Shows
The CRA Podcast with Linda Ezuka#083: Building Financial Resilience for Military Families with GoVA FoundationIn 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...
2025-08-2041 minThe CRA Podcast with Linda Ezuka#082: CRA Tips: Less is More - Perfecting Your CRA File by Cutting the ClutterAs 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 fo...
2023-11-0710 minThe CRA Podcast with Linda Ezuka#081: CRA Tips: 46th Anniversary of the CRA - How will you serve?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 u...
2023-10-3105 minThe CRA Podcast with Linda Ezuka#080: CRA Tips: CRA Services Hours, Events, or Instances? What the What?!?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 t...
2023-10-1708 minThe CRA Podcast with Linda Ezuka#079: CRA Tips: You are not alone...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...
2023-10-1012 minThe CRA Podcast with Linda Ezuka#078: CRA Tips: Finish Strong: How to Prepare for Your Next CRA ExamIn 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...
2023-10-0309 minThe CRA Podcast with Linda Ezuka#077: CRA Tips: CDCs-Your Partners in Community DevelopmentI 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 lo...
2023-09-2612 minThe CRA Podcast with Linda Ezuka#076: Beyond Bricks and Mortar: Rethinking Community Development Strategy to Address Digital Inequity with Sarah Hope MarshallSarah 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...
2023-09-1929 minThe CRA Podcast with Linda Ezuka#075: CRA Tip: The Pandemic May Be Over but SBA PPP Loans May Still Have an Impact During Your Next ExamYour 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 PP...
2023-09-1208 minThe CRA Podcast with Linda Ezuka#074: CRA Tips: What "hooks" could a loan to a nonprofit fall under?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...
2023-09-0507 minThe CRA Podcast with Linda Ezuka#073: CRA Tips: I'm an ISB, do I really need to look at my lending performance?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...
2023-08-2907 minThe CRA Podcast with Linda Ezuka#072: CRA Tips: Naturally Occurring Affordable Housing and CD LoansNaturally 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...
2023-08-2206 minThe CRA Podcast with Linda Ezuka#071: CRA Tips: CRA Services-What exactly does the provision of financial services mean?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.pdf
2023-08-1507 minThe CRA Podcast with Linda Ezuka#070: CRA Services: If It’s Not Documented, It Didn’t HappenI 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...
2023-08-0808 minThe CRA Podcast with Linda Ezuka#69: CRA Tips: Regulatory Change Part III: Operational and Financial RisksAs 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"...
2023-08-0110 minThe CRA Podcast with Linda Ezuka#068: CRA Tips: Regulatory Change Part II: Reputational RiskRegulators 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. T...
2023-07-2507 minThe CRA Podcast with Linda Ezuka#67: CRA Tips: Regulatory Change Part I: Compliance Risk - The Only Constant is ChangeIt’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 agen...
2023-07-1809 minThe CRA Podcast with Linda Ezuka#66: CRA Tips: Revisiting the Fundamentals: The Most Overlooked CD HookWe’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 vi...
2023-07-1109 min
The CRA Podcast with Linda Ezuka#65: CRA Tips: Revisiting the Fundamentals: A Community Development Loan PrimerThis 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 develo...
2023-07-0509 min
The CRA Podcast with Linda Ezuka#64: Bridging the Racial Wealth Divide with NCRC's Community Development FundNCRC 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...
2023-06-2727 min
The CRA Podcast with Linda Ezuka#63: CDFI Partnership with Joshua KummerThis 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...
2022-10-0425 min
The CRA Podcast with Linda Ezuka#62: What exactly is the BLS and how does it relate to the CRA?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...
2022-09-0803 min
The CRA Podcast with Linda Ezuka#61: Community Development Loans DemystifiedCRA 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...
2022-07-0720 min
The CRA Podcast with Linda Ezuka#60: How to Leverage Internal Expertise to Drive External ImpactAre 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 crea...
2022-05-3106 minThe CRA Podcast with Linda Ezuka#59: Economic Development as a Key to Community Development ServicesThere 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...
