their focus on oversight, supervision, and enforcement.The adaptation to new regulations, market disruption, and expected lack of clear guidance and training from regulators will increase our risk to regulatory change. Our regulators are also adapting, and whenever there’s something new, there will be uncertainty on both sides as the changes are implemented. State agencies are also getting more involved in regulatory oversight and coming up with their own approaches to CRA and banking. There’s also an increase in fair lending risk and an increased interest in climate change and the impact of natural disasters on lower income populations. Listen in to part one of this three part series on regulatory change. I have also compiled a free resource that will support you as you start to prepare your bank for this monumental shift in managing risk and your CRA program. Get the CRA Regulatory Change Checklist here: https://cratoday.com/regulatory-change-checklist/CRA Today Website: https://cratoday.com/ CRA Hub: https://cratoday.com/hubLinda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2023 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.

We’re taking a deeper dive into the economic development hook, which is often an overlooked aspect of community development loans. However, it plays a crucial role in strengthening local economies. Here, you’ll learn how to identify community development loans that were originated for small businesses to support your portfolio.Remember, when qualifying for a CD loan under the economic development hook, you’ll need to meet the size and purpose test. The criteria to meet the test are: The borrower must be considered a bona fide small business per Small Business Association (SBA) standards. You can view their standards here: U.S. Small Business Administration Table of Small Business Size StandardsThe borrower or purpose of the loan must also retain or create jobs for low or moderate-income individualsCredit write ups don’t usually include salaries or job information, CRAs have to make their own assumptions. The CRA Q&A has tools and guidelines to help you make the best assumptions possible. Here, I include some examples of common small businesses that qualify under the economic development hook.You can reference the Bureau of Labor Statistics to document information on representative jobs and income levels. This publication is intended as a quick guide for identifying CRA loan data reporting categories. It is designed for bank CEOs, presidents, CRA and compliance officers, and others who have an interest in the CRA loan data collection process. Refer to Regulation BB, Regulation C, and the instructions for the preparation of the Consolidated Reports of Condition and Income for more detailed information. CRA Today Website: https://cratoday.com/ CRA Hub: For more Community Reinvestment Act training resources, check out the Hub! https://cratoday.com/hubLinda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2023 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.

This episode will lay the foundation for community development loans as it relates to your CRA program. Community development loans must have a primary purpose of community development. You will need to follow the loan proceeds to the intended primary impact that resulted from originating a loan to the borrower.An “oldie but goodie” resource is the Office of the Comptroller of the Currency’s Community Developments Fact Sheet published by the Community Affairs team.Within this resource, the primary purpose of community development is defined as follows:Under the CRA, community development activities • Support affordable housing for low- or moderate-income (LMI) individuals, including multifamily rental housing. • Target community services to LMI individuals.• Promote economic development by financing businesses or farms that have gross annual revenues of $1 million or less or that meet the size eligibility requirements of the U.S. Small Business Administration’s (SBA) Small Business Development Company or Small Business Investment Company (SBIC) programs. • Revitalize or stabilize LMI geographies; designated disaster areas; or distressed or underserved nonmetropolitan middle-income geographies designated by the OCC, the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation. [Source OCC publication linked above]This guide from the Federal Reserve Bank of Dallas is an excellent resource and one I still use several times a month. This publication is intended as a quick guide for identifying CRA loan data reporting categories. It is designed for bank CEOs, presidents, CRA and compliance officers, and others who have an interest in the CRA loan data collection process. Refer to Regulation BB, Regulation C, and the instructions for the preparation of the Consolidated Reports of Condition and Income for more detailed information. CRA Today Website: https://cratoday.com/ CRA Hub: For more Community Reinvestment Act training resources, check out the Hub! https://cratoday.com/hubLinda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2023 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.

NCRC Community Development Fund, a subsidiary of the National Community Reinvestment Coalition, lends primarily to Black, Latino, women, and immigrant entrepreneurs and business owners throughout the country with its mission to help bridge the racial wealth divide by supporting entrepreneurship and affordable homeownership in America’s underserved communities.Its new lending platform – for which it is also building an algorithm to determine loan eligibility – stands to make the roughly 10-person operation more efficient, Marisa Calderon, NCRC CDF’s executive director, said in a recent interview.This episode of the CRA Podcast addresses the promise of CDFI lending, partnerships with financial institutions to support the continuum of capital for disadvantaged communities, and how the Community Development Fund is also building a new lending platform leveraging AI to not only support efficiencies in their operation but also for others in the CDFI industry. Marisa Calderon’s Bio and ExperienceMarisa Calderon is an experienced executive who is regularly recognized, awarded and cited nationwide for her expertise in the housing and financial services industries. She has over two decades of experience dedicated to the issues of economic mobility and bridging America’s racial wealth gap. Marisa Calderon is the executive director at NCRC Community Development Fund (NCRC CDF), a nonprofit, U.S. Treasury-certified community development financial institution (CDFI) that provides loan capital to expand access to affordable homeownership, which helps Black-, Brown- and woman-owned businesses thrive. Under her leadership in her first 18 months at NCRC CDF, they deployed over $17 million in capital to historically underserved Black, Latino, immigrant, and women entrepreneurs through their small business and investment programs, earning them a place on Fast Company’s list of 2022 Most Innovative Companies in the World. She is also chief of community finance and mobility at the NCRC CDF’s parent company, the National Community Reinvestment Coalition (NCRC), where her work focuses on advancing economic mobility for communities impacted by systemic inequality and disinvestment. Marisa is ranked on the Swanepoel Power 200 as one of the most powerful leaders in the residential real estate industry, and was twice named a HousingWire Woman of Influence in 2018 and 2021 for her work in increasing real estate and mortgage professionals’ understanding and appreciation of the Hispanic home-buying market. In 2021, she was named one of Diversity Journal’s Women Worth Watching in Leadership and was featured in Hispanic Stars Rising: The New Face of Power and was recognized on Women We Admire’s list of the Top 50 Women Leaders in Finance of 2022. Frequently sought out as an expert on affordable housing, lending and immigration, Marisa has been interviewed by numerous publications and media outlets, including NPR’s Marketplace and does regular public speaking at industry and general market events, including Mortgage Banker’s Association, FDIC, Consumer Federation of America, National Fair Housing Alliance, and many others. In addition to this work, Marisa is also a board member of the non-partisan political action committee, Latinas Lead California and a Senior Advisor to America’s Homeowner Alliance.CRA Today Website: https://cratoday.com/ CRA Hub: https://cratoday.com/hubLinda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2023 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.

This episode of the CRA Podcast highlights the community development work of Joshua Kummer of Bankers Trust. Joshua is the bank’s CRA and Fair Banking Officer overseeing the bank’s Fair Banking Program, which includes CRA, Fair Lending, HMDA, UDAAP, and Complaint Management. You will find Joshua to be very passionate about this work and this episode shares the high impact community development partnerships he has forged within his community. Not only does he have the heart for this work; you will also hear how his passion and drive has helped Bankers Trust sustain an Outstanding Community Reinvestment Act (CRA) rating!Here are the programs that are referenced within the episode:Community Development Financial Institutions (CDFI) Involvement Iowa Community CapitalSolidarity Microfinance is a non-profit program of Iowa Community Capital to create economicopportunities through small business loans, training and support, and savings services.ICC's Solidarity Microfinance program provides small loans of $500 to $8000, savings services, and financial learning opportunities for eligible low-income entrepreneurs in the Greater Des Moines Metro Area. The Solidarity Microfinance program uses Grameen peer-group lending methodology and targets women entrepreneurs from diverse new resident cultures. Neighborhood Finance CorporationNFC provides unique lending programs and other services to facilitate neighborhood revitalization in Polk County and Cedar Rapids, Iowa through partnerships with residents, governments, community-based organizations, lending institutions and the business community. For more information on our programs and services, please visit our Loan Programs page. NFC is a proud Chartered Member of NeighborWorks America. TrellisTrellis (originally started as Neighborhood Housing Services of Phoenix) was formed in 1975 with help from the City of Phoenix and NeighborWorks America. NeighborWorks America is a national nonprofit organization, federally funded by appropriations from Congress that provide financial support, technical assistance and training for community-based revitalization efforts in all 50 states.Access to homeownership is for all of us. Individuals and families become stable and more economically secure; neighborhoods become vital, active communities; and cities gain jobs and tax revenues. It’s an investment with positive returns for everyone.Other Community Involvement InitiativesHOME, Inc.HOME, Inc. is the oldest private nonprofit housing organization in Des Moines. Our mission is to meet individuals and families where they are in their housing journey. We surround our clients with compassion, support, and education so they feel empowered to make a safe, stable home for themselves or their family. To accomplish our mission, we…– Provide counseling and education to help people become successful homeowners, landlords, and tenants.– Develop, rehab, and build affordable housing units.– Help families through counseling and education to become homeowners.Newtown Community Development CorporationOur mission is to help people improve their financial well-being while strengthening communities through education, counseling, coaching, and the development and stewardship of permanently affordable homes.Newtown Community Development Corporation (Newtown) is a Tempe-based nonprofit founded in 1994. Newtown is recognized throughout the Phoenix Metro Area as a leading provider of homebuyer education, homeownership counseling, credit counseling, financial coaching, financial literacy education, and down-payment assistance. Newtown is a HUD-Approved Housing Counseling Agency and adheres to national industry standards for homeownership education and counseling. Services are provided in English and Spanish.Newtown also operates an innovative Community Land Trust, which builds and renovates permanently affordable houses, providing successful homeownership opportunities for generations of lower-income families. Created in 2001, Newtown’s Community Land Trust is the largest in Arizona with homes across Maricopa County.BIOJoshua Kummer is the AVP, Fair Banking Officer at Bankers Trust; Iowa’s largest privately owned bank headquartered in Des Moines, Iowa with assets totaling over $6 billion. The bank operates branches in Central Iowa, Cedar Rapids, IA, and Phoenix, AZ, as has offices in Omaha, NE and Sioux Falls, SD. Joshua started his banking career over 11 years ago as a part-time teller while attending college. Since then, he’s held various positions including Personal Banker, Sales & Service Manager, Branch Manager, CRA Officer and now Fair Banking Officer. He holds two compliance-related certifications: Certified Community Bank Compliance Officer (CCBCO) and Fair Lending Expert (FLE). He is also involved in his community and currently sits on the Neighborhood Finance Corporation Board of Directors, Greater DesMoines Habitat for Humanity Access to Credit Committee, Iowa Bankers Association DEI Committee and Special Olympics Iowa Fundraising Committee. Joshua has a passion for ensuring customers receive fair and equitable treatment while banking with Bankers Trust and advocates for those with limited financialresources. Bankers Trust: As Iowa’s largest privately owned bank, Bankers Trust serves the personal and business banking, lending and wealth management needs of our community.Bankers Trust Core Value: CommunityWe will strive to be the best corporate citizen by supporting diverse community organizations, both financially and through employee volunteerism. We invest in the community by nurturing and encouraging growth, stability and continued success.

