Topic: Community Reinvestment Act (CRA)
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Can you help us research how to set up a Community Development Corporation (CDC)?
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The Interagency CRA FAQs list community development corporations (CDCs) as one of several types of financial intermediaries to which banks can make “qualified investments” for CRA credit (with other examples including Community Development Financial Institutions (CDFIs) and New Markets Tax Credit-eligible Community Development Entities). An FDIC advisory opinion confirms that investments in community development corporations…
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When deciding on CRA investments, is there some kind of ratio that tells you how much credit the bank would get for each qualified investment?
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The CRA regulations (Regulation BB) do not specify exactly how much weight would be given to qualified investments in an institution’s CRA rating. The investment performance component of the CRA rating is just one of three components of a CRA rating (though we note that the investment component is more significant for banks examined under…
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What disclosures should we make before moving up the cut-off time for check deposits to noon on Saturdays?
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The Promissory Note and Bank Holiday Act already permits banks to close at noon on each Saturday. 205 ILCS 630/17. Also note that the cut-off hour for the receipt of deposits may be no earlier than 2:00 p.m. (or 12:00 p.m. for ATMs) under Regulation CC, but you do not have to accept deposits after…
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Do you have any information on the $78 million in federal funds received by Illinois for small business lending (under the Advantage Illinois program)?
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The Illinois Department of Commerce & Economic Opportunity’s webpage on the Advantage Illinois program should answer most of your questions. Also see the press release announcing the program, which has four components: Capital Access Program (CAP) assists businesses with various financing needs. It is designed to encourage financial institutions to make loans to small and…
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If we are reducing the business hours for one of our branches, do we need to be aware of any CRA issues?
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We are not aware of any laws that address a reduction in branch hours, and so we can only make suggestions as to reputation risk and CRA risks. The Illinois Promissory Note and Bank Holiday Act imposes duties when a bank plans to close a branch one day per week, but it is silent as…