| Wednesday, October 2, 2013

CDBANewsflash - Low Rez For Email 2

October 1, 2013

Member News

More Small Businesses Could Bid for MTA Contracts Thanks to Carver Federal Savings Bank Loans
Westfair Communications

Empire State Development Corp., a New York State economic development agency, has partnered with the Metropolitan Transportation Authority (MTA) and Manhattan-based Carver Federal Savings Bank to make it easier for small businesses to bid on construction projects with the MTA. The state’s aim is to increase the availability of funds for the MTA’s high-capital projects through its Small Business Mentoring Program, which provides businesses with mentoring, training, surety bonding services and access to loan capital. The maximum amount of loans Carver Federal Savings Bank will provide has increased to $900,000, up from $150,000. This increase in the amount of lending through the bank is intended to help small businesses grow, create jobs, provide more competitive prices for MTA construction contracts, and save the state money, MTA CEO Thomas F. Prendergast said. 

City First Foundation Presents Finance Summit
City First Foundation

The City First Family of Companies will be holding its inaugural finance summit, "The Resurgence of Neighborhoods: Fueling D.C.'s Economic Growth" on November 7, 2013 at the Omni Shoreham Hotel in Washington. The summit will focus on how small businesses, new housing options, increased transportation options and innovative financing are changing neighborhood dynamics, contributing to Washington's population growth and building the city's economic vitality. Speakers will discuss how the success of Washington's highly desirable neighborhoods can be replicated in underserved neighborhoods while avoiding gentrification that jeopardizes equity and cultural diversification. Attendees are encouraged to register here.

Of Interest

In Banking, Should There Be a ‘Public Option’?
New York Times

In an New York Times editorial debate, banking industry experts put forward their views on the potential value of state-run banks. Only one U.S. state, North Dakota, currently owns a bank. But that bank has been so successful – and the financial systems elsewhere have been so problematic – that 22 other legislatures have considered starting similar state banks. Debaters were posed the following questions: would government-owned banks distort the free market, or complement private lending? If states or the federal government set up banks, should they lend directly to consumers and businesses? "By providing inexpensive, accessible financing to the free enterprise sector of the economy, public banks make commerce more vital and stable," writes Ellen Brown, president of the Public Banking Institute. But Hester Peirce of George Mason University's Mercatus Center recommends caution: "imagine the anti-government sentiment that would be stirred up by a wave of foreclosures by the state bank, widespread write-downs on taxpayer-financed mortgages, or the revelation of sweetheart loans made by state banks to powerful politicians’ cronies. Free markets offer healthy discipline for borrower and lender alike." 

Tribes Lose Battle to Shield Payday Sites From New York State Crackdown
New York Times

A federal judge has denied a request by two American Indian tribes to stop New York State’s top financial regulator from cracking down on their online payday lending businesses. The two plaintiffs in the case are the Otoe Missouria Tribe, in Red Rock, Okla., and the Lac Vieux Desert Band of Lake Superior Chippewa Indians, in Watersmeet, Mich. The tribes had argued that Benjamin M. Lawsky, superintendent of the state’s Department of Financial Services, overstepped his jurisdictional bounds in trying to regulate business activity taking place on Indian reservations in Oklahoma and Michigan. The Federal District Court in Manhattan issued a ruling dismissing the Indians’ claims. According to the decision, when tribal businesses use the Internet to reach consumers beyond their reservations’ borders, they lose their federally protected rights as sovereign nations. Attorney David Bernick, who is representing the tribes, suggested he would seek to appeal the case. This is the second recent decision that has gone against the Indian tribes. Last week, the Consumer Financial Protection Bureau rebuffed a bid by three Indian online lenders to halt the federal agency from investigating whether their business practices violated federal laws.

Business and the Shutdown: Banks Prepare for Tricky Times
Wall Street Journal

The government shutdown could create headaches for some lenders and borrowers. Issues might arise when agencies such as the Small Business Administration, Federal Housing Administration and Department of Veterans Affairs are involved, or in requests of tax transcripts from the IRS. Customers could also experience delays in loan approvals which require employment verification, as for government employees. For big banks that handle and process many payments, this could mean major challenges. The government-operated food stamp program distributes payments through debit cards loaded up by big banks. Bank executives will need to decide whether to trust that the government will continue to make payments for such cards – and thus whether to keep loading them up with funds and sending them out. Similar questions may be asked of government-guaranteed loans to small businesses. The shutdown may result in processing delays and uncertainty across the banking sector. 

