3. Banking and The Community
WELCOME
John Taylor- President & CEO - NCRC
November 9, 2011 Hilo, Hawaii
4. Sure, the lack of
resources for adequate
staffing, books,
facilities, special needs,
Well yes, but why are sure that contributes
they poor?
And how come so many
live in the same
proximity?
If only we got more No question housing is
federal money or if only most people’s number
the state did more? cost and if you are
If they would just fund paying too much of your
my organization more Yeh, that too, but why income for that, well it
we could solve this the lack of jobs, becomes hard to break
problem. Really? why the lack of out of poverty.
Certainly gov’t funds affordable housing,
of good schools?
Why is everybody here
poor or near poor?
5. What Makes a Neighborhood Poor?
Sure, the lack of
resources for adequate
staffing, books,
facilities, special needs,
Well yes, but why are sure that contributes
they poor?
And how come so many
live in the same
proximity?
If only we got more No question housing is
federal money or if only most people’s number
the state did more? cost and if you are
If they would just fund paying too much of your
my organization more Yeh, that too, but why income for that, well it
we could solve this the lack of jobs, becomes hard to break
problem. Really? why the lack of out of poverty.
Certainly gov’t funds affordable housing,
of good schools?
Why is everybody here
poor or near poor?
6. What Makes a Neighborhood Poor?
Sure, the lack of
resources for adequate
staffing, books,
facilities, special needs,
Well yes, but why are sure that contributes
they poor?
And how come so many
live in the same
proximity?
If only we got more No question housing is
federal money or if only most people’s number
the state did more? cost and if you are
If they would just fund paying too much of your
my organization more Yeh, that too, but why income for that, well it
we could solve this the lack of jobs, becomes hard to break
problem. Really? why the lack of out of poverty.
Certainly gov’t funds affordable housing,
of good schools?
Why is everybody here
poor or near poor?
7. What Makes a Neighborhood Poor?
Sure, the lack of
Poor people? resources for adequate
staffing, books,
facilities, special needs,
Well yes, but why are sure that contributes
they poor?
And how come so many
live in the same
proximity?
If only we got more No question housing is
federal money or if only most people’s number
the state did more? cost and if you are
If they would just fund paying too much of your
my organization more Yeh, that too, but why income for that, well it
we could solve this the lack of jobs, becomes hard to break
problem. Really? why the lack of out of poverty.
Certainly gov’t funds affordable housing,
of good schools?
Why is everybody here
poor or near poor?
8. What Makes a Neighborhood Poor?
Sure, the lack of
Poor people? Bad educational system? resources for adequate
staffing, books,
facilities, special needs,
Well yes, but why are sure that contributes
they poor?
And how come so many
live in the same
proximity?
If only we got more No question housing is
federal money or if only most people’s number
the state did more? cost and if you are
If they would just fund paying too much of your
my organization more Yeh, that too, but why income for that, well it
we could solve this the lack of jobs, becomes hard to break
problem. Really? why the lack of out of poverty.
Certainly gov’t funds affordable housing,
of good schools?
Why is everybody here
poor or near poor?
9. What Makes a Neighborhood Poor?
Sure, the lack of
Poor people? Bad educational system? resources for adequate
staffing, books,
facilities, special needs,
Well yes, but why are sure that contributes
they poor?
And how come so many
live in the same
proximity?
Is it the lack of decent and
affordable housing?
If only we got more No question housing is
federal money or if only most people’s number
the state did more? cost and if you are
If they would just fund paying too much of your
my organization more Yeh, that too, but why income for that, well it
we could solve this the lack of jobs, becomes hard to break
problem. Really? why the lack of out of poverty.
Certainly gov’t funds affordable housing,
of good schools?
Why is everybody here
poor or near poor?
10. What Makes a Neighborhood Poor?
Sure, the lack of
Poor people? Bad educational system? resources for adequate
staffing, books,
facilities, special needs,
Well yes, but why are sure that contributes
they poor?