2022-05-2405 minThe CRA Podcast with Linda Ezuka#58: How to Increase your CRA Services By Partnering with Impactful OrganizationsAfter 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 suppo...
2022-05-1706 minThe CRA Podcast with Linda Ezuka#57: I Bet You Are Underreporting Your Community Development Loans… Most Banks Are Too!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 reve...
2022-05-1005 minThe CRA Podcast with Linda Ezuka#56: Key Departments Critical to A Sound CRA Training ProgramA 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...
2022-05-0305 min
The CRA Podcast with Linda Ezuka#55: From Elementary School Principal to Community Development Banker“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 Americ...
2022-04-2730 min
The CRA Podcast with Linda Ezuka#54: Inspiring Our Next Generation of Financially Literate Students“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 incr...
2022-04-1919 min
The CRA Podcast with Linda Ezuka#53: It’s National Financial Capability Month…Where Do I Begin?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 ta...
2022-04-1205 min
The CRA Podcast with Linda Ezuka#52: Inspiring You to Greatness with Tawalla SimmonsFor 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...
2022-04-0515 minThe CRA Podcast with Linda Ezuka#51: CRA Plan Checklist Inside!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...
2022-03-2904 min
The CRA Podcast with Linda Ezuka#50: Haven’t Developed a CRA Plan Yet?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 accomplish...
2022-03-2206 minThe CRA Podcast with Linda Ezuka#49: Congrats! Take The Day Off!!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 C...
2022-03-0105 minThe CRA Podcast with Linda Ezuka#48: Just 120 Business Hours Left...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.
2022-02-2205 minThe CRA Podcast with Linda Ezuka#47: Just 10 Business Days Left...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 ru...
2022-02-1507 minThe CRA Podcast with Linda Ezuka#46: You Only Have Three Weeks Left...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 ov...
2022-02-0807 minThe CRA Podcast with Linda Ezuka#45: Three Ways to Supplement Your CRA Program TodayLet'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 up...
2022-02-0106 minThe CRA Podcast with Linda Ezuka#44: How to Build the Culture of Compliance Within the BankSo, 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...
2022-01-2506 minThe CRA Podcast with Linda Ezuka#43: How to Add a Team Member to Your CRA Mighty Team of OneSo, 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...
2022-01-1805 minThe CRA Podcast with Linda Ezuka#42: How to Grow Your Team Without Adding StaffLet'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...
2022-01-1105 minThe CRA Podcast with Linda Ezuka#41: How to Do the Undoable DealWe 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 avai...
2021-12-2805 minThe CRA Podcast with Linda Ezuka#40: It Takes a Village...Do You Know Who You Can Trust?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...
2021-12-2107 minThe CRA Podcast with Linda Ezuka#39: Community Development Finance: Yes, It’s Part of Your Job Too!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...
2021-12-1406 min
The CRA Podcast with Linda Ezuka#38: Bank On: Bringing the Unbanked and Underbanked into the Financial MainstreamCities 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...
2021-12-0738 minThe CRA Podcast with Linda Ezuka#37: I Failed My CRA Data Integrity Exam – Now What?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...
2021-11-3005 minThe CRA Podcast with Linda Ezuka#36: Best Practices to Ensure CRA Data IntegrityGather 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...
2021-11-2305 minThe CRA Podcast with Linda Ezuka#35: The Secret to a Smooth CRA Data Integrity Exam!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 extr...
2021-11-1605 minThe CRA Podcast with Linda Ezuka#34: How to Ace Your Next CRA Data Integrity Exam!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...
2021-11-0903 minThe CRA Podcast with Linda Ezuka#33: The Devil Is in the Details but Don’t Let It Get to Your Data, Too!The purpose of CRA data collection and maintenance is to enable examiners and the public to evaluate (through issuance of a CRA Performance Evaluation) whether a bank is helping to meet the credit needs of its communities through its small business and small farm loans. Accurate data leads to accurate assessments of fair lending and CRA lending performance. When data errors do occur, not only is the bank subject to reputational risk, but costly remediations and an erosion of consumer confidence may also ensue.Three Common Challenges: • Determining which commercial loan transactions are reportable and/or which on...