Staying Alive: Weak Banks Hang On
Wall Street Journal

Bank-failure data show that weak banks are hanging around much longer than they have in the past. The risk, some banking-industry observers say, is that regulators' go-slow approach can prompt bank management to take extreme risks to survive and can lead to bigger price tags for the government if they ultimately fail. 13 of the 22 banks that failed in 2013, or 59%, were deemed "significantly undercapitalized" for at least a year before they failed. That compares with just 20% of the bank failures in 2012. The Treasury Department's Inspector General's Office, which examines bank failures, has criticized banking regulators for their inaction. Of 56 failed-bank reviews from 2008 through 2012, 48 have been critical of regulators, saying they often didn't take strong, quick action to address risky practices that helped lead to the banks' failures. A 2011 Government Accountability Office report said that although regulators identified failing banks' problems early and could have addressed them sooner, "they did not consistently do so." 

Treasury's Lapse in Appropriations Contingency Plan
U.S. Department of the Treasury

The U.S. Treasury department describes its shutdown contingency plan. Operations of the following bureaus are funded from sources other than annual Congressional appropriations and would operate normally if a government shutdown were to occur: the Office of the Comptroller of the Currency, the United States Mint, and the Bureau of Engraving and Printing. Additionally, Public Debt functions of the Fiscal Service are authorized to continue in the absence of annual appropriations by the Second Liberty Loan Act. Specific programs within DO and certain bureaus that are funded from other than annual appropriations are addressed within the individual plans. The CDFI plan will use available prior year balances during a short lapse of appropriations. In the event of a longer-term lapse the CDFI plan would re-evaluate based upon a range of factors, including availability of funds. 

From the Margins to the Mainstream: Assessment of the Impact Investment Sector and Opportunities to Engage Mainstream Investors
World Economic Forum Investors Industries

An Economic Forum Investors Industries report provides an assessment of the impact investment sector and identifies the factors constraining the acceleration of capital into the field. The authors of the report expect that as enterprises and deal sizes grow, track records develop and perceptions about financial performance are realized, impact investing will become an increasingly attractive option to investors. Among the report's industry recommendation are creating transparent tools to measure social impact, attracting investors with more flexible investment mechanisms, cooperating with philanthropists and foundations and collaborating across the industry to aggregate impact data and connect capital to deals. The report is the product of interviews, workshops and conference calls with 150 mainstream investors, business executives, philanthropic leaders and policy-makers.


Community Action, Inc. Seeks Deputy Director (Beloit, Wis.)
The Deputy Director will provide strategic leadership to support the agency's objective of providing strong, effective and culturally relevant services that meet the needs of our local communities. This position will ensure programs are managed effectively, contract and funder requirements are adhered to and that programs are managed efficiently in accordance with strong fiscal standards and approved budgets. The individual will be a core member of the agency leadership team, responsible for integrating strategic objectives within program operations. This position is responsible to the Executive Director.

The CDBA Newsflash is a service of the Community Development Bankers Association (CDBA). For more information about other members and the work of CDBA please visit Or write to us at: 1444 I Street NW, Suite 201, Washington D.C., 20005 or

| Friday, September 27, 2013

CDBA member Carver Bancorp, Inc., the holding company for Carver Federal Savings Bank, announced that Lewis Jones III, Kenneth Knuckles and Colvin Grannum have been appointed to the Company's Board of Directors. Lewis Jones III is managing principal and co-founder of 5 Stone Green Capital. Kenneth Knuckles is the president and chief executive officer of the Upper Manhattan Empowerment Zone Development Corporation. Colvin Grannum is president of the Bedford Stuyvesant Restoration Corporation. "Carver is pleased to announce the appointment of three exceptional business leaders to the Board as we work to ensure that Carver remains a strong and trusted resource in the urban communities that we serve," said Robert Holland, Lead Independent Director of Carver. "Their collective experience will be of tremendous value to our Board and management team as we work in concert to guide the Company on the execution of its business strategy going forward."

| Wednesday, September 25, 2013

CDBANewsflash - Low Rez For Email 2

September 25, 2013


Member News

CDFI Fund Announces Awards to CDBA Members

Eight CDBA Members received $9.526 of a total of $12.3 million in awards to CDFI banks in the FY 2013 funding round of the CDFI Program. $172 million in awards were distributed in total by the CDFI Fund. Six of the CDBA members were awarded the maximum amount of $1,347,000. Congratulations to the following CDBA members who have received CDFI Core Awards: Central Bancshares of Kansas City – $597,000; CityFirst Enterprises – $847,000; First Eagle Bancshares – $1,347,000; Guaranty Capital Corporation – $1,347,000; Greater Chicago Financial Corp – $1,347,000; OnePacific Coast Bancorp – $1,347,000; Southern Bancorp Bank – $1,347,000 and Virginia Community Capital – $1,347,000. 