Hi, it's Linda with CRA today and the CRA Hub. I thought I'd hop back here and give you a quick tip. So many of you have asked "what exactly is BLS (hint, it is the Bureau of Labor Statistics) and how should I use it to support my CRA program?" Well this month in the CRA Hub, we're focusing on CRA exam prep. As you know, it's really important to make sure that we are crossing our T's and dotting our I's and making sure that all of our community development activities are properly documented. Well, this is where the website bls.gov comes in. This website will help you substantiate the creation or retentions of jobs for low and moderate income people. The BLS website is where you can go to create the documentation or the proof, to show your examiners during an exam to substantiate community development loans and activities, as applicable. So let’s take a $1.5M community development loan that your bank originated to a restaurant to expand to a new location. You would first document that the borrower is considered a small business and then you will need to document and prove that the majority of the jobs created as a result of your financing would in fact be jobs for low and moderate income individuals. Given my description so far, you may know you are working towards documenting this community development loan under the economic development hook, right? So after you document all other aspects of the community development loan and you are down to documenting the creation of jobs for LMI individuals. So you go to BLS.gov and you search for jobs that typically would be found in a restaurant, like cooks, waiters, bartenders. I tend to keep two or three, as an example is my backup files for examiners. And then you can drill down to the different geographies within Bureau of Labor Statistics (BLS). So I recommend getting as close as you can to the geographic location of the business that you are documenting the community development loan for aka “follow the money” to the community development impact.Here is the link to the screen share overview of BLS.gov: https://www.loom.com/share/2ae5b997547343a2b33ce9413db17598You would take these representative jobs and compare the salaries against area median income to make sure these annual salaries fall below the thresholds for a moderate-income person in the area for which the loans proceeds are applied. I hope this helps you as you continue to mine for community development loans and then also document your CD loans. I often say, if it’s not properly document, it didn’t really happen! The “art of the CRA” as I say is to properly document all of your activities to support an efficient review by your examiners and this “pre-work” if you will will also allow you to defend your position with confidence. CRA Today provides Community Reinvestment Act Training, Professional Development, and a new Certification for CRA professionals. We Help You Master the CRA, Get Exam-Ready, and Reinvest for the Greater Good.Want to learn the CRA basics? Sign up for CRA Essentials Live! A live webinar with Linda Ezuka that shares everything you need to create a solid foundation for your CRA journey. https://hub.cratoday.com/freewebinarReady to take a deeper dive into the CRA? Join your fellow CRA enthusiasts in the CRA Hub as we navigate regulatory change, study core CRA concepts and connect as community development professionals across the nation.https://cratoday.com/hub/CRA Today Website: https://cratoday.com/ Linda Ezuka, LinkedIn: https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2022 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.

CRA Podcast Episode 16: Community Development Loans Demystifiedwith Krista Shonk, VP & Senior Counsel, Regulatory Compliance and Policy, Fair & Responsible Banking, ABAAre you one of the 95 percent of banks that are underreporting community development loans under the Community Reinvestment Act (CRA)? This episode debunks the myths around how to recognize community development loans at the time of loan origination and how to avoid expensive loan mining activities at the tail end of your compliance processes.Community development loans are the most heavily weighted aspect of the CRA, and when you understate your community development loans you are compromising your bank's lending performance. As you know, if you don’t meet the credit needs of your communities, it can lead to public relations risks that could even result in an internal “needs to improve” rating or hamper your ability to adjust your bank’s strategy priorities.ABA’s Krista Shonk interviews Linda Ezuka of CRA Today in this focused episode on the most subjective aspect of the CRA. Identifying community development loans requires many internal stakeholders within the bank and this episode highlights a solid approach to engage commercial lenders in identifying loans that are hidden within their portfolios and their loan pipelines. Most lenders are focusing on meeting the credit needs of their commercial clients and overlook common community development loans due to a lack of understanding of the CRA. The key to engaging commercial loan officers is to conduct community development loan training. Use this training to highlight the community development "hooks" or pillars to determine if their loans meet the primary purpose test.Ongoing micro-training moments are key to keep community development loans top of mind thereafter.Enjoy this episode that breaks down strategies to identify community development loans at origination and how to avoid underreporting these important loans. If you want to take a deeper dive into this work to learn how to increase your community development loan portfolios, consider our community development loan workshop of customized bank training for commercial loans officers. See below for more information. Links: Customized Bank Training: https://cratoday.com/cra-training/ Check out our website to take the next step in your CRA journey today: www.cratoday.com Copyright © 2022 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.

Are you looking to take your community development services to the next level? If so, don’t underestimate the breadth and depth of internal expertise that lies right at your fingertips. Your bank is likely full of subject-matter experts that can enhance your existing services or perhaps even build out an entirely new external partnership.While banks typically engage mortgage officers, lenders, and retail team members with opportunities to teach financial education in the community, other departments have a wealth of technical expertise to offer. Employees’ technical expertise in core business functions can result in the creation of deliverables at the end of a short project (i.e. creating a social media strategy, designing a logo, conducting a technology assessment) or can result in actionable recommendations. Think of your employees as pro-bono consultants. For example, consider how you might leverage the internal expertise found in these departments to drive the positive and meaningful impact your organization has on the community. (Ensure the benefitting organization meets one of the four community development purposes!)• Compliance: Serve as a subject-matter expert at a small business fraud prevention workshop or a consumer protection workshop (identify theft, fraud prevention, common types of financial exploitation, etc).• Human Resources: Teach on workforce development topics such as resume prep, interview tips. Serve on an advisory board for a nonprofit focused on financial service career pathways for LMI individuals. Consult with an organization as they develop an employee handbook.• Marketing: Create collateral (brochure, etc.) or a logo pro-bono for a local nonprofit. Help a nonprofit or small business develop a social media strategy.• IT: Serve on an advisory board for a nonprofit focused on financial service career pathways for LMI individuals. Conduct a technology assessment for an organization. Assist with the installation of new software/hardware.• Accounting: Provide assistance on accounting/bookkeeping. Help organizations review internal controls and policies.• Legal: Review contracts, etc. pro bono.CRA Today helps bankers master the Community Reinvestment Act, get exam ready, and change lives through the power of community development.Want to learn the CRA basics? Sign up for CRA Essentials Live! A live webinar with Linda Ezuka that shares everything you need to create a solid foundation for your CRA journey. https://hub.cratoday.com/freewebinarReady to take a deeper dive into the CRA? Join your fellow CRA enthusiasts in the CRA Hub as we navigate regulatory change, study core CRA concepts and connect as community development professionals across the nation.https://cratoday.com/hub/CRA Today Website: https://cratoday.com/ Linda Ezuka, LinkedIn: https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2022 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.

