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/hub 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.

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-yAu5h CRA Today Website: https://cratoday.com/ CRA Hub: https://cratoday.com/hub 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 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/hub CRA 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/webinars CRA Today Website: https://cratoday.com/ CRA Hub: https://cratoday.com/hub 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 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/hub 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.

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 § 12211 https://www.naceda.org/index.php?option=com_dailyplanetblog&view=entry&category=bright-ideas&id=25%3Awhat-is-a-community-development-corporation-&Itemid=171 https://case.edu/ech/articles/c/community-development-corporations https://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/hub 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.

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 Marshall1-773-595-0974 sarahhope@profoundhopeindustries.com http://subdomain.profoundhopeindustries.com/digital-equity Article: Reckoning with Digital Inequity in Place-Based Community Revitalization: https://www.jpna.org/index.php/jpna/article/view/873 1% 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/hub 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.

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.pdf CRA Today Website: https://cratoday.com/ CRA Hub: https://cratoday.com/hub 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.

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/hub 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.

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.pdf CRA Today Website: https://cratoday.com/ CRA Hub: https://cratoday.com/hub 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.