City First Foundation Presents Finance Summit
City First Foundation

The City First Family of Companies will be holding its inaugural finance summit, "The Resurgence of Neighborhoods: Fueling D.C.'s Economic Growth" on November 7, 2013 at the Omni Shoreham Hotel in Washington. The summit will focus on how small businesses, new housing options, increased transportation options and innovative financing are changing neighborhood dynamics, contributing to Washington's population growth and building the city's economic vitality. Speakers will discuss how the success of Washington's highly desirable neighborhoods can be replicated in underserved neighborhoods while avoiding gentrification that jeopardizes equity and cultural diversification. Attendees are encouraged to register here.

BankPlus and Journal Partners for Education
Madison County Journal

BankPlus and the Madison County Journal have partnered with the "Student 360" initiative, which highlights scholastic achievement in Madison County, Miss. The program features high school seniors from over a dozen area public and private schools. Each week for 13 weeks, the Madison County Journal will highlight a high school senior with a profile. In May, two of the students will win a cash scholarship from BankPlus. "BankPlus is committed to being a part of the communities in which we serve. We especially place a strong emphasis on education and supporting our local schools," said Donna Sims, President of BankPlus for Madison County.


Of Interest

Treasury Awards Over $172 Million to Organizations Serving Low-Income Communities

The CDFI Fund awarded 191 organizations Financial Assistance and Technical Assistance awards totaling over $172 million. This amount includes 10 awards totaling more than $22 million through the Healthy Food Financing Initiative. Credit unions, depository institutions, loan funds and venture capital funds collectively received $150,289,499 in Financial Assistance and Technical Assistance awards. Ten CDFIs received $22.3 million in funding under the Healthy Food Financing initiative. The CDFI Fund also announced more than $12.4 million in awards from the Native American CDFI Assistance Program (NACA Program). "The fiscal year 2013 round of the CDFI Program provides more awards than any other round in the CDFI Fund’s history. By expanding the reach and impact of this program to more organizations, the CDFI Fund is supporting more economic development efforts than ever before to bring new life to struggling communities,” said CDFI Fund Director Donna J. Gambrell. 

Mortgage Data Rule Changes to Lighten Banks' Burden: CFPB's Cordray
American Banker

Banks can expect changes to federal reporting requirements for mortgage data, according to Consumer Financial Protection Bureau Director Richard Cordray. Cordray offered little detail on how institutions will report Home Mortgage Disclosure Act data differently than they do now, but said that one of the motivations for the changes will be to simplify the process for banks. Cordray also signaled that the bureau plans to release details on how banks' fair-lending requirements are included in the definition of "Qualified Mortgages." The QM rule, which is due to take effect in January, will create a special class of safe loans that will be deemed in compliance with CFPB criteria for evaluating a borrower's ability to repay. Cordray said the Bureau sought to combat the "four D's" threatening consumers: "discrimination," "deception," "debt traps" and the "dead ends" consumers face in trying to counter bad industry actors. Cordray's speech identified several practices that negatively affect borrowers, including discriminatory lending, bullying tactics by debt collectors, misleading customers about crucial loan information and predatory payday lending.

Some Smaller Banks Still Owe TARP Money
Wall Street Journal

Five years after the Troubled Asset Relief Program began, 113 small to midsize banks in the Capital Purchase Program(CPP) portfolio still owe the Treasury Department about $2.7 billion. The banks pose a challenge for the Treasury, which is eager to get rid of its financial stakes but is finding many of the banks too weak to forgo government capital. Repaying is about to get harder, as quarterly dividend payments owed are set to nearly double to 9%. Seventy-nine of the remaining banks are behind on dividend or interest payments, owing about $217 million to the government, according to the Treasury. Of those, 63 have missed 10 or more payments. "There are some institutions that we don't think can repay," said Timothy Massad, the Treasury Department's assistant secretary for financial stability. The department usually moves to sell those assets because, he said, "we don't want a financial system that is owned by the government." The Treasury has reaped a small profit on the program so far: Of the $204.9 billion that Treasury invested in banks, it had recouped $195.1 billion in principal and an additional $12 billion in interest and dividends as of last week. About $2.75 billion is still outstanding.

