Josh Silver
09-12-2007, 09:17 PM
*
September 12, 2007
*
TO:***************** NCRC Members and Colleagues
*
FROM:*********** Josh Silver, Vice President of Research and Policy
*
*
RE:****************** NCRC CRA Manual
*
Dear Colleagues:
*
We are pleased to announce that we have updated the CRA Manual, to reflect the recent changes to the regulations implementing the Community Reinvestment Act.* This manual explains to community groups and other stakeholders how CRA works and how to use CRA to increase access to capital and credit for working class and minority neighborhoods.
*
This link will take you to the CRA Manual and also to fact sheets about the home and small business data -- http://www.ncrc.org/policy/cra.php. **
*
We hope you find this useful.
*
*
From the Introduction of the CRA Manual
*
The Community Reinvestment Act (CRA) is a remarkable law.* Not only does it prohibit discrimination against working class and minority neighborhoods, it also imposes an affirmative obligation on banks to serve these communities.* It is not good enough for a bank to establish branches and passively wait for customers to walk into branches.* Instead, banks must proactively assess community needs, conduct marketing and outreach campaigns in all communities, and consult with community stakeholders in developing financing options for affordable housing and economic development activities.*
*
Another ingenious aspect of CRA is that it requires community participation.* Banks are custodians of community wealth; thus they have an obligation to determine the credit needs of bank customers and depositors.** There is no better way for banks to serve credit needs than to listen to members of the community articulate what those needs are.* Thus, CRA establishes formal mechanisms for banks and regulators to seriously consider community needs and input.* Members of the community can comment at any time on a bank’s CRA performance in a formal or informal manner.* When federal agencies conduct CRA exams of banks’ lending, investing, and service activities in low- and moderate-income communities, federal agencies are required to consider the comments of members of the public concerning bank performance.* Likewise, federal agencies are required to consider public comments when deciding whether to approve a bank’s application to merge or open and relocate branches.
*
CRA has spawned an impressive amount of collaboration among banks and community organizations.* Every bank in this country has a CRA officer, whose job it is to seek out profitable business opportunities and deals in low- and moderate-income communities.* It is important for community organizations to contact CRA officers of several banks in their community and discuss needs and opportunities with the CRA officers.** As a result of advocacy and collaboration, CRA has leveraged trillions of dollars of bank financing and services for low- and moderate-income communities over the last three decades.* Our nation’s low- and moderate-income communities would stand no chance of economic revitalization and empowerment if CRA was not the law of the land.*
*
This manual is a how-to book for community organizations and any other stakeholder wishing to become engaged in the CRA process and economic building activities for low- and moderate-income communities.* The first chapter provides a quick summary of the CRA regulation and how members of the general public can become involved in the CRA process.* The second chapter outlines the elements of CRA exams for various types of banks in a powerpoint format.* The third chapter then provides a detailed description of CRA exams.* Commentary is offered on the strengths and weaknesses of CRA exams and issues community organizations should consider when commenting on CRA exams.* The fourth chapter provides an overview of the bank application and merger process and how community groups can become involved.* The manual then proceeds to one fictitious case study and one actual case study of commenting on CRA exams.* Finally, CRA sunshine requirements are described.* CRA sunshine is a frivolous requirement; nevertheless, compliance requirements are straightforward for community organizations and banks.**
*
The intention of this Manual is to bolster community group and public participation in the CRA process.* If banks and regulators are the only stakeholders involved in a secretive or mysterious CRA process, chances increase that CRA exams and merger applications become rubber stamps without imposing meaningful obligations to serve the community.* On the other hand, if the general public is actively engaged in providing thoughtful and penetrating insights and comments on bank performance, CRA becomes a rigorous process, holding banks accountable to serving community needs.* Consequently, bank lending, investing, and services increase for low- and moderate-income communities.
*
During this 30th Anniversary of CRA, we hope that the CRA Manual helps nurture a public that continues to be actively engaged in the CRA process.* We hope that community organizations and members of the public across the country use this Manual and offer us input on how to make it more understandable and effective.
*
*
September, 2007
*
Josh Silver
Vice President of Research and Policy
National Community Reinvestment Coalition
(202) 628-8866 or http://www.ncrc.org
*
*
This post transferred from the cdb-l mailing list
September 12, 2007
*
TO:***************** NCRC Members and Colleagues
*
FROM:*********** Josh Silver, Vice President of Research and Policy
*
*
RE:****************** NCRC CRA Manual
*
Dear Colleagues:
*
We are pleased to announce that we have updated the CRA Manual, to reflect the recent changes to the regulations implementing the Community Reinvestment Act.* This manual explains to community groups and other stakeholders how CRA works and how to use CRA to increase access to capital and credit for working class and minority neighborhoods.
*
This link will take you to the CRA Manual and also to fact sheets about the home and small business data -- http://www.ncrc.org/policy/cra.php. **
*
We hope you find this useful.
*
*
From the Introduction of the CRA Manual
*
The Community Reinvestment Act (CRA) is a remarkable law.* Not only does it prohibit discrimination against working class and minority neighborhoods, it also imposes an affirmative obligation on banks to serve these communities.* It is not good enough for a bank to establish branches and passively wait for customers to walk into branches.* Instead, banks must proactively assess community needs, conduct marketing and outreach campaigns in all communities, and consult with community stakeholders in developing financing options for affordable housing and economic development activities.*
*
Another ingenious aspect of CRA is that it requires community participation.* Banks are custodians of community wealth; thus they have an obligation to determine the credit needs of bank customers and depositors.** There is no better way for banks to serve credit needs than to listen to members of the community articulate what those needs are.* Thus, CRA establishes formal mechanisms for banks and regulators to seriously consider community needs and input.* Members of the community can comment at any time on a bank’s CRA performance in a formal or informal manner.* When federal agencies conduct CRA exams of banks’ lending, investing, and service activities in low- and moderate-income communities, federal agencies are required to consider the comments of members of the public concerning bank performance.* Likewise, federal agencies are required to consider public comments when deciding whether to approve a bank’s application to merge or open and relocate branches.
*
CRA has spawned an impressive amount of collaboration among banks and community organizations.* Every bank in this country has a CRA officer, whose job it is to seek out profitable business opportunities and deals in low- and moderate-income communities.* It is important for community organizations to contact CRA officers of several banks in their community and discuss needs and opportunities with the CRA officers.** As a result of advocacy and collaboration, CRA has leveraged trillions of dollars of bank financing and services for low- and moderate-income communities over the last three decades.* Our nation’s low- and moderate-income communities would stand no chance of economic revitalization and empowerment if CRA was not the law of the land.*
*
This manual is a how-to book for community organizations and any other stakeholder wishing to become engaged in the CRA process and economic building activities for low- and moderate-income communities.* The first chapter provides a quick summary of the CRA regulation and how members of the general public can become involved in the CRA process.* The second chapter outlines the elements of CRA exams for various types of banks in a powerpoint format.* The third chapter then provides a detailed description of CRA exams.* Commentary is offered on the strengths and weaknesses of CRA exams and issues community organizations should consider when commenting on CRA exams.* The fourth chapter provides an overview of the bank application and merger process and how community groups can become involved.* The manual then proceeds to one fictitious case study and one actual case study of commenting on CRA exams.* Finally, CRA sunshine requirements are described.* CRA sunshine is a frivolous requirement; nevertheless, compliance requirements are straightforward for community organizations and banks.**
*
The intention of this Manual is to bolster community group and public participation in the CRA process.* If banks and regulators are the only stakeholders involved in a secretive or mysterious CRA process, chances increase that CRA exams and merger applications become rubber stamps without imposing meaningful obligations to serve the community.* On the other hand, if the general public is actively engaged in providing thoughtful and penetrating insights and comments on bank performance, CRA becomes a rigorous process, holding banks accountable to serving community needs.* Consequently, bank lending, investing, and services increase for low- and moderate-income communities.
*
During this 30th Anniversary of CRA, we hope that the CRA Manual helps nurture a public that continues to be actively engaged in the CRA process.* We hope that community organizations and members of the public across the country use this Manual and offer us input on how to make it more understandable and effective.
*
*
September, 2007
*
Josh Silver
Vice President of Research and Policy
National Community Reinvestment Coalition
(202) 628-8866 or http://www.ncrc.org
*
*
This post transferred from the cdb-l mailing list