And how come so many
live in the same
proximity?
Is it the lack of decent and
affordable housing?
If only we got more I got it, it’s No question housing is
federal money or if only most people’s number
the state did more?
If they would just fund
the lack of jobs cost and if you are
paying too much of your
my organization more Yeh, that too, but why income for that, well it
we could solve this the lack of jobs, becomes hard to break
problem. Really? why the lack of out of poverty.
Certainly gov’t funds affordable housing,
of good schools?
Why is everybody here
poor or near poor?
11. What Makes a Neighborhood Poor?
Sure, the lack of
Poor people? Bad educational system? resources for adequate
staffing, books,
facilities, special needs,
Well yes, but why are sure that contributes
they poor?
And how come so many
live in the same
proximity?
Lack of
Government Is it the lack of decent and
Funding? affordable housing?
If only we got more I got it, it’s No question housing is
federal money or if only most people’s number
the state did more?
If they would just fund
the lack of jobs cost and if you are
paying too much of your
my organization more Yeh, that too, but why income for that, well it
we could solve this the lack of jobs, becomes hard to break
problem. Really? why the lack of out of poverty.
Certainly gov’t funds affordable housing,
of good schools?
Why is everybody here
poor or near poor?
12. What Makes a Neighborhood Poor?
Sure, the lack of
resources for adequate
staffing, books,
facilities, special needs,
Well yes, but why are
they poor?
Poor neighborhoods sure that contributes
And how come so many
live in the same are the direct result of the
proximity?
private financial services
sector determining that
such neighborhoods do
not fit into the bank’s
If only we got more
federal money or if only business plans No question housing is
most people’s number
the state did more? cost and if you are
If they would just fund paying too much of your
my organization more Yeh, that too, but why income for that, well it
we could solve this the lack of jobs, becomes hard to break
problem. Really? why the lack of out of poverty.
Certainly gov’t funds affordable housing,
of good schools?
Why is everybody here
poor or near poor?
13. What Makes a Neighborhood Poor?
Sure, the lack of
resources for adequate
staffing, books,
facilities, special needs,
Well yes, but why are sure that contributes
they poor?
And how come so many
live in the same
proximity?
If only we got more No question housing is
federal money or if only most people’s number
the state did more? cost and if you are
If they would just fund paying too much of your
my organization more Yeh, that too, but why income for that, well it
we could solve this the lack of jobs, becomes hard to break
problem. Really? why the lack of out of poverty.
Certainly gov’t funds affordable housing,
of good schools?
Why is everybody here
poor or near poor?
14. What Makes a Neighborhood Poor?
Sure, the lack of
resources for adequate
staffing, books,
facilities, special needs,
Well yes, but why are sure that contributes
they poor?
And how come so many
live in the same
proximity?
We ought to make a law against that
If only we got more No question housing is
federal money or if only most people’s number
the state did more? cost and if you are
If they would just fund paying too much of your
my organization more Yeh, that too, but why income for that, well it
we could solve this the lack of jobs, becomes hard to break
problem. Really? why the lack of out of poverty.
Certainly gov’t funds affordable housing,
of good schools?
Why is everybody here
poor or near poor?
15. I’m sorry but one thing nags
at me.
Do you think people will
understand what we mean by
“ credit worthy borrowers
all”
Do you think they’ll get that
we’re talking about including
low and moderate income
neighborhoods?
Lets be clear about this.
I like that. That obligation part I like this a lot, I love to get this One thing that bothers me
Ought to doesn’t seem doesn’t quite cut it. We law passed about this is I don’t want
very strong... need strengthen that part banks to make unsustainable I THINK WE NAILED IT,
lets change that to to make sure they Except one thing bothers me. loans or unsafe or unsound ET’S PROPOSE IT TO
“have to” understand we want them It’s not only about loans, it’s loans. CONGRESS, WHAT DO
to be assertive or about ser vices, investments, Do you think we need to make YOU SAY.
affirmative in this every type of credit need. that clear in this law we’re I have some news for you:
obligation, so let’s add, say, So lets change the “loans” to creating?
the word “affirmative”. actually meeting “credit needs” Lets
16. So let’s create a law together that
we can get congress to pass that
would address this problem
I’m sorry but one thing nags
at me.