2021-11-0205 minThe CRA Podcast with Linda Ezuka#32: Creative Items to Add to Your CRA Committee Meeting AgendaAre you looking for creative ways to reinvigorate your CRA committee meetings?It is crucial to foster communication and collaboration during these meetings, so people leave inspired and are motivated to get involved in your CRA program. But, this is easier said than done. Here are a couple strategies that help generate a larger impact during your CRA committee meetings.• Invite a CDFI to present (either a CDFI that you partner with or that you may partner with) to learn more about their impactful work.• Bring in a nonprofit that serves low to m...
2021-10-2605 minThe CRA Podcast with Linda Ezuka#31: Three Documents You Must Have for Your CRA ProgramWhen it comes to CRA program governance, there are three documents that every CRA program should have: a CRA policy, a CRA program plan and a CRA self-assessment.The CRA Policy: This document explains what you stand for, how you run your CRA program from the highest level, and how the program fits into your overall governance.The CRA Program Plan: This document explains the nitty gritty of your CRA program and institutionalizes it for the bank and your future CRA officers. What staffing do you have in place? Do you have a CRA committee? Do...
2021-10-1905 minThe CRA Podcast with Linda Ezuka#30: Repurpose Your CRA Self Assessment To Build Awareness and Buy-InOnce you have a solid self-assessment document, now it is time to socialize it. Not only will you increase awareness of your CRA program, but you will also be using it as a training tool. Make sure you break it down to the discrete applicable parts to avoid overwhelm. Consider setting up time with the following teams...and bring coffee! Emphasize their specific impact in the work and highlight your bank’s strengths and weaknesses. Listen to their responses and add their feedback as valuable performance context! • The CRA Team – your MVPs! • Bank Directors, Executive Manageme...
2021-10-1205 minThe CRA Podcast with Linda Ezuka#29: 5 Key Resources To Inform Your CRA Self AssessmentDoes a blank page make you nervous? Yes, us too. Here are some documents you may want to reference (and even borrow the framework of!) to get you started on your CRA self assessment. • Peer Data: Download performance evaluations from similarly situated banks in your assessment areas.• Industry Data: Data from local community development think tanks, government agencies, or nonprofits. National statistics on demographics, labor, market, housing, small business, affordability, poverty, etc.• PE Templates: Performance evaluation templates are available at FFIEC.gov. Make sure to select the correct template based on your asset size...
2021-10-0504 minThe CRA Podcast with Linda Ezuka#28: Choices. Make One and Let’s Get to Work!There just aren’t enough hours in the day. We get it. Many institutions believe they don’t have time to perform a self-assessment. What you may not know is that there are many types of self-assessments, some easier than others. Check out this list of assessment types to determine what kind of assessment will best fit your institution’s needs. Having a CRA self assessment is a best practice and a must have. Lite Self Assessment If you don’t have one, start with a “lite” version. This is often similar to an executive summary. Take a macro-view...
2021-09-2807 minThe CRA Podcast with Linda Ezuka#27: Look Back to Learn How to Look ForwardMany banks make the mistake of spending too much time over-analyzing their performance history without giving equal airtime to formulating new strategies to address performance gaps within their CRA programs. It is imperative to create a self assessment that mimics a regulatory framework to assess your past performance. This document will not only get you exam-ready, but it will also serve as a foundation to build upon. Once you have a solid understanding of your bank’s key performance indicators, you can then move forward in developing strategies and partnerships with community-based initiatives and organizations to pr...
2021-09-2104 minThe CRA Podcast with Linda Ezuka#26: Strategy Is a Commodity, Execution Is an ArtDo you know what your bank’s strategy is? If this is not something that has been shared with you, reach out to leaders within your organization’s hierarchy to learn more. Ask questions like, “What are your division's key priorities?” and/or “What is the major initiative you are focusing on this year?” Take this information and brainstorm ways that you can align their strategies and initiatives with your CRA program priorities. Aligning your CRA strategy with your institution’s overall strategy will make it easier for employees to see how their role adds value to the bank’s core bu...
2021-09-1404 minThe CRA Podcast with Linda Ezuka#25: Don’t Leave This for the Examiners to DecideThe single most important CRA exam prep tool for you to consider is a CRA self-assessment. CRA self-assessments are assessments you perform on your own institution to understand your CRA strengths and performance gaps. If done correctly, the self-assessment mirrors an examiner’s approach to assessing your performance under the CRA. This assessment helps you understand how you’re currently performing, so you can prepare your performance context and story for your next CRA examination. There are three different types of CRA self-assessments: lite, targeted and comprehensive.Self-assessments are living and breathing documents that shou...
2021-09-0705 minThe CRA Podcast with Linda Ezuka#24: CDFIs Are Changing The World. Will You Join Them?Community Development Financial Institutions (CDFIs) were created to deliver responsible, affordable lending to help low-income, low-wealth and other disadvantaged people and communities join the economic mainstream. CDFIs can’t do this work alone. They are your partners in community development, not your competition! CDFIs make loans that you can’t make due to regulatory constraints, which makes them excellent partners. Reach out to your local CDFI and consider the vast array of partnership opportunities, including:• Instituting a loan referral program (formal or informal arrangements)• Serving on a loan approval or fundraising committee• Helping CDFIs refine the...
2021-08-3104 minThe CRA Podcast with Linda Ezuka#23: $2.2 Billion Is at Stake for Low-Income TaxpayersJoin the network of thousands of volunteers that ensures millions of low-income taxpayers receive billions of dollars in refunds, a network that helps the community meet their civic obligations as taxpayers and supports them on the path to financial security and opportunity. Consider volunteering for the Volunteer Income Tax Assistance (VITA) program. You can volunteer in your local community through various VITA sites, usually run by local nonprofit organizations (Goodwill, YMCA, Catholic Charities, etc.). You can potentially get CRA service consideration for both the training and the actual tax preparation services you perform through the program....
2021-08-2404 minThe CRA Podcast with Linda Ezuka#22: The Average American Has $90,460 In Consumer DebtAccording to Experian data, if you have a credit card or two in your wallet, you're not alone. There is over $756 billion in outstanding credit card debt in the U.S., and approximately 95% of adults have a credit card account open in their name, according to Experian data from the third quarter (Q3) of 2020.In other words, every month should be financial literacy month! You don’t have to wait for next April to come to deploy financial literacy programs. The best time is now! There are many ways to adopt and/or develop a financial li...
2021-08-1703 minThe CRA Podcast with Linda Ezuka#21: 1 Super Simple Community Development Service You Might Be Under-ReportingThe low-hanging fruit of community development services is…boards and committees! Many bank executives and employees are or could be serving on nonprofit boards and committees. These service hours and activities count towards the majority of community development services for most banks. Make sure you are diligently collecting this data and not letting it fall through the cracks. You may want to add a link to your intranet or launch a campaign and incentivize employees to report their board and committee service hours. Quotes• “I estimate that the boards and committees that your banker...
2021-08-1004 minThe CRA Podcast with Linda Ezuka#20: Can the Countless Hours We Spent on the SBA PPP Count? You Might Be Surprised...Can the countless hours you’ve spent on the SBA Paycheck Protection Program (PPP) count as a community development service?The answer is yes and no! Although your bank worked seemingly around the clock last year to stand up the SBA PPP, none of the hours spent internally creating the loan application portals, working on underwriting and compliance or deploying loans under the program count towards your CRA program.You will, however, count the SBA PPP as a special loan program and loans will count either as small business loans or may qualify as community development lo...
2021-08-0303 minThe CRA Podcast with Linda Ezuka#19: 3 Community Development Services You’d Be Surprised Don’t CountOn this week’s CRA Tip episode, we explore three community development services you might be surprised don’t count as CRA activities. Here is a brief overview:1. Serving food at your local homeless shelter. This activity does not relate to the provision of financial services.2. Helping build a Habitat for Humanity home during a weekend build. Again, this activity does not relate to the provision of financial services. 3. Ringing the bell for the Salvation Army’s major fundraiser each holiday season that raises over $125 million to support hunger alleviation and poverty reduction for our mo...
2021-07-2704 minThe CRA Podcast with Linda Ezuka#18: Are You Unintentionally Under-Serving Low- and Moderate-Income (LMI) Communities?Take a second look at the retail distribution of your branches, ATMs and deposit-taking ATMs. Sometimes, it is helpful to map these data points to visualize how far away your branches and ATMs are from the next closest low- or moderate-income area. Now that you’re looking more closely, does your retail distribution arbitrarily exclude LMI geographies?Make sure to work closely with the executive management, compliance and legal departments to ensure that any changes to branching strategy (opening, consolidating and closing branches) are vetted from a CRA perspective. In addition, make sure that your bank’s policies and...
2021-07-2003 min
The CRA Podcast with Linda Ezuka#17: 3 Ways to Inspire More Community Development Loan ActivitiesLast week, we talked about community development loan identification best practices – the low-hanging fruit that may already exist at your institution.Now, we switch our attention to proactive measures! Here are some best practices to increase the number of community development loan prospects that come across your desk. 1. AUTOMATE. Program your core system with community development definition prompts, so business lending units can easily identify potential community development loans at origination and onboarding.2. BUILD. Develop relationships with your loan teams through targeted training and frequent visits to stay “top of mind,” so loan officers will b...
2021-07-1304 minThe CRA Podcast with Linda Ezuka#16: Internal Stakeholders: Who They Are And Why They MatterYou can’t do this work alone. In fact, the best CRA programs are built around key stakeholders working together towards the same CRA goals. As you know, mining for community development loans (CDL) can be a very manual and time-consuming process. This is especially true given that the subjective and technical definitions of a CDL aren’t often necessary within each credit approval memorandum write-up. So, who is key to this work? 1. Key business lending units are the pathway for solid leads and early identification. Depending on the size of your bank, key depa...
2021-07-0604 minThe CRA Podcast with Linda Ezuka#15: Community Development Loans.... How Much Is Enough?Regulators are currently revisiting the way they define a community development loan (CDL) through CRA modernization efforts. So until there is more regulatory certainty, how do you determine how many CDL qualified loans are enough? While you can’t guarantee anything during the iterative swirl of CRA reform, this episode aims to give you a good idea of reasonable targets when executive management asks “how much is enough.” Here’s where you should start:• Look at your performance year-over-year to benchmark against your own performance. Specifically, review the following: (1) Year-over-year community development loan volume (# and $ amount) in each assessment...
2021-06-2904 minThe CRA Podcast with Linda Ezuka#14: Community Development Loan Mining Strategies You Don’t Want to MissWhen looking through your loan portfolio for qualified community development loans, it is essential to have a strategic approach given limited time and resources to conduct a 100% review. A tactical approach can save you time and help you qualify more loans to support your bank’s lending performance.Start with these subsets of community development loan prospects to yield an efficient review:• Loans to nonprofit organizations of any dollar amount• Small Business Administration (SBA) 504 loans• Renewals and major modifications• Loan officer/system identified loans• LMI areas/redevelopment districtsStart with the largest...
2021-06-2204 minThe CRA Podcast with Linda Ezuka#13: 5 Must-Have Strategy and Implementation Documents to Guide Your CRA ProgramAs you start building or refreshing your CRA program, these internal documents can serve as a guiding light. Gather these core documents and make sure you revisit them often as you initiate new programs and build your CRA culture throughout the bank.1. Institution’s Strategic Plan & Goals2. Marketing Plan and Activities3. CRA Plan & Goals4. CRA Self-Assessment5. CRA Policies and ProceduresMake sure you know what your bank’s core strategy priorities are for the year and make sure that all CRA programmatic documents fall under this umbrella of strategy to ensure aligned impa...
2021-06-1504 minThe CRA Podcast with Linda Ezuka#12: CRA Tips: A Series Created for CRA PractitionersManaging the Community Reinvestment Act (CRA) program for your financial institution can be challenging, especially if you’re new to the CRA. To support you in your CRA journey, CRA Today and Kadince have partnered to provide informative content to highlight CRA best practices and ideas to guide your CRA program. We will be producing a new CRA Tip podcast episode every Tuesday morning, so you can start your day with intention. We know you are busy so we will keep it tight and to the point. The weekly CRA Tips are designed to give you something quick to...
2021-06-0805 min
The CRA Podcast with Linda Ezuka#11: The Catalytic Impact of a $40 Million Investment in the CDFI SectorBB&T and SunTrust formed Truist with a shared purpose – to inspire and build better lives and communities equally and equitably across all geographies. By providing grants in support of nonprofit organizations through the Truist Foundation, we can help grow their impact. In the first half of this episode, we will hear from Lynette Bell, President of the Truist Foundation. Learn more about why Truist decided to invest $40 million in the CDFI sector and how banks, both large and small, should go about approaching CDFIs in their respective markets.In the second half of this episode, we will he...
2021-05-1951 min
The CRA Podcast with Linda Ezuka#10: EBA Fund Converting the promise of entrepreneurship into assets that build economic inclusion and equityCRA Podcast Episode: EBA Fund: Converting the promise of entrepreneurship into assets that build economic inclusion and equityThis episode interviews Brett Simmons, Fund Manager, and Joyce Klein, Chair of the Board of the EBA Fund and Director of Business Ownership Initiative, a program of the Aspen Institute. The podcast highlights the launch of Entrepreneur Backed Assets (EBA) Fund, is a new nonprofit creating a secondary market for microloans, a new tool to help capitalize CDFI lenders doing amazing work to serve entrepreneurs of color, small businesses in low-income communities, and the millions navigating through the pandemic.
2021-01-3047 min
The CRA Podcast with Linda Ezuka#09: findCRA and First Western Trust-Partnering for ImpactCRA Podcast Episode: findCRA and First Western Trust-Partnering for ImpactThis episode interviews findCRA Co-Founders, Ben Loehle and Brian Waters, and Ted Gerbick, Director of Marketing & Philanthropic Giving and Emily Gardner, Senior CRA Analyst of First Western Trust. Together we explore tools for modern day CRA programs, regulatory reform and philanthropic priorities during the pandemic. We end on a lighter note sharing our hopes for a fresh new year putting COVID behind us and looking forward to in-person convenings and more high impact community development work.findCRAfindCRA is a national software and CRA...
2021-01-0655 min
The CRA Podcast with Linda Ezuka#08: Demystifying Community ReinvestmentThis is a replay of an an CRA Files podcast interview. In this episode of the CRA Files, Ron Brooks interviews Linda Ezuka: Consultant. Community Advocate. Committed to transforming communities through the power of economic development and CRA. Listen to hear Linda describe her vision for the CRA Hub and other community development thoughts.CRA Partners is a turnkey CRA compliance program powered by the Senior Housing Crime Prevention Foundation. The Foundation operates Senior Crimestoppers, a nationwide crime prevention program educating and safeguarding against theft, abuse and neglect. Senior Crimestoppers is funded exclusively by the banking industry.
2020-11-1537 min
The CRA Podcast with Linda Ezuka#07: Jenny Flores of Wells Fargo and The Power of Diversity in Community DevelopmentThis episode interviews Jenny Flores, who leads the Wells Fargo Foundation as their Head of Small Business Growth Philanthropy. Jenny joins me in a community development conversation and Wells Fargo’s commitment to diversity, equity and inclusion in their programs supporting small business. This episode highlights the power of diversity, equity and inclusion in our collective community development work. Jenny Flores is Head of Small Business Growth Philanthropy for the Wells Fargo Foundation, one of the largest corporate foundations in the U.S. In 2018, the Wells Fargo Foundation donated $444 million to accelerate economic opportunity and success in underserved co...