There are a wealth of opportunities to serve aspiring entrepreneurs and established small businesses!Consider the following opportunities to diversify your portfolio of existing community development services and ensure that some of them meet the “Economic Development” community development purpose.• Contact your local CDFIs and other small business development nonprofits and inquire about committee or board openings. Some might even have opportunities for lenders to serve as mentors to local entrepreneurs or to serve on a one-time committee that provides constructive feedback on the entrepreneurs' business ideas. • Reach out to local Small Business Development Centers and see if one of your lenders can teach a class or serve on a panel about accessing capital. Consider inviting a credit union, a CDFI, and another type of bank to join the panel as well. Each one will have a unique perspective to provide!• Volunteer with your local SCORE chapter, where opportunities include serving as a Business Mentor, Subject Matter Expert, Local Workshop Presenter, and more.CRA Today helps bankers master the Community Reinvestment Act, get exam ready, and change lives through the power of community development.Want to learn the CRA basics? Sign up for CRA Essentials Live! A live webinar with Linda Ezuka that shares everything you need to create a solid foundation for your CRA journey. https://hub.cratoday.com/freewebinarReady to take a deeper dive into the CRA? Join your fellow CRA enthusiasts in the CRA Hub as we navigate regulatory change, study core CRA concepts and connect as community development professionals across the nation.https://cratoday.com/hub/CRA Today Website: https://cratoday.com/ Linda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2022 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.

After collecting information about existing employee involvement through board service and volunteerism, it’s apparent you need to increase your bank’s community development services…but where do you start?First, look at your bank’s existing community development services and consider whether you can expand or deepen that relationship by providing additional services. Is the organization looking for new board or committee members with financial expertise? Could their clients benefit from financial capability workshops or workforce development support such as resume reviews?Second, are there local affiliates of national organizations that you might be able to support in each of your assessment areas? Through Junior Achievement your employees could teach a curriculum focused on financial literacy and career readiness in local schools with free-and-reduced-lunch rates greater than 51%. Through Habitat for Humanity, an employee could review homeowner applications to ensure applicants can afford the mortgage while serving on a Family Selection Committee. Third, don’t be afraid to get creative! Consider meeting with the local community foundation or United Way chapter to learn about the greatest needs in the communities you serve. Oftentimes these organizations are the first to know about board or committee opportunities in the community and can direct you towards organizations that serve low-to-moderate-income individuals or small businesses and that align with CRA community development purposes. The sky is the limit to what you could build together! For some inspiration, read the OCC’s Financial Capability Fact Sheet. https://www.occ.gov/publications-and-resources/publications/community-affairs/community-developments-fact-sheets/pub-fact-sheet-financial-capability-jan-2019.pdfCRA Today helps bankers master the Community Reinvestment Act, get exam ready, and change lives through the power of community development.Want to learn the CRA basics? Sign up for CRA Essentials Live! A live webinar with Linda Ezuka that shares everything you need to create a solid foundation for your CRA journey. https://hub.cratoday.com/freewebinarReady to take a deeper dive into the CRA? Join your fellow CRA enthusiasts in the CRA Hub as we navigate regulatory change, study core CRA concepts and connect as community development professionals across the nation.https://cratoday.com/hub/CRA Today Website: https://cratoday.com/ Linda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2022 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.

I estimate that at least 90% of banks under report their community development loans. Yes, that’s an alarming statistic, but I believe it's true. As I often say, the art of the CRA is not creating new programs, but actually unveiling what your bank is already doing to meet the needs of your community by the nature of opening your doors and deploying your core banking services. Recently, I have been conducting many customized bank training sessions for commercial loan officers. We use the bank’s credit approval memorandums and take a deep dive into originated loans to reveal hidden community development purposes. It’s fun! The look on their faces when they realize they originated community development loans and they didn’t even know it! It’s priceless. I also offer a follow up Q&A session where the loan officers get to review their pipeline with me and ask me anything. Again, like magic, there are more community development loan prospects on the table. Here is what a senior commercial lender shared… “Linda’s webinar provided CRA/CDL training that gave us the depth of knowledge to more accurately identify opportunities that we had been missing for years. Past trainings left us with more questions than answers. Her presentation was customized to our needs and our commercial lending team dealt with actual loans that we selected. We also had the opportunity to ask experience based questions and receive in depth answers that opened people’s eyes. Since the webinars, we have taken a deeper dive into our loan closings since our last exam and found numerous cases of economic development and affordable housing loans that had not been reported. Very well worth the time and cost that will pay dividends over the years.” ~Chuck Woerner, SVP , Senior Commercial Lender, Fairfield County BankYou don’t need me to do this training, but if you have too much on your plate, this is a good option too. Either way you approach this training, it is imperative to have a strategy in place or you will be underreporting your community development loan portfolio which compromises your lending performance and your overall CRA rating. What do you have planned to engage with your commercial lending officers? Make sure you outline a solid strategy to build these critical relationships and support them in identifying community development loans. The return on your investment of time is priceless! CRA Today helps bankers master the Community Reinvestment Act, get exam ready, and change lives through the power of community development.Want to learn the CRA basics? Sign up for CRA Essentials Live! A live webinar with Linda Ezuka that shares everything you need to create a solid foundation for your CRA journey. https://hub.cratoday.com/freewebinarReady to take a deeper dive into the CRA? Join your fellow CRA enthusiasts in the CRA Hub as we navigate regulatory change, study core CRA concepts and connect as community development professionals across the nation.https://cratoday.com/hub/CRA Today Website: https://cratoday.com/ Linda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2022 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.

A key element of your CRA program is understanding that CRA is not always about creating new opportunities, but is about finding the opportunities that already exist. To do this, you should aim to give each team at least three CRA trainings a year. This will keep team members up-to-date on any new regulations and will help keep your program top of mind. Team members are more likely to forget about CRA when they haven’t heard from you in a long time. But if you train team members to watch out for CRA opportunities, you’re almost guaranteed to come across new services, loans, and investments that are eligible for CRA credit. So who do you train, you ask? It depends on your bank size and structure, but here is a common list of trainings: New Hire Training: The first introduction to CRA, do this in person or recorded, keep it quick and high level. CRA Essential Live - https://hub.cratoday.com/freewebinarBankwide Training: Keep this high level and part of your LMS (your learning management system). Highlight how everyone has a role in the CRA program (service etc). Commercial Lending Partners: This includes small businesses, commercial lending, commercial real estate, all aimed to help you identify community development loans! You can do this yourself or I also help train commercial loan officers using their own credit documents! -https://cratoday.com/cra-training/ Don’t forget loan ops too, not only for community development loan identification, but also for data integrity training! Other departments include Marketing, Investments, Controllers etc. The list can go on and on! The bottomline here is you need to have a solid training plan in place based on your bank size and plan to deploy training on a periodic basis. And don’t forget to keep it light and fun! CRA Today helps bankers master the Community Reinvestment Act, get exam ready, and change lives through the power of community development.Want to learn the CRA basics? Sign up for CRA Essentials Live! A live webinar with Linda Ezuka that shares everything you need to create a solid foundation for your CRA journey. https://hub.cratoday.com/freewebinarReady to take a deeper dive into the CRA? Join your fellow CRA enthusiasts in the CRA Hub as we navigate regulatory change, study core CRA concepts and connect as community development professionals across the nation.https://cratoday.com/hub/CRA Today Website: https://cratoday.com/ Linda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2022 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.

“One of the things that are appealing to me about being a Community Reinvestment Officer is helping those who are underserved,” says Melvin Hugans, a Community Reinvestment Officer at Thomasville National Bank. In honor of National Financial Capability Month, where financial institutions and organizations support programs that promote economic empowerment, host Linda Ezuka interviews Melvin Hugans on his life as a CRA officer. A retired elementary school principal with a history of non-profit community work, Melvin is now on a mission to educate America’s youth on the benefits of financial literacy.With debt on the rise in America, people need financial literacy more than ever. Understanding this all too well, Melvin works to educate young people on how they can start saving and create spending plans now. Through Thomasville National Bank, a company whose mission is to promote economic development in their community, Melvin can continue doing what he loves while bettering the lives of others. Tune into this week’s episode of CRA Podcast for a meaningful conversation on financial literacy education. Learn more about Melvin’s transition into the CRA profession, how Thomasville National Bank serves its community, and the importance of staying committed to your mission all year.The Community Reinvestment Act (CRA) encourages banks to invest in and deploy financial literacy efforts in their communities. If you would like to learn more about the intersection between banks, the CRA, financial literacy, and how to join their efforts, visit the Community Developments Fact Sheet from the OCC. Financial capability resource from the Office of the Comptroller of the Currency.Melvin Hugans has served as the Thomasville National Bank Community Reinvestment Officer for 2 years. He has a long history of involvement in community non-profits in the communities where TNB branches are located. Prior to assuming the role as the Community Reinvestment Officer, Melvin retired as an elementary school principal. The relationships he established as a principal have helped him grow in his role as a community reinvestment officer. TNB is a regulated by the OCC and has 1.3 Billon dollars in assets.Links:Thomasville National Bank: https://tnbank.com/about-usCommunity Developments Fact Sheet: https://www.occ.gov/publications-and-resources/publications/community-affairs/community-developments-fact-sheets/pub-fact-sheet-financial-capability-jan-2019.pdfFor more information on the CRA Hub, a membership for bankers to connect, inspire, and master the art of CRA: https://cratoday.com/hub/ CRA Today Website: https://cratoday.com/ Linda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2022 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by HiveCast.fm

“11% of students from low-income households graduate college,” says Abby Coyle. As a former educator for Teachers for America, Abby realized the equity gap in the education system. To close the gap, Abby co-founded ClassEquity, an online platform aimed to help students build financial literacy. Class equity enables students to open their own "bank account," through which they practice earning classroom dollars, saving, and spending in a safe environment. Co-founders Abby and Katie started ClassEquity to solve a problem they both experienced during their time as classroom teachers in Title 1 schools: access to financial education. With ClassEquity, they aim to increase economic mobility by giving all students the tools they need to become financially independent, regardless of their zip code. After launching this fall, ClassEquity now supports over 3,000 students across 120 classrooms weekly. Tune into this episode of the CRA Podcast to learn more about the role that technology and financial education play in providing economic and educational equity for students. Links: Links to program: ClassEquity.com; Blog; LinkedIn pageContact info: [email protected] sponsorship opportunities, interested parties can email me at [email protected] For more information on the CRA Hub, a membership for bankers to connect, inspire, and master the art of CRA: https://cratoday.com/hub/ Copyright © 2022 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by HiveCast.fm

April 1st marked the start of National Financial Capability Month, a month during which organizations (especially financial institutions!) across the country focus on supporting programs that expand financial literacy, economic empowerment, and access to capital and credit for all consumers. You might be asking, “As a bank, what can we do to build financial capability in our community?” Luckily, there are many pre-existing resources just waiting for you to use! Here are a few:• FDIC’s Money Smart – Consider this the Swiss army knife of financial capability resources. It provides a range of curriculum options tailored for young people (K-12), young adults (12-20), adults, older adults, and even small businesses. Note that some modules are long (2+ hours); adapt them in partnership with the nonprofit to best suit the needs & interests of your audience and to fall within time constraints.https://www.fdic.gov/resources/consumers/money-smart/index.html• The Federal Reserve Bank of Dallas’s Building Wealth – A 5-module curriculum available in multiple formats. https://www.dallasfed.org/~/media/microsites/cd/wealth/index.html• Consumer Financial Protection Bureau – Pull together educational tools for key financial decisions, search their database of 270 financial literacy activities for youth, or download publications for youth and adults available in PDF or print format.https://www.consumerfinance.gov/• American Bankers Association – ABA has various ready-to-teach presentations and activities in connection with their various community programs, such as Get Smart About Credit, Teach Children to Save, and Safe Banking for Seniors. ​​https://www.aba.com/For a comprehensive list of useful financial literacy resources, issues, and events, visit the OCC’s Financial Literacy Resource Directory.occ.gov/topics/consumers-and-communities/community-affairs/resource-directories/financial-literacy/index-financial-literacy-resource-directory.htmlCRA Today helps bankers master the Community Reinvestment Act, get exam ready, and change lives through the power of community development.Want to learn the CRA basics? Sign up for CRA Essentials Live! A live webinar with Linda Ezuka that shares everything you need to create a solid foundation for your CRA journey. https://hub.cratoday.com/freewebinarReady to take a deeper dive into the CRA? Join your fellow CRA enthusiasts in the CRA Hub as we navigate regulatory change, study core CRA concepts and connect as community development professionals across the nation.https://cratoday.com/hub/Are you understating your lending performance? Learn the 5 Foundational Steps to Building an Outstanding Community Development Loan Portfolio with an on-demand training workshop.https://cratoday.com/blueprint/CRA Today Website: https://cratoday.com/ Linda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2022 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by HiveCast.fm

For the last thirty years, Tawalla Simmons has dedicated her career to serving others through CRA-inspired programs. Today, she is the president of Inspiring You to Greatness, a 501(c)3 nonprofit dedicated to educating low to moderate-income members of the community about credit, mortgage, and money literacy. As a previous mortgage broker, Tawalla saw firsthand the gap in education surrounding topics such as credit, job readiness, and housing stability. To better serve the community, Tawalla put together a platform of CRA-eligible programs that provide the necessary tools to both increase mortgage approval rates and teach community members how to be successful in the workforce. As the president of IYTG, Tawalla hopes to one day be a primary resource utilized by banks across the country. Tune into this week’s episode of the CRA Podcast to learn more about the importance of strengthening your basic life skills, community development, and how you can achieve personal and professional growth through IYTG’s online educational programs. Call to Action: Inspiring You To Greatness CDC would like to be one of the resources utilized by banks when they need to begin the bootstrap serving in the census tracts and communities we currently serve. We provide bank approved CRA eligible online classes with certificates of completion, demographics, zip codes, income information, and data collection tools to ensure CRA examinations are Satisfactory. Links: Tawalla Simmons, President, Inspiring You to Greatness CDCEmail: [email protected]: www.iytgcdc.orgOnline Academy: www.iytgcdc.com www.gocoacht.teachable.com Inspiring You To Greatness CDC Educational Academy supports CRA Community Reinvestment Acts of Service in Communities by offering Social Services, Financial Literacy, Credit Education, College, Career, Mortgage Readiness Certificate of Completion Classes through an online platform helping non-profits, banking partners, businesses, and clients connect for the greater good.Inspiring You To Greatness CDC Educational Academy courses assist clients with taking classes in a busy environment, helps banks by offering CRA eligible online courses, while helping other nonprofits streamline social services through our platform.For more information on the CRA Hub, a membership for bankers to connect, inspire, and master the art of CRA: https://cratoday.com/hub/ Copyright © 2022 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by HiveCast.fm

It’s time to build your 2022 CRA strategy and action plan! Here are your next steps:Sign up to download the CRA plan resource. This list of questions will help prompt you as you start to build out your CRA plan. https://hub.cratoday.com/opt-in-c71cd533-9b19-4d80-89d9-43b2ec44f869 To prepare your approach, start by obtaining a copy of your bank’s strategic plans for 2022, if available. If a document is not available to you, set up meetings with your executive management team members to learn more about the core strategies of the bank and how you might integrate those priorities into your CRA plan. Next, meet with business units to learn about their business goals and discuss how your CRA program might also support them in their business goals. You can also set benchmarks for identifying community development loans within the commercial lending departments and divisions.You might also want to meet with marketing to make a stronger link between your CRA program and their key priorities as well. Typically CRA programs incorporate marketing goals as it relates to CRA service goals and charitable giving initiatives. Compile all the details into one document and set benchmarks and timelines to pave the path forward for an effective CRA program. Don’t forget that it doesn’t have to be perfect, you just have to get it started! CRA Today helps bankers master the Community Reinvestment Act, get exam ready, and change lives through the power of community development.Want to learn the CRA basics? Sign up for CRA Essentials Live! A live webinar with Linda Ezuka that shares everything you need to create a solid foundation for your CRA journey. https://hub.cratoday.com/freewebinarReady to take a deeper dive into the CRA? Join your fellow CRA enthusiasts in the CRA Hub as we navigate regulatory change, study core CRA concepts, and connect as community development professionals across the nation.https://cratoday.com/hub/Are you understating your lending performance? Learn the 5 Foundational Steps to Building an Outstanding Community Development Loan Portfolio with an on-demand training workshop.https://cratoday.com/blueprint/CRA Today Website: https://cratoday.com/ Linda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2022 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by HiveCast.fm