Do you think people will
understand what we mean by
“ credit worthy borrowers
all”
Do you think they’ll get that
we’re talking about including
low and moderate income
neighborhoods?
Lets be clear about this.
I like that. That obligation part I like this a lot, I love to get this One thing that bothers me
Ought to doesn’t seem doesn’t quite cut it. We law passed about this is I don’t want
very strong... need strengthen that part banks to make unsustainable I THINK WE NAILED IT,
lets change that to to make sure they Except one thing bothers me. loans or unsafe or unsound ET’S PROPOSE IT TO
“have to” understand we want them It’s not only about loans, it’s loans. CONGRESS, WHAT DO
to be assertive or about ser vices, investments, Do you think we need to make YOU SAY.
affirmative in this every type of credit need. that clear in this law we’re I have some news for you:
obligation, so let’s add, say, So lets change the “loans” to creating?
the word “affirmative”. actually meeting “credit needs” Lets
17. I’m sorry but one thing nags
at me.
Do you think people will
understand what we mean by
“ credit worthy borrowers
all”
Do you think they’ll get that
we’re talking about including
low and moderate income
neighborhoods?
Lets be clear about this.
I like that. That obligation part I like this a lot, I love to get this One thing that bothers me
Ought to doesn’t seem doesn’t quite cut it. We law passed about this is I don’t want
very strong... need strengthen that part banks to make unsustainable I THINK WE NAILED IT,
lets change that to to make sure they Except one thing bothers me. loans or unsafe or unsound ET’S PROPOSE IT TO
“have to” understand we want them It’s not only about loans, it’s loans. CONGRESS, WHAT DO
to be assertive or about ser vices, investments, Do you think we need to make YOU SAY.
affirmative in this every type of credit need. that clear in this law we’re I have some news for you:
obligation, so let’s add, say, So lets change the “loans” to creating?
the word “affirmative”. actually meeting “credit needs” Lets
18. Banks ought to have an obligation to
loan to all credit worthy borrowers
I’m sorry but one thing nags
at me.
Do you think people will
understand what we mean by
“ credit worthy borrowers
all”
Do you think they’ll get that
we’re talking about including
low and moderate income
neighborhoods?
Lets be clear about this.
I like that. That obligation part I like this a lot, I love to get this One thing that bothers me
Ought to doesn’t seem doesn’t quite cut it. We law passed about this is I don’t want
very strong... need strengthen that part banks to make unsustainable I THINK WE NAILED IT,
lets change that to to make sure they Except one thing bothers me. loans or unsafe or unsound ET’S PROPOSE IT TO
“have to” understand we want them It’s not only about loans, it’s loans. CONGRESS, WHAT DO
to be assertive or about ser vices, investments, Do you think we need to make YOU SAY.
affirmative in this every type of credit need. that clear in this law we’re I have some news for you:
obligation, so let’s add, say, So lets change the “loans” to creating?
the word “affirmative”. actually meeting “credit needs” Lets
19. Banks have an obligation to loan
to all credit worthy borrowers
I’m sorry but one thing nags
at me.
Do you think people will
understand what we mean by
“ credit worthy borrowers
all”
Do you think they’ll get that
we’re talking about including
low and moderate income
neighborhoods?
Lets be clear about this.
