The CRA Podcast with Linda Ezuka

The CRA Podcast with Linda Ezuka

Welcome to the CRA Podcast. I’m Linda Ezuka, your host and Founder of CRA Today and the CRA Hub. This podcast is part of my mission to transform communities through the power of economic development and the Community Reinvestment Act. For a deeper dive into community development concepts, join your CRA colleagues in the CRA Hub, a membership for bankers to connect and master the art of the CRA.


November 7, 2023 10 mins
As most of you know, the public file is a straightforward requirement of the CRA. Its purpose is to disclose basic information about your bank, its products and services, and how you serve the community. The file includes a wide variety of information, and here I discuss the technical requirements, what not to include, and recommendations around best practices.

Tips include putting together a checklist so you don’t miss any necessa...
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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 regula...
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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 h...
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October 10, 2023 12 mins
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 an...
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In case you missed it, I recently published an article in the ABA Compliance Magazine earlier this year. It was all about preparing for your CRA exam in the midst of regulatory uncertainty. We sure do have a lot of uncertainty swirling around these days. Although it’s easy to get distracted, I recommend you stay laser-focused on your CRA program and finish strong with your current exam cycle.

Your bank will likely have one more exam...
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I recently walked a CRA officer through a potential loan transaction in partnership with a community development corporation, otherwise known as a CDC. As a CRA professional, you may be approached by CDCs directly, or CDCs might approach your lenders first. Either way, these mission based organizations are great partners in community development.

It is estimated that there are 4,500 CDCs nationwide, and there’s likely one or several...
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Sarah Hope Marshall joins me here to reflect upon digital inequity in place-based community revitalization. Our discussion focuses on digital inequity and how community development professionals can revisit this as they revisit their community development programs. Here are some key quotes from our conversation:

“It made me pause and ask, wait a minute. This neighborhood that we’re in has a really rich history of community organizin...
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Your previous CRA exam may not have included pandemic activities, but your next one is likely to include activity around the SBA’s Paycheck Protection Program, or PPP. You can get credit for participating in the PPP under your CRA program, which translates into CRA lending performance. Your next exam would highlight your participation in the program, and you would also account for the individual loans that were deployed under the p...
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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 guara...
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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 ...
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Naturally 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 commercia...
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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...
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I 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 v...
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As referenced in the episode, you may want to download our free 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....
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Regulators 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 communi...
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It’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...
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We’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 ...
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This 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 publis...
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NCRC 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 ...
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October 4, 2022 25 mins
This 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 ...
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