Build your CRA plan.You aren’t required under the Community Reinvestment Act to build a plan, but it’s an industry best-practice and will help take your CRA program to the next level. Keep your plan simple and don’t worry about making it perfect. Your plan can be one page or it can be 20; everything is up to you. As a general rule, you should start your plan with an overview of your CRA program. Where are you in the exam cycle? Who’s your regulator? What are some of the past year’s accomplishments? Next, list out your bank’s strategic priorities, both long and short term. Include your CRA performance goals, and make sure to mention goals for your lending, services, and investment tests (including benchmarks!), as well as goals for fee and investment income, deposits, and various business units. This is where you can set business unit goals, community development activity benchmarks and the like. This document represents your path forward. Some sections you might include are how you’re going to conduct CRA training, any applicable regulatory changes, technical compliance, public relations, and marketing. For a list of questions to ask yourself when building your CRA plan, sign up for the PDF download here: https://hub.cratoday.com/pl/2147559089. This will help you think about your CRA program and build that perfect plan to promote your program and make a difference in your community. Most of all, remember that your CRA journey is your CRA journey. Don’t make it more complicated than it needs to be, and have fun with it. Once you’ve created your CRA plan, you can share it with executive management, internal business units, the compliance department, and even CRA examiners. This will help keep everyone in your bank on the same page and set expectations throughout the company.CRA Today helps bankers master the Community Reinvestment Act, get exam ready, and change lives through the power of community development.Want to learn the CRA basics? Sign up for CRA Essentials Live! A live webinar with Linda Ezuka that shares everything you need to create a solid foundation for your CRA journey. https://hub.cratoday.com/freewebinarReady to take a deeper dive into the CRA? Join your fellow CRA enthusiasts in the CRA Hub as we navigate regulatory change, study core CRA concepts and connect as community development professionals across the nation.https://cratoday.com/hub/Are you understating your lending performance? Learn the 5 Foundational Steps to Building an Outstanding Community Development Loan Portfolio with an on-demand training workshop.https://cratoday.com/blueprint/CRA Today Website: https://cratoday.com/ Linda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2022 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by HiveCast.fm

Data submitted…now what? Now that you are confident in the reliability of the data, revisit your goals for the new performance year. It’s never-ending, I know!First, you’ll want to align your CRA strategy with the bank’s corporate strategy. As a member of the CRA team, you’re responsible for leading programs and building support in the community that helps your bank connect with potential customers. As such, key stakeholders and the executive management team should see you as a key player in carrying out the bank strategy. Before you can build your own CRA plan or strategy, it’s important to consider the bank’s corporate strategy and priorities. Once you understand the bank’s key initiatives, you can align your CRA program’s priorities with overarching corporate directives to impact the entire institution and the community. To learn about your bank’s key initiatives and corporate strategy, meet with the appropriate people and discuss. Ask how your CRA program could support the bank, and make sure to tell them how they might help your CRA program. Next, you’ll want to consider all elements of your CRA program. When planning and outlining your CRA strategy for 2022, you need to keep all elements of your program in mind. Here are some things to consider:• Collaborate with different business units to ensure you’re meeting the credit needs of the community. • Engage key internal bank stakeholders to maximize the bank’s community development services, loans, and investments.• Create a system to ensure technical compliance with all required deadlines and activities associated with public file, public notices, sunshine provision reporting, etc. • Acknowledge where you are in the CRA exam cycle. Your priorities will shift depending on whether you’re in year one of your exam cycle or if your exam is coming next quarter.• Develop a plan to train key internal stakeholders such as commercial loans officers, retail staff members, and CRA team members embedded in different departments.CRA Today helps bankers master the Community Reinvestment Act, get exam ready, and change lives through the power of community development.Want to learn the CRA basics? Sign up for CRA Essentials Live! A live webinar with Linda Ezuka that shares everything you need to create a solid foundation for your CRA journey. https://hub.cratoday.com/freewebinarReady to take a deeper dive into the CRA? Join your fellow CRA enthusiasts in the CRA Hub as we navigate regulatory change, study core CRA concepts and connect as community development professionals across the nation.https://cratoday.com/hub/Are you understating your lending performance? Learn the 5 Foundational Steps to Building an Outstanding Community Development Loan Portfolio with an on-demand training workshop.https://cratoday.com/blueprint/CRA Today Website: https://cratoday.com/ Linda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2022 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by HiveCast.fm

Why does February only have 28 days? It seems so wrong as we are up against our March 1st CRA data reporting deadline! For those of you with CRA data reporting requirements, by now you have filed or might be working the weekend to prepare your small business, HMDA and community development loans data for FRB submission. Since time is of the essence, I recommend you do a "hail mary" last minute data integrity review to mimic a data integrity exam, much like what our examiners will do on-site prior to a full scope CRA examination.https://kajabi-storefronts-production.global.ssl.fastly.net/kajabi-storefronts-production/themes/1621312/settings_images/KjOTyo8DTGOZ0El5W7Po_Screenshot_2020-02-28_07.25.24.pngAs many of you have experienced, and may have already integrated into your compliance management system, periodically sampling your data is a cornerstone of ensuring CRA data integrity. If you haven't mimicked a CRA data integrity exam lately, use the link below to remind your team how to follow the FRB's approach to data sampling. And, if things "go south" post review, data resubmission instructions are included, too! These data resubmission instructions are geared for data-integrity exams, but can be used as a guide to determine if you want to resubmit during your annual filing process before the data is aggregated and available for public consumption.Consumer Compliance Handbook (Page 852-854): https://www.federalreserve.gov/boarddocs/supmanual/cch/cch.pdfBe sure to report your findings and your specific recommendation to executive management.CRA Today helps bankers master the Community Reinvestment Act, get exam ready, and change lives through the power of community development.Want to learn the CRA basics? Sign up for CRA Essentials Live! A live webinar with Linda Ezuka that shares everything you need to create a solid foundation for your CRA journey. https://hub.cratoday.com/freewebinarReady to take a deeper dive into the CRA? Join your fellow CRA enthusiasts in the CRA Hub as we navigate regulatory change, study core CRA concepts and connect as community development professionals across the nation.https://cratoday.com/hub/Are you understating your lending performance? Learn the 5 Foundational Steps to Building an Outstanding Community Development Loan Portfolio with an on-demand training workshop.https://cratoday.com/blueprint/CRA Today Website: https://cratoday.com/ Linda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2022 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by HiveCast.fm

As you know, time is ticking away and soon you will be faced with scrubbing your CRA data to ready your small business, HMDA and community development loans data submission. Over the next few weeks, we will cover the most common mistakes and will provide some guidance to support you on your road to CRA data integrity. Here are four of the mistakes most commonly made by banks regarding their CRA data: 1. Reporting Non-Reportable Loans• Ensure loans reported meet the size and definition tests• Check loans to non-profits, only some are reportable• Follow the rules for refinance/renewal loans• Review loan lists to ensure all reportable loans are reportedFFIEC’s Guide to CRA Data Collection and Reporting: https://www.ffiec.gov/cra/default.htm 2. Incorrect Loan Amount• Check records for appropriate loan amount, specifically focusing on:• Refinances/renewals• Credit line increases/decreases• Typographical errors/transposing numbers/rounding3. Incorrect Loan Location• Ensure the correct address is used; request street address• Create a reliable backup system if address was not identified• Watch for typographical errors, transposing numbers, rounding• Update systems with FFIEC Census file geographic changes, check for the correct year4. Incorrect Gross Annual Revenue (GAR)• Ensure that gross annual revenues or income was reported instead of net revenue• Ensure that aggregated revenues were reported if the underwriting relied/considered additional entity revenues• Double check if the credit file contains revenue information, and if so, report that revenue even if there was no reliance on revenue in underwritingQuotes• “Triple check reporting loans to make sure that they are in fact reportable and that you report the correct loan amount, correct loan location, and the correct gross annual revenue.” (06:45-07:00)CRA Today helps bankers master the Community Reinvestment Act, get exam ready, and change lives through the power of community development.Want to learn the CRA basics? Sign up for CRA Essentials Live! A live webinar with Linda Ezuka that shares everything you need to create a solid foundation for your CRA journey. https://hub.cratoday.com/freewebinarReady to take a deeper dive into the CRA? Join your fellow CRA enthusiasts in the CRA Hub as we navigate regulatory change, study core CRA concepts and connect as community development professionals across the nation.https://cratoday.com/hub/Are you understating your lending performance? Learn the 5 Foundational Steps to Building an Outstanding Community Development Loan Portfolio with an on-demand training workshop.https://cratoday.com/blueprint/CRA Today Website: https://cratoday.com/ Linda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2022 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by HiveCast.fm

Let’s refocus our time on your CRA data integrity and, for some of you, your annual CRA data submission. For small and intermediate small banks, this means making sure your data is collected and maintained for future examiner review. For large banks, this means readying your data for FRB submission! By now, you are well on your way to testing, sampling and double checking your HMDA, small business and community development loans. Speaking of community development loans, have you finished scouring your loan originations to mine for additional community development loans that may have been overlooked? In the perfect world, your loan officers would be involving you in community development deals at the prospecting phase through origination or at least providing you with a credit approval memorandum or a heads up that they just closed a community development loan that you should take a look at! Just in case you are still working through this, here are three approaches you might want to consider as you continue to prepare for the March 1st deadline. #1 Economic Development Hook: When reviewing a credit approval memorandum for a potential economic development qualified community development loan, SBA size standards are commonly used to determine if a borrower qualifies as a small business. Unlike the "gross annual revenue" definition in small business reporting, the NAICS size standards use a different measure defined as "annual receipts." This enables you to generally qualify more businesses as "small" and thus more potential community development loans. Click this link to learn more: https://www.sba.gov/sites/default/files/2019-08/SBA%20Table%20of%20Size%20Standards_Effective%20Aug%2019%2C%202019_Rev.pdf#2 Check 2021 Double Check Loans for Renewals: Remember renewals generally count, so I double check my list for any "low-hanging fruit" as long as the community development purpose remains. Click this link to reference the Q&A: https://www.govinfo.gov/content/pkg/FR-2016-07-25/pdf/2016-16693.pdf§ ll.42(b)(2)—5: Should institutions collect and report data about community development loans that are refinanced or renewed?A5. Yes. Institutions should collect information about community development loans that they refinance or renew as loan originations. #3 Defending Community Development Loan Impact: Although not required to file, it is imperative that a folder is created for each community development loan that will be reported in the aggregate. This is a tedious task, but essential when regulators are on-site testing for impact. It's easy to push this task into the future, but trust me, it's a monumental task if left to the last minute with other competing priorities of onsite examination preparation. Don't let this slip, and if you need to take an extra few weeks after the filing deadline, then do so... just don't wait until the end of your exam cycle!Quotes• “I estimate that over 90% of banks underreport their community development loans.” (02:21-02:28)CRA Today helps bankers master the Community Reinvestment Act, get exam ready, and change lives through the power of community development.Want to learn the CRA basics? Sign up for CRA Essentials Live! A live webinar with Linda Ezuka that shares everything you need to create a solid foundation for your CRA journey. https://hub.cratoday.com/freewebinarReady to take a deeper dive into the CRA? Join your fellow CRA enthusiasts in the CRA Hub as we navigate regulatory change, study core CRA concepts and connect as community development professionals across the nation.https://cratoday.com/hub/Are you understating your lending performance? Learn the 5 Foundational Steps to Building an Outstanding Community Development Loan Portfolio with an on-demand training workshop.https://cratoday.com/blueprint/CRA Today Website: https://cratoday.com/ Linda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2022 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by HiveCast.fm

Let's say you don't get to add to your CRA staff. What can you do to accomplish all of the work that you have before you? Today, I have three ways to support and supplement your CRA program. Leverage Bank Trainee ProgramsChances are there is a trainee program at your bank, whether it’s for new officers of the bank, credit training, retail staff, etc. Oftentimes, these trainee programs have special projects you can vie for in your CRA program. You can provide either a special, one-time project OR a credit activity that they can embark upon during each training session to learn more about the bank.So, it's a win-win, right? Your bank trainees are very eager. Make sure you train them on the core CRA and community development loan identification concepts, and they can help identify community development loans. They can also help with:• Documentation, if you haven’t had time to cross your T’s and dot your I’s• Data integrity reviews• Desktop procedures• Self-assessments or performance contexts for performance gaps you might haveSo, really think about this in terms of a case study, do some training, run some challenges, have a little fun, and make your training program a way to supplement your resources to support your CRA program.Hire InternsMany of our banks have intern programs, and you can have the interns do the same activities. Now, if you have some restrictions on the reporting or the sensitivity of client information, you can just have them do more external research and not have them look at credit documents. But, oftentimes we have our interns sign non-compete and confidentiality disclosures as well.Outsource to Consulting FirmsThe third way to support your CRA program is through outsourcing. We often use outsource consulting firms to help us either mine for community development loans or check the validity of our data on a quarterly basis. While you may be looking at loans at a hundred percent, these firms can provide independent, sampled reviews. Sometimes, you can even have consultants create self-assessments on your behalf.So again, leverage your trainee program within the bank, consider interns within your intern program and consider outsourcing to the extent that you need even more help that's specialized. CRA Today helps bankers master the Community Reinvestment Act, get exam ready, and change lives through the power of community development.Want to learn the CRA basics? Sign up for CRA Essentials Live! A live webinar with Linda Ezuka that shares everything you need to create a solid foundation for your CRA journey. https://hub.cratoday.com/freewebinarReady to take a deeper dive into the CRA? Join your fellow CRA enthusiasts in the CRA Hub as we navigate regulatory change, study core CRA concepts and connect as community development professionals across the nation.https://cratoday.com/hub/Are you understating your lending performance? Learn the 5 Foundational Steps to Building an Outstanding Community Development Loan Portfolio with an on-demand training workshop.https://cratoday.com/blueprint/CRA Today Website: https://cratoday.com/ Linda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2022 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by HiveCast.fm

So, how do you actually build the culture of compliance within your bank?When you're looking at identifying your internal stakeholders, you'll want to look at the small business department, loan ops in particular. You could look at your home mortgage department, since they also have a loan ops group that touches the data on a daily basis as they originate loans. You also have your commercial lenders, your marketing and retail groups, and your investments and treasury divisions. These are all major stakeholders in ensuring that your bank meets the credit needs of your community and that you're able to run a safe and sound CRA program. It's really important that you look at all of these lines of businesses and then move the mark and build a culture of compliance.You would start by looking at executive management and making the case for more support from the line. You absolutely have to receive management buy-in to move forward. You can outline the expectations that you're hoping to support through working with a small business.You must also address the capacity issues. Everybody feels like they have an overwhelming plate of tasks, duties and job responsibilities. So, you must address this with management at the very start, so that you can be mindful of everyone’s time and efficiently rebalance job activities. You must also commit to training as much as is necessary to support a smooth transition and ensure data integrity over time.You'll definitely have to play a leadership role in the training of your new stakeholders and lines of business, the key people that are supporting your CRA program. You'll also want to create your policies and procedures that then relate to the CRA. So, if it's in their job description and they're playing a role in the CRA program, you'll want to make sure that it's evidenced in the CRA policies, procedures, and desktop procedures for the work that they do. You can also create incentives, so that these stakeholders are inspired to do more. You always want to involve the lines of businesses as you continue to grow your CRA program, so that it’s truly the bank's responsibility in your building up the CRA program as a team.Quotes• “You’ll provide a lot of leadership, but it’ll pay off by having a second set of eyes and more resources to support your CRA program.” (05:35-05:43)CRA Today helps bankers master the Community Reinvestment Act, get exam ready, and change lives through the power of community development.Want to learn the CRA basics? Sign up for CRA Essentials Live! A live webinar with Linda Ezuka that shares everything you need to create a solid foundation for your CRA journey. https://hub.cratoday.com/freewebinarReady to take a deeper dive into the CRA? Join your fellow CRA enthusiasts in the CRA Hub as we navigate regulatory change, study core CRA concepts and connect as community development professionals across the nation.https://cratoday.com/hub/Are you understating your lending performance? Learn the 5 Foundational Steps to Building an Outstanding Community Development Loan Portfolio with an on-demand training workshop.https://cratoday.com/blueprint/CRA Today Website: https://cratoday.com/ Linda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2022 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by HiveCast.fm

So, how do you best go about dividing and conquering the work of a CRA officer? Many people inherit the CRA program and still have compliance responsibilities or dabble in BSA or share the titles of CRA officer and fair lending officer. Usually if you're just a team of one or even a partial position, you really have to do it all. From CRA data collection to data integrity testing to lending performance analytics to collecting service, investment and community development activities….the list goes on and on.Many people try to, as they grow over time, advocate to add to staff. So when you do that, this is how you might determine to divide and conquer. So as a CRA officer, you would keep some of the core responsibilities of your job, like CRA data strategy, goal setting, executive management engagement and, of course, working with compliance and risk management at a higher level. For CRA data integrity, you would continue monitoring your performance analytics blending service and investments, engaging with the lines of businesses, looking for and managing the exam prep activities and navigating regulatory change.And when you are able to “add to staff” and hire a CRA program administrator, or CRA deputy officer, the duties rebalance. You could have this person take on the data integrity aspects of extracting lending activity from your core system input, scrubbing it and importing into a CRA proprietary database. They might also do the first review and then you do a test review of the CRA data integrity.The CRA administrator would collect all the service activities and investment activities, and they can mine for community development loans. They would be creating the lists, the spreadsheets, or inputting into cadence software. They'll also be responsible for the technical compliance aspects of the CRA and managing your policies and procedures. So, there are definitely ways that you can delegate work between a CRA officer and an administrator to support your CRA program.I hope this helps at least differentiate how you might add to staff so that you can start to create your business case, to add an FTE to your team, to your mighty team of one.CRA Today helps bankers master the Community Reinvestment Act, get exam ready, and change lives through the power of community development.Want to learn the CRA basics? Sign up for CRA Essentials Live! A live webinar with Linda Ezuka that shares everything you need to create a solid foundation for your CRA journey. https://hub.cratoday.com/freewebinarReady to take a deeper dive into the CRA? Join your fellow CRA enthusiasts in the CRA Hub as we navigate regulatory change, study core CRA concepts and connect as community development professionals across the nation.https://cratoday.com/hub/Are you understating your lending performance? Learn the 5 Foundational Steps to Building an Outstanding Community Development Loan Portfolio with an on-demand training workshop.https://cratoday.com/blueprint/CRA Today Website: https://cratoday.com/ Linda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2021 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by HiveCast.fm

Let's say you can't “add to staff” given resource constraints and you have to remain a mighty team of one doing “all of the things.” Sometimes you might feel like throwing in the towel…but not so fast! I have a few ideas for you. One common option is to engage with your line of business (LOB) management and team members to expand your internal CRA resources. You'll have to engage and inspire your LOB team members to get involved. This takes a while and requires you to build a culture of compliance throughout your institution. As you know, CRA is not a one-man job; instead, it’s done by many in the best case scenario. So, here's what you would do. First, you would ask your small business LOB to play more of a leadership role in ensuring the accuracy of their small business data, as that is a best practice in similarly situated financial institutions. You could also talk with the home mortgage group and have them extract their data, scrub it, and then import it into your CRA proprietary database. You can also inspire your commercial lenders to identify community development loans at origination, so that you spend less time mining for them at the back end.You can meet with marketing and inspire them to identify community development, volunteer activities upfront, so that you’re always ahead of the curve. You can set a goal for your investments and treasury divisions to identify some community development investments as part of their portfolio, and then they can report that activity to you. We know that there's always such pressure on the finite resources within our banks. If you have to be an officer of one, a CRA program of one, I'd inspire you to take baby steps, to start inspiring executive management, to get your lines of businesses together in order to support your CRA program. For every dollar your bank makes, there is a commensurate cost of compliance. So, you have to build your case and slowly you can move the mark and ask for more help. Now you have to be mindful of their resource constraints as well, right? That's why it takes a while to really get the support that you need from your lines of businesses. So build a case, get executive management involved and try to lead your program with more support from the lines of businesses. CRA Today helps bankers master the Community Reinvestment Act, get exam ready, and change lives through the power of community development.Want to learn the CRA basics? Sign up for CRA Essentials Live! A live webinar with Linda Ezuka that shares everything you need to create a solid foundation for your CRA journey. https://hub.cratoday.com/freewebinarReady to take a deeper dive into the CRA? Join your fellow CRA enthusiasts in the CRA Hub as we navigate regulatory change, study core CRA concepts and connect as community development professionals across the nation.https://cratoday.com/hub/Are you understating your lending performance? Learn the 5 Foundational Steps to Building an Outstanding Community Development Loan Portfolio with an on-demand training workshop.https://cratoday.com/blueprint/CRA Today Website: https://cratoday.com/ Linda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/Copyright © 2021 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by HiveCast.fm

We spent the last few CRA tips talking about community development finance. Today’s episode focuses on filling the gap when a seemingly undoable deal is before you. Our commercial lenders were trained to manage risk for the bank and to manage that risk based on various regulations, including the safety and soundness provisions. When a community development project is not quite doable, it may be up to you to recommend a path forward. Sometimes our commercial lenders haven’t had the range of experiences you have and may not know what loan enhancements might be available to them. This is where your role as a CRA professional comes in. It’s your responsibility to be involved in the community, to know who the key stakeholders are, and to understand who your go-to partners are when it comes to best serving the credit and social needs of disadvantaged communities. Here are a couple of ways you might consider approaching the financing gap by bringing flexible capital and equity sources to the table. • Participation Loans• Bank Financing-Debt-Conventional• CDFI-Debt (flexible debt)• Bonds (cheaper debt)• And more!Although these sources of capital can be powerful, many sources are obtained through a competitive application process and/or through various initiatives that take time to curate. But great things come to those who are patient, yes? These projects have the power to make significant impacts in the communities in which we serve, so they are worth the wait! Quotes• “If you partner with your commercial lenders more often or train them often, they might come to you then when you have a deal that might not be quite be bankable, but you can partner together, in community, to make it work.” (02:28-02:47)• “There are so many different ways that you can bring partnerships to the table to make the undoable deal doable.” (04:40-04:49)Want to learn more about the CRA? Sign up for CRA Today’s free course: https://hub.cratoday.com/freecourseLinksConsumer Compliance Handbook (Page 852-854): https://www.federalreserve.gov/boarddocs/supmanual/cch/cch.pdf CRA Today Website: https://cratoday.com/ For more information on the CRA Hub, a membership for bankers to connect, inspire, and master the art of CRA: https://cratoday.com/hub/ Copyright © 2021 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by HiveCast.fm

The best and most impactful community development finance projects are not done by any one bank, CDFI or community partner. The most monumental community-based projects are forged over time with strong leadership (and trust!) and the fortitude to manage the never-ending variables that are often required when driving impact into the most disadvantaged communities. This is where your internal and external partners come into play. Internal partners include executive management, commercial lenders, loan servicing, your investment/treasury division, compliance and legal, and marketing and PR. External partners include private sector businesses, nonprofit organizations, philanthropic entities, governmental agencies, commercial and private developers, and practitioners/consultants.These community development projects tend to take a couple of years and have many people and partners cycle through the deal. Oftentimes, CRA Officers play a convening role by offering to meet in a bank conference room or to coordinate virtual meetings. Your work in this regard will likely garner community development service hours for your bank as well.No matter the role you play, it is important to keep all stakeholders apprised of the project along the way. This is especially true for internal partners as equity sources and credit enhancements fall into place to make the seemingly un-doable deals, well, doable! I hope you now have a sense of all of the key players and can call upon them as you embark on your community development initiatives. Quotes• “It’s very important that you keep all of your internal partners aware of the community development work you’re doing, so when financing comes to play everybody is aware of the role you might play in community.” (02:38-02:53)Want to learn more about the CRA? Consider joining the CRA Hub, a membership for bankers to connect, inspire, and master the art of CRA: https://cratoday.com/hub/ LinksCRA Today Website: https://cratoday.com/ Copyright © 2021 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by HiveCast.fm

Once you have a good understanding of the technical aspects of the CRA and have stabilized your CRA program, now it's time to expand your reach into the community. Oftentimes, that will involve working alongside various stakeholders, who care deeply about serving lower income and disadvantaged communities. When working in community, you will likely be invited to participate in community redevelopment initiatives and, of course, financing will be part of that conversation! If you ask 10 bankers how they would define community development financing, you will likely get 10 different responses. As a general framework, community development finance involves economic growth in which people come together and make decisions to organize and pool assets and resources for the purposes of addressing unmet credit needs and opportunities. Let’s take a deeper look at pooling assets and resources for addressing unmet credit needs. In a simplified capital stack, you’ll see that conventional debt (otherwise known as conventional financing or bank debt) is at the foundation. If a bank can originate a deal, it will; however, you often will need to bring extra resources to the table to make the deal work. That is where you come in. Your job is to know about these various sources and work with the bank to consider partnering with a CDFI or bringing more equity sources to the table. In complex deals, sometimes there are more than 10 equity sources layered in with a CDFI enhancement (or first loss position) and conventional debt. I hope this gives you a glimpse into the world of community development finance. Remember: community development finance is deployed in partnership with community stakeholders who bring varied resources to the table to address challenges and barriers that can not be overcome by one bank or stakeholder alone.Quotes• “It’s very important that you understand that the most productive and powerful community development initiatives require many people coming to the table and various levels within the capital stack to make the deal work.” (04:48-05:06)Want to learn more about the CRA? Sign up for CRA Today’s free course: https://hub.cratoday.com/freecourseLinksConsumer Compliance Handbook (Page 852-854): https://www.federalreserve.gov/boarddocs/supmanual/cch/cch.pdf CRA Today Website: https://cratoday.com/ For more information on the CRA Hub, a membership for bankers to connect, inspire, and master the art of CRA: https://cratoday.com/hub/ Copyright © 2021 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by HiveCast.fm

Cities for Financial Empowerment (CFE) Fund: https://cfefund.org/The CFE Fund is a 501(c)3 nonprofit organization; our programmatic, research and policy efforts focus on designing, embedding and replicating financial empowerment initiatives within the fabric of local government.The CFE Fund’s national Bank On platform supports local coalition and financial institution efforts to connect consumers to safe, affordable bank accounts: https://joinbankon.org/Bankers, learn more about the Bank On certification here: www.joinbankon.org/certify Research from the Federal Deposit Insurance Corporation shows that there are many reasons consumers lack a basic transaction account: not enough money for the minimum balance; distrust of financial institutions; high or unpredictable fees; or identification, credit or banking history problems. Many Americans are driven to use expensive alternative financial services, including check cashers, payday lenders and pawn shops that charge high fees for financial services that fail to help people get ahead. Without a checking account, families wind up paying too much for basic financial transactions and are hard pressed to build savings and assets.Quick Facts:• Close to 5% of U.S. households (approximately 12 million adults) are “unbanked,” without a checking or savings account.• Almost 11% of U.S. households (approximately 24 million adults) are underbanked, meaning they still use some fringe financial services.• Nearly 34% of unbanked and 45% of underbanked households earn less than $30,000 per year.• Nationally, 48% of Black households and 42% of Hispanic households are unbanked or underbanked, compared to less than 14% of white households.Why do basic transaction accounts matter?A basic transaction account is an important first step in establishing a mainstream banking relationship, depositing earnings securely, accessing credit and saving for the future. Unbanked and underbanked individuals lose the cost savings and stabilizing benefits such an account provides, such as:• Cost savings: The average unbanked person spends 5% of net income on unnecessary fees for alternative financial services. This can amount to $40,000 over a lifetime—a significant amount for those who can least afford it.• Asset building: Without a bank account, a family lacks the ability to save reliably or automatically, or establish a banking relationship that can lead to accessing affordable credit for opportunities like a car, small business, or home mortgage.• Public safety: Without a safe place to deposit their money, unbanked people are more likely to be victims of crime because they often carry large sums of cash with them or keep cash in their homes. Elderly, disabled or undocumented immigrants can be particularly vulnerable.• Financial stability: Research shows that being unbanked makes it harder to achieve financial goals like reducing debt and improving credit scores.David Rothstein, Senior Principal, CFE Fund: https://www.linkedin.com/in/david-rothstein-72a5516/David is a Senior Principal at the CFE Fund (https://www.linkedin.com/company/cities-for-financial-empowerment-fund/), where he leads the national Bank On initiative. Previously, he served as Director of Resource Development and Public Affairs for Neighborhood Housing Services of Greater Cleveland providing fund development and policy leadership. He also served as a research fellow for the New America Foundation in asset building and the Program Director for the Ohio CASH Coalition with Policy Matters Ohio. He has a BA in Political Science from John Carroll University and an MPA from Kent State University.Matt Hanke, Retail Strategies Manager, VP from Northwest Bank: https://www.linkedin.com/in/matthanke/Matt’s years of banking experience from being a Customer Service Representative, Personal Banker, Mortgage Banker and now a member of Northwest Bank’s executive team, has given him an unique perspective on fostering customer experiences that build relationships that exceed expectations.Northwest Bank (https://www.nw.bank/) is a $2.3 billion community bank that offers a full line of business, agricultural, mortgage, consumer deposit and lending products as well as wealth management and insurance services. Northwest Bank has 18 offices located throughout Iowa and Nebraska.Compass Digital Account (https://www.nw.bank/personal/checking/compass-digital-account) is Northwest Bank’s Bank On Certified Product.~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~For more information on the CRA Hub, a membership for bankers to connect, inspire, and master the art of CRA: https://cratoday.com/hub/ Copyright © 2021 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by HiveCast.fm

Take a deep breath. There is life after a failed CRA data integrity exam. I’ve been through a few rough ones over the past 27 years, and every bank ends up with a stronger program as a result. While I can’t promise a smooth path forward, I can offer a few quick tips to help you get to the root cause. First of all, you will want to identify the type of error that occurred: human or systemic. This will likely have been identified by the examiners, but if not, you will need to diagnose this right away, so you can start to understand which control points to focus on first. Then you will need to determine if the errors are isolated to a certain loan product or a certain line of business like small business or HMDA. Once you have determined the root cause, you will need to act fast!It’s important to review the end-to-end process of accepting a loan application all the way through to origination. If you have a data integrity issue, be sure to bring together a CRA data working group to drive short- and long-term solutions. Lack of data integrity delays CRA examinations, causing costly rescrubbing efforts often with the support of outsourced and expensive consulting firms. Revisit your control points to determine your root cause and your path to remediation.Want to learn more about the CRA? Sign up for CRA Today’s free course: https://hub.cratoday.com/freecourseLinksConsumer Compliance Handbook (Page 852-854): https://www.federalreserve.gov/boarddocs/supmanual/cch/cch.pdf CRA Today Website: https://cratoday.com/ For more information on the CRA Hub, a membership for bankers to connect, inspire, and master the art of CRA: https://cratoday.com/hub/ Copyright © 2021 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by HiveCast.fm

Gather all of your data-related resources into one place.Review the data-related policies and procedures. Review the content. What is missing? Is it accurate? When was it reviewed last? Does it have a revision date? Create a regular review schedule and make sure to involve major stakeholders (loan officers, underwriters, loan booking, documentation, your chief compliance officer, etc.).Identify your small business control points within the bank. Do you have a data flow chart for all commercial loan products? Are specific business unit procedures documented? Have you reviewed them? Are they accurate? How often should they be reviewed? Create a regular review schedule with the appropriate executive-level review and acknowledgement.Simulate a data integrity examination. Report your findings and your specific recommendations to executive management.Train. Customize training for key stakeholders: branch employees, loan officers, underwriting, loan booking and documentation, compliance colleagues, management, executive management and the board.Train again. This best practice will never end... but the impact, critical! Quotes• “The best desktop procedures are used to help create bench strength, to help train various team members and make sure that you ensure data integrity and that it’s institutionalized for your CRA program and your bank.” (02:21-02:38)• “Training of course is so key to all of this data integrity best practice.” (03:45-03:50)• “The best practices that are associated with CRA data integrity: it’s never-ending, right? We have to keep working it, make sure it’s part of your core governance, revisit this work and make sure you’re able to ensure compliance and integrity.” (04:23-04:38)Want to learn more about the CRA? Sign up for CRA Today’s free course: https://hub.cratoday.com/freecourseLinksConsumer Compliance Handbook (Page 852-854): https://www.federalreserve.gov/boarddocs/supmanual/cch/cch.pdf CRA Today Website: https://cratoday.com/ For more information on the CRA Hub, a membership for bankers to connect, inspire, and master the art of CRA: https://cratoday.com/hub/ Copyright © 2021 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by HiveCast.fm

I’ll bet you didn’t guess this one! The secret to a smooth CRA data integrity exam is...your loan operations team. Yep, loan ops! Wait, what? These team members are masterful at detail with their checklists, loan code sheets, document indexing system and digitalization platforms. They are your first call when you get your sampled lists from your examiners, and they carry the heavy burden of pulling files and reading them for examiner review. They are often juggling their daily loan origination workflow and supporting various departments with one audit after another. I spend extra time taking care of these valuable team members. Make sure that you develop relationships with them in between exam cycles and recognize their efforts to ensure data integrity through the normal course of business. Most importantly, be sure to keep them in the loop as valued partners to your CRA program. The moment you receive your exam notice, inform them of key dates and what will be expected of them so they can prepare. They will need to shift priorities to pull loan files for you under the CRA program but also for your bank’s compliance exam, so they are working under great pressure in the midst of their regular process flow and transactional deadlines. Once the data integrity exam is complete, loop back to them to share the outcome of the review and commend them for a job well done. You may even want to surprise them with some coffee and donuts! Quotes• “[Your loan operations officers] are always critical to your work, and god forbid you actually have to expand your sample, they’re involved, too, because it’s their work that’s being examined as well.” (02:35-02:48)• “[Your loan operations officers] are a key piece of the team to ensure clean data and happy examiners. So, make sure that you keep them in the loop and that they’re part of your CRA team, your inner circle if you will.” (02:58-03:14)Want to learn more about the CRA? Sign up for CRA Today’s free course: https://hub.cratoday.com/freecourseLinksCRA Today Website: https://cratoday.com/ For more information on the CRA Hub, a membership for bankers to connect, inspire, and master the art of CRA: https://cratoday.com/hub/ Copyright © 2021 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by HiveCast.fm

As you know, before each exam, your regulators will conduct a review of your lending data to ensure that it is accurate enough to determine your lending performance. The regulators have a very specific approach that is delineated within the Consumer Compliance Handbook. If you haven’t downloaded this yet, I would encourage you to do so today. Here is the link and notation on where to find the specific framework within the several hundred page document. Consumer Compliance Handbook (Page 852-854): https://www.federalreserve.gov/boarddocs/supmanual/cch/cch.pdf Use this as a guide for any size bank; regardless of regulator, these sampling procedures are universal. I suggest that you mimic this sampled approach on a periodic basis for your small business loans, small farm and HMDA loans. You can even use this same statistically sound approach to sample your community development loans, services and investments. The CRA sampling model employs a 5.0 percent precision level with a minimum 90.0 percent confidence. It’s prudent to have an independent review embedded into your CRA program to ensure data integrity! Happy sampling!Quotes• “[An independent review] means that whoever’s collecting this information, we should have someone else sampling and double checking.” (02:55-03:04)Want to learn more about the CRA? Sign up for CRA Today’s free course: https://hub.cratoday.com/freecourseLinksConsumer Compliance Handbook (Page 852-854): https://www.federalreserve.gov/boarddocs/supmanual/cch/cch.pdf CRA Today Website: https://cratoday.com/ For more information on the CRA Hub, a membership for bankers to connect, inspire, and master the art of CRA: https://cratoday.com/hub/ Copyright © 2021 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by HiveCast.fm