I like that. That obligation part I like this a lot, I love to get this One thing that bothers me
Ought to doesn’t seem doesn’t quite cut it. We law passed about this is I don’t want
very strong... need strengthen that part banks to make unsustainable I THINK WE NAILED IT,
lets change that to to make sure they Except one thing bothers me. loans or unsafe or unsound ET’S PROPOSE IT TO
“have to” understand we want them It’s not only about loans, it’s loans. CONGRESS, WHAT DO
to be assertive or about ser vices, investments, Do you think we need to make YOU SAY.
affirmative in this every type of credit need. that clear in this law we’re I have some news for you:
obligation, so let’s add, say, So lets change the “loans” to creating?
the word “affirmative”. actually meeting “credit needs” Lets
20. Banks have an affirmative obligation
to loan to all credit worthy borrowers
I’m sorry but one thing nags
at me.
Do you think people will
understand what we mean by
“ credit worthy borrowers
all”
Do you think they’ll get that
we’re talking about including
low and moderate income
neighborhoods?
Lets be clear about this.
I like that. That obligation part I like this a lot, I love to get this One thing that bothers me
Ought to doesn’t seem doesn’t quite cut it. We law passed about this is I don’t want
very strong... need strengthen that part banks to make unsustainable I THINK WE NAILED IT,
lets change that to to make sure they Except one thing bothers me. loans or unsafe or unsound ET’S PROPOSE IT TO
“have to” understand we want them It’s not only about loans, it’s loans. CONGRESS, WHAT DO
to be assertive or about ser vices, investments, Do you think we need to make YOU SAY.
affirmative in this every type of credit need. that clear in this law we’re I have some news for you:
obligation, so let’s add, say, So lets change the “loans” to creating?
the word “affirmative”. actually meeting “credit needs” Lets
21. Banks have an affirmative obligation
to address the credit needs
of all credit worthy borrowers
I’m sorry but one thing nags
at me.
Do you think people will
understand what we mean by
“ credit worthy borrowers
all”
Do you think they’ll get that
we’re talking about including
low and moderate income
neighborhoods?
Lets be clear about this.
I like that. That obligation part I like this a lot, I love to get this One thing that bothers me
Ought to doesn’t seem doesn’t quite cut it. We law passed about this is I don’t want
very strong... need strengthen that part banks to make unsustainable I THINK WE NAILED IT,
lets change that to to make sure they Except one thing bothers me. loans or unsafe or unsound ET’S PROPOSE IT TO
“have to” understand we want them It’s not only about loans, it’s loans. CONGRESS, WHAT DO
to be assertive or about ser vices, investments, Do you think we need to make YOU SAY.
affirmative in this every type of credit need. that clear in this law we’re I have some news for you:
obligation, so let’s add, say, So lets change the “loans” to creating?
the word “affirmative”. actually meeting “credit needs” Lets
22. Banks have an affirmative obligation to address
the credit needs of all credit worthy borrowers,
consistent with safety and soundness
I’m sorry but one thing nags
at me.
Do you think people will
understand what we mean by
“ credit worthy borrowers
all”
Do you think they’ll get that
we’re talking about including
low and moderate income
neighborhoods?
Lets be clear about this.
I like that. That obligation part I like this a lot, I love to get this One thing that bothers me
Ought to doesn’t seem doesn’t quite cut it. We law passed about this is I don’t want
very strong... need strengthen that part banks to make unsustainable I THINK WE NAILED IT,
lets change that to to make sure they Except one thing bothers me. loans or unsafe or unsound ET’S PROPOSE IT TO
“have to” understand we want them It’s not only about loans, it’s loans. CONGRESS, WHAT DO
to be assertive or about ser vices, investments, Do you think we need to make YOU SAY.
affirmative in this every type of credit need. that clear in this law we’re I have some news for you:
obligation, so let’s add, say, So lets change the “loans” to creating?
the word “affirmative”. actually meeting “credit needs” Lets
23. Banks have an affirmative obligation to address
the credit needs of all credit worthy borrowers, I’m sorry but one thing nags
at me.
Do you think people will
consistent with safety and soundness, including
understand what we mean by
“ credit worthy borrowers
all”
Do you think they’ll get that
we’re talking about including
low and moderate income neighborhoods low and moderate income
neighborhoods?
Lets be clear about this.
I like that. That obligation part I like this a lot, I love to get this One thing that bothers me
Ought to doesn’t seem doesn’t quite cut it. We law passed about this is I don’t want
very strong... need strengthen that part banks to make unsustainable I THINK WE NAILED IT,
lets change that to to make sure they Except one thing bothers me. loans or unsafe or unsound ET’S PROPOSE IT TO
“have to” understand we want them It’s not only about loans, it’s loans. CONGRESS, WHAT DO
to be assertive or about ser vices, investments, Do you think we need to make YOU SAY.
affirmative in this every type of credit need. that clear in this law we’re I have some news for you:
obligation, so let’s add, say, So lets change the “loans” to creating?
the word “affirmative”. actually meeting “credit needs” Lets
24. The Community Reinvestment Act
Passed by the U.S.Congress and signed by
President Carter in 1977:
Banks have an affirmative obligation to address
the credit needs of all credit worthy borrowers, I’m sorry but one thing nags
at me.
Do you think people will
consistent with safety and soundness, including
understand what we mean by
“ credit worthy borrowers
all”
Do you think they’ll get that
we’re talking about including
low and moderate income neighborhoods low and moderate income
neighborhoods?
Lets be clear about this.
I like that. That obligation part I like this a lot, I love to get this One thing that bothers me
Ought to doesn’t seem doesn’t quite cut it. We law passed about this is I don’t want
very strong... need strengthen that part banks to make unsustainable I THINK WE NAILED IT,
lets change that to to make sure they Except one thing bothers me. loans or unsafe or unsound ET’S PROPOSE IT TO
“have to” understand we want them It’s not only about loans, it’s loans. CONGRESS, WHAT DO
to be assertive or about ser vices, investments, Do you think we need to make YOU SAY.
affirmative in this every type of credit need. that clear in this law we’re I have some news for you:
obligation, so let’s add, say, So lets change the “loans” to creating?
the word “affirmative”. actually meeting “credit needs” Lets
28. So How’s CRA working in Hawaii?
Let’s Look at a Sample of Home Mortgage Lending in Honolulu
29. So How’s CRA working in Hawaii?
Let’s Look at a Sample of Home Mortgage Lending in Honolulu
First we’ll look at how all lenders are doing in LMI areas, then
we’ll take a closer look at these three banks:
Bank of Hawaii Central Pacific Bank USAA Federal Savings Bank
10750 Robert F McDermott Fwy
130 Merchant Street 220 South King Street San Antonio, TX 78288-000
Honolulu, Hawaii 96813 Honolulu, Hawaii 96813
30.
31. FIRST - ALL LENDERS - Are they affirmatively
meeting the mortgage credit needs of all
Honolulians (sic) are they lending in LMI areas?
44. •
USAA Bank offered a considerably lower percentage of loans to Asians than all
lenders as a group.
o USAA issued 14% of its loans to Asians, while all lenders as a group made 54% of
their loans to Asians.
•
Asians make up 48% of the households in Honolulu, yet received only 14% of USAA’s loans.
•
In contrast, USAA made 55% of its loans to whites, while all lenders as a group made only 24%.
•
Native Hawaiians received 4% of USAA’s loans, while all lenders as a group made 9% of their loans to this group.
•
Low-and-Moderate Income (LMI) borrowers received just 10% of USAA’s loans, while all lenders as a group provided 23% of their loans to LMI
borrowers.
Bank of Hawaii:
•
Bank of Hawaii offered a lower percentage of loans to Native Hawaiians than all
lenders as a group.
o The bank issued 6% of its loans to Native Hawaiians, while all lenders, as a group,
made 9% of their loans to the same group.
o Native Hawaiians make up 17% of the households in Honolulu.
•
Bank of Hawaii can probably do a better job of providing loans to LMI households in proportion to their population.
o The bank issued 22% of their loans to LMI borrowers, while all lenders as a group provided 23%.
o LMI households make up 39% of the households in Honolulu.
•
Bank of Hawaii does a good job of making loans to Asians.
o The bank issued 59% of their loans to Asians, while all lenders, as a group, made 54%.
Central Pacific HomeLoans:
•
Central Pacific HomeLoans offered a lower percentage of loans to Native Hawaiians
than all lenders as a group.
o Central Pacific issued 6% of its loans to Native Hawaiians (similar to Bank of Hawaii), while all lenders, as group, made 9%.
o Central Pacific did a better job serving LMI borrowers. It made 25% of its loans to LMI households, while all lenders as a group made just
23%.
47. So how can CRA change this scenario?
*Banks tested/examined every two-three years on: Lending,Servicing and Investments.
Bank examiners have listen to you.The CRA requires that each insured depository
institution's record in helping meet the credit needs of its entire community be
evaluated periodically. That record is taken into account in considering an institution's
application for deposit facilities, including mergers and acquisitions. CRA
examinations (see Exam Schedules) are conducted by the federal agencies that are
responsible for supervising depository institutions: the Board of Governors of the
Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC),
and the Office of the Comptroller of the Currency (OCC)
48. So how can CRA change this scenario?
*Banks tested/examined every two-three years on: Lending,Servicing and Investments.
Bank examiners have listen to you.The CRA requires that each insured depository
institution's record in helping meet the credit needs of its entire community be
evaluated periodically. That record is taken into account in considering an institution's
application for deposit facilities, including mergers and acquisitions. CRA
examinations (see Exam Schedules) are conducted by the federal agencies that are
responsible for supervising depository institutions: the Board of Governors of the
Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC),
and the Office of the Comptroller of the Currency (OCC)
*Data available on what banks are doing. New from Dodd-Frank is small business data - NCRC does this for you.
49. So how can CRA change this scenario?
*Banks tested/examined every two-three years on: Lending,Servicing and Investments.
Bank examiners have listen to you.The CRA requires that each insured depository
institution's record in helping meet the credit needs of its entire community be
evaluated periodically. That record is taken into account in considering an institution's
application for deposit facilities, including mergers and acquisitions. CRA
examinations (see Exam Schedules) are conducted by the federal agencies that are
responsible for supervising depository institutions: the Board of Governors of the
Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC),
and the Office of the Comptroller of the Currency (OCC)
*Data available on what banks are doing. New from Dodd-Frank is small business data - NCRC does this for you.
*New CFPB - new sheriff in town -will write rules on collecting data, enforcing fair lending laws, even has a
special office for older Americans.
50. So how can CRA change this scenario?
*Banks tested/examined every two-three years on: Lending,Servicing and Investments.
Bank examiners have listen to you.The CRA requires that each insured depository
institution's record in helping meet the credit needs of its entire community be
evaluated periodically. That record is taken into account in considering an institution's
application for deposit facilities, including mergers and acquisitions. CRA
examinations (see Exam Schedules) are conducted by the federal agencies that are
responsible for supervising depository institutions: the Board of Governors of the
Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC),
and the Office of the Comptroller of the Currency (OCC)
*Data available on what banks are doing. New from Dodd-Frank is small business data - NCRC does this for you.
*New CFPB - new sheriff in town -will write rules on collecting data, enforcing fair lending laws, even has a
special office for older Americans.
*It’s all about working in Coalition - CRA coalitions work - PNC example
51. So how can CRA change this scenario?
*Banks tested/examined every two-three years on: Lending,Servicing and Investments.
Bank examiners have listen to you.The CRA requires that each insured depository
institution's record in helping meet the credit needs of its entire community be
evaluated periodically. That record is taken into account in considering an institution's
application for deposit facilities, including mergers and acquisitions. CRA
examinations (see Exam Schedules) are conducted by the federal agencies that are
responsible for supervising depository institutions: the Board of Governors of the
Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC),
and the Office of the Comptroller of the Currency (OCC)
*Data available on what banks are doing. New from Dodd-Frank is small business data - NCRC does this for you.
*New CFPB - new sheriff in town -will write rules on collecting data, enforcing fair lending laws, even has a
special office for older Americans.
*It’s all about working in Coalition - CRA coalitions work - PNC example
*Meetings with lenders, defining credit needs, documenting those meetings
52. So how can CRA change this scenario?
*Banks tested/examined every two-three years on: Lending,Servicing and Investments.
Bank examiners have listen to you.The CRA requires that each insured depository
institution's record in helping meet the credit needs of its entire community be
evaluated periodically. That record is taken into account in considering an institution's
application for deposit facilities, including mergers and acquisitions. CRA
examinations (see Exam Schedules) are conducted by the federal agencies that are
responsible for supervising depository institutions: the Board of Governors of the
Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC),
and the Office of the Comptroller of the Currency (OCC)
*Data available on what banks are doing. New from Dodd-Frank is small business data - NCRC does this for you.
*New CFPB - new sheriff in town -will write rules on collecting data, enforcing fair lending laws, even has a
special office for older Americans.
*It’s all about working in Coalition - CRA coalitions work - PNC example
*Meetings with lenders, defining credit needs, documenting those meetings
*Celebrating when a bank does more in LMI areas, commenting on when they perform poorly - let
the public know who is lending to LMI Hawaiians and who is not - a Community Lending Scorecard
53. So how can CRA change this scenario?
*Banks tested/examined every two-three years on: Lending,Servicing and Investments.
Bank examiners have listen to you.The CRA requires that each insured depository
institution's record in helping meet the credit needs of its entire community be
evaluated periodically. That record is taken into account in considering an institution's
application for deposit facilities, including mergers and acquisitions. CRA
examinations (see Exam Schedules) are conducted by the federal agencies that are
responsible for supervising depository institutions: the Board of Governors of the
Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC),
and the Office of the Comptroller of the Currency (OCC)
*Data available on what banks are doing. New from Dodd-Frank is small business data - NCRC does this for you.
*New CFPB - new sheriff in town -will write rules on collecting data, enforcing fair lending laws, even has a
special office for older Americans.
*It’s all about working in Coalition - CRA coalitions work - PNC example
*Meetings with lenders, defining credit needs, documenting those meetings
*Celebrating when a bank does more in LMI areas, commenting on when they perform poorly - let
the public know who is lending to LMI Hawaiians and who is not - a Community Lending Scorecard
*Create a linked deposit program - city ordinance
54. How Cities Can Pursue
Responsible Banking:
Model City Ordinance to Create Community Reinvestment
Requirements for Depository Institutions
October 2010
MODEL CITY ORDINANCE
WHEREAS, The practices and products (such as loan and investment products) of financial
institutions have a measurable impact on the City’s tax base, quality of life and overall
economic viability and competitiveness; and
WHEREAS, Economic viability and competitiveness comes from strengthening, and
providing opportunities within all areas of the City;
WHEREAS, financial institutions receive deposits and other forms of investments and
accounts from City residents;
BE IT RESOLVED, therefore, that in return for the privilege of safeguarding and investing
the community’s wealth and doing business with the City, the financial institutions have a
continuing and affirmative obligation to serve the credit and other financial needs of all
communities, including and especially minority and low- and moderate-income communities,
consistent with safety and soundness. The City shall assess financial institutions’ performance
in meeting community needs and use this assessment as a factor in its decision to place
municipal deposits in financial institutions and conduct other business with financial
institutions.
55. Get involved with The National
Community Reinvestment
Join NCRC
www.ncrc.org
Thank you