2020-09-2323 min
The CRA Podcast with Linda Ezuka#06: Ken Thomas: CRA Modernization and COVID Recovery Efforts CollideThis podcast interviews Ken Thomas, Ph.D., one of our pioneers of the Community Reinvestment Act (CRA) to share a high-level overview of CRA Reform now that the Office of the Comptroller of the Currency (OCC) released its final rule. This episode highlights CRA modernization, interagency positions, politics and coronavirus recovery efforts.Key Topics and Interests: CRA Modernization, CRA Reform, OCC, FRB, FDIC, Community Reinvestment Act, CRA, Community Development, COVID19, Coronavirus recovery, SBA PPP, Ken Thomas, Community Development Partners, CRA TodayAs so many of us are working with our banks to support our...
2020-05-2628 minThe CRA Podcast with Linda Ezuka#05: Community Action and Partnerships Prevails as Banks Mobilize to Respond to COVID-19Just when we were all getting ready to sit down and draft our OCC and FDIC CRA Comment Letters in preparation for our April 8th deadline, the unfathomable happened: our world shifted to all things COVID-19. Linda Ezuka shares her thoughts around bank's role in recovery efforts and provides details of the interagency regulatory response under the CRA.
2020-03-2610 min
The CRA Podcast with Linda Ezuka#04: The Power of Impact Investing with Richard WooOur guest for this episode is Richard Woo, retired CEO of the Russell Family Foundation. During his tenure at the foundation, he learned first-hand the power of impact investing and shares his early explorations, community partnership and impressive ROI results. Impact investing, which seeks to generate social and/or environmental benefits while delivering a financial return, is expanding as a promising tool for both investors and philanthropists. Stakeholders in community development have much to gain from learning more about this tool to fund mission critical projects in their communities. Some estimates value the current impact investing market at...
2020-03-0428 min
The CRA Podcast with Linda Ezuka#03: Michael Delucchi with Elevate Chats About Regulatory ReformWelcome to this episode and launch of a new series of podcasts around regulatory reform. Most of you know that we are in the midst of regulatory reform and things are heating up! In today’s episode of the CRA Podcast, I switch gears and share a podcast episode I recently recorded with Michael Delucchi of ElevateTALKS. Enjoy this short interview and then check the show notes below to learn more about the innovative work of Elevate for today’s community bankers and the regulatory reform concepts shared in the episode.After nearly two years of anticipation, financial regu...
2020-02-2322 min
The CRA Podcast with Linda Ezuka#02: Mark Pinsky's CDFI Friendly Cities and More Community Development InspirationCommunity development financial institutions or otherwise known as CDFIs are powerful tools that are an important player within the continuum of credit spectrum to strategically deploy capital within disadvantaged communities. CDFIs partner with banks and other community development entities to realize the power of partnerships to realize impact. In this podcast, Mark Pinsky shares a few stories of his CDFI journey and will share his new CDFI Friendly Cities initiative and his deep thoughts about community development. Mark will share his insights on how communities gain access to valuable and financing for small business, commercial real...
2018-08-0156 min
The CRA Podcast with Linda Ezuka#01: Maurice Jones of LISC Highlights Opportunity Zones... a Freshly Minted Community Development ToolPC101 Opportunity Zones... a freshly minted new community development tool poised to incentivize private investments in low-income and distress communities across the nation.Welcome to the CRA Podcast. I’m Linda Lewis Ezuka, your host and Founder of CRA Today. This podcast is part of my mission to transform communities through the power of economic development and the Community Reinvestment Act. We are lucky enough today to have with us a very good friend of mine and a spectacular human being, Maurice Jones. Maurice Jones is the President and CEO of Local Initiatives Support Corporation (otherwise kn...
2018-06-1423 min