Lawmakers Likely to Pursue Piecemeal Approach to Regulatory Relief
American Banker

It is unlikely Congress will take up a comprehensive bill addressing legislative changes desired by community bankers anytime soon, according to several regulatory specialists. "We may be in an atmosphere now where we simply have to deal with legislation piece-by-piece, one bill at a time, as opposed to a large bill," said James Ballentine, chief lobbyist for the American Bankers Association. Ballentine said the association and others in the industry should continue to push for piecemeal reforms on a host of issues, including a delay of the Consumer Financial Protection Bureau's ability-to-pay rule, changes to the bank examinations process and repeal of an annual privacy notice requirement, in the hopes of grabbing lawmakers' attention. Panelists also underscored that, while some issues do need to be addressed by Congress, others remain in the hands of regulators.

Forget too big to fail: Some Banks Now too Small to Succeed
Los Angeles Times

Community bankers are finding it increasingly tough to survive, in part because they must commit more of their limited resources to complying with new regulations stemming from the financial crisis. That has increased pressures on the owners and directors of small banks to sell out to their larger brethren. At the end of 2007, the government insured 8,534 commercial banks and savings institutions — down 52% from 1984. The current count is 6,926, down 19% since the crisis began. Of the 1,608 banks that have disappeared since the financial crisis, nearly a third were shut down by regulators. The rest were attributed to consolidation. Most of the community banks that failed had overdosed on loans to land developers and home builders during the housing boom. A Federal Reserve Bank of San Francisco analysis of return on assets highlighted the disparity between small and large banks, finding that banks with less than $1 billion in assets reported an average return of 0.7% in the second quarter this year, compared with 1.1% for banks with $1 billion or more.



Accion East Seeks Controller (New York, N.Y.)
The Controller is responsible for managing Accion East's yearly financial performance, in line with budgeted expectations including cash management and access to lending capital. The Controller will also assist in improving customer satisfaction by ensuring timely and courteous fulfillment of loan-related transactions, inquiries and processing for new and existing clients. The Controller reports to the CEO and the manages accounting department and service center.
Cities for Financial Empowerment Fund Seeks Program Manager(New York, N.Y.)
The Program Manager is responsible for managing the Access to Banking portfolio, focusing mainly on Cities for Financial Empowerment Fund's Bank On 2.0 project. Bank On 2.0 is a national, centralized approach to helping low-income families access safe and affordable banking products and services. The CFE Fund plans to build on the success of a broad range of existing programs in cities across the country that integrate large-scale safe banking opportunities through networks of city-provided social services. The Program Manager will report to the Chief Program Officer.


| Tuesday, September 24, 2013

Community Development Bankers Association Press Release

WASHINGTON (September 24, 2013) – Eight CDBA Members received $9.526 million of a total of $12.3 million in awards to CDFI banks in the FY 2013 funding round of the CDFI Program. $172 million in awards were distributed in total by the CDFI Fund. Six of the eight CDBA members were awarded the maximum amount of $1,347,000.

The following CDBA members have received CDFI Core (Financial Assistance) Awards:

•Central Bancshares of Kansas City (Central Bank of Kansas City) (Kansas City, Mo.) – Core $597,000 
•CityFirst Enterprises (City First Bank of DC) (Washington, D.C.) – Core $847,000
•First Eagle Bancshares (First Eagle Bank) (Hanover Park, Ill.) – Core $1,347,000 
•Guaranty Capital Corporation (Guaranty Bank) (Belzoni, Miss.) – Core $1,347,000
•Greater Chicago Financial Corp (ABC Bank) (Chicago, Ill.) – Core $1,347,000
•OnePacific Coast Bancorp (OnePacific Bank) (Oakland, Calif.) – Core $1,347,000
•Southern Bancorp Bank (Arkadelphia, Ark.) – Core $1,347,000
•Virginia Community Capital (Virginia Community Capital Bank) (Christiansburg, Va.) – Core $1,347,000

The following non-CDBA CDFI banks and holding companies also received CDFI Fund Core and SECA Awards totaling $2.794 million: 

•Carver Financial Corporation (Carver State Bank) (Savannah, Ga.) – SECA $600,000
•Liberty Financial Services Corporation (New Orleans, La.) – Core $1,347,000
•PGB Holdings (Global Pacific Bank) (Chicