Monday, July 6, 2015

Are You Meeting the Credit Needs of Your Community?  
For many, the Community Reinvestment Act, (“CRA”) represents yet another compliance task without merit.  What if instead of being an administrative burden, compliance with the CRA resulted in greater marketing opportunities and greater opportunities for overall profitability? These opportunities exist if you embrace the concept of meeting the needs of your community. 
One of the main tenants of the Community Reinvestment Act is that banks should strive to meet the credit needs of the communities in which they take deposits.   The reason that this is one of the main parts of the regulation and for that matter, the reason that the CRA exists at all is a story for a different time.  Suffice to say that for years, banks engaged in the practice of “redlining” which meant that they directly ignored the credit needs of many communities.   Redlining was the process of drawing a red line around certain neighborhoods on a map and making a deliberate decision that no loans would be granted within the boundaries of the red line. The deposits of communities that had been red-lined, became the source of lending funds for other communities.   Red-lining then, was one of the main practices that the CRA was designed to stop.  
When the CRA was first enacted, it was designed to get financial institutions to take a second look at communities that had been historically overlooked for credit by financial institutions. Though these communities tended to be populated with low to moderate income borrowers, these borrowers represent significant opportunities for good credit. The CRA was a means to an ends to get banks and financial institutions to “meet the credit needs of the communities in which they operate, including low- and moderate-income neighborhoods, consistent with safe and sound banking operations”   [1]
Over the years, even though billions of dollars of investments have been made in communities that were being overlooked[2], the reputation of the CRA has become the regulation that forces banks to make “bad loans”. However, the true emphasis of the regulation has been and always will be to encourage banks to assess the credit needs of the communities they serve. In other words, one of the main goals of the regulations was to get banks to find credit “diamonds in the rough” in areas that had traditionally been written off.
Opportunities Abound
The strategy of serving communities that have been overlooked has been successfully and very profitably employed by none other than hall of fame basketball star Earvin “Magic” Johnson. His Magic Johnson Enterprises has partnered with all manner of fortune 500 companies to invest over $500 million in communities that had been overlooked.  Using the approach of finding the “diamonds in the rough” Johnson’s companies continue to grow and show amazing profits by investing in low to moderate income communities.  So how does he find these opportunities? “Magic Johnson Enterprises is known for successfully staying rooted in communities because they understand those communities’ unique needs and personalities[3]. In other words, he knows the needs of his communities and provides services that meet those needs.
 Women Owned Businesses- A Growing Opportunity 
In its report, entitled “The 2015 State of Women Owned Business Report” American Express’ Open, detailed the tremendous growth of women owned businesses from 1997 through 2015: 
 
 Between 1997 and 2015, when the number of businesses in the United States increased by 51%, the number of women-owned firms increased by 74% – a rate 1-1/2 times the national average. Indeed, the growth in the number (up 74%), employment (up 12%) and revenues (up 79%) of women-owned firms over the past 18 years exceeds the growth rates of all but the largest, publicly-traded firms – topping growth rates among all other privately-held businesses over this period.[4]
 
The report also points out that women owned firms tend to be smaller than average.  Women owned firms are the fastest growing in number and economic clout.  These firms also tend to have specific credit needs.  Is your bank considering these needs and developing products to address them?  If not a huge opportunity is passing you by.  
 
Micro Lending  
Though micro lending has been very popular in several foreign countries, the industry is fairly new in the United States.   Micro businesses are defined as “a business with five or fewer employees that requires no more than $35,000 in start-up capital.”  [5]   There is a surprisingly large number of businesses in the United States that meet this definition.   In 2011, there were approximately 26 million micro businesses. [6]     Each of these businesses represents a group of people that working towards self-sufficiency, greater wealth and ultimately, the potential to be significant customers at commercial banks.    
In the United States, the Small Business Administration defines a microloan as one at or below $50,000.  Data as of 2012 showed that the average loan for a microenterprise was $14,000. [7] Currently there are several sources for obtaining microloans, including nonprofit organizations, community development financial institutions and private equity funds  
A formal micro lending program would be the ultimate in innovation.  Such a program would greatly enhance the reputation of a bank within its community.   It is worth nothing that micro lending programs have been very profitable both internationally and in the United States. 
 
The FFIEC’s proposed   Interagency Questions and Answers Regarding Community Reinvestment make it clear that the focus in the future will be on innovation in lending and creativity in delivering banking services.  Credit will be given to lenders for innovation in lending. [8] 
 
Embracing Credit Needs  
For banks, embracing the concept of determining and meeting the credit needs of the community can yield very positive results. The list of factors that make up the consideration of credit needs from the Federal Reserve Bank of Atlanta’s publication “Community Reinvestment – Does Your Bank Measure Up?” includes the following;  
  • The makeup of the community;
  • What the local and regional economic conditions are;
  • What kind of opportunities exist for serving the community through lending and investments;
  • What your banks business strategy and products are; how is your bank doing financially;
  • What your bank sees as the credit needs of the community; and
  • What individuals, community and civic organizations, and business-as well as state, local, and tribal government-think about your banks efforts toward meeting the community credit needs.
By placing a heavy emphasis on the determination of the credit needs of the community, banks can not only meet the requirements of the CRA, but also discover profit opportunities in communities that have been overlooked. This process does not have to involve a great deal of expense or effort.  Contacting civic groups, getting out into the community, talking with local businesses is painless and inexpensive.   The credit needs of your community will continue to grow and change.  Make sure you are ready to be a full participant


[1] Don't Blame Subprime Mortgage Crisis or Financial Meltdown on CRA  Stable Communities.com 2008
[2] See The Community Reinvestment Act: 30 Years of Wealth   Building and What We Must Do to Finish the Job John Taylor and Josh Silver National Community Reinvestment Coalition
[3] Magic Johnson Enterprises Helps Major Corporations Better Serve the Multicultural Consumer  Business Wire 2008
[4] “The 2015 State of Women Owned Business Report” American Express’ Open  page 1
[5] Elaine L. Edgcomb and Joyce A. Klein, “Opening Opportunities, Building Ownership: Fulfilling the Promise of Microenterprises in the United States,” FIELD, February 2005, http://www.fieldus.org/ publications/FulfillingthePromise.pdf.
[6] Microenterprise Development: A Primer,” FDIC Quarterly 5, No. 1 (2011):
[8]   Community Reinvestment Act; Interagency Questions and Answers Regarding Community Reinvestment; Notice  September 3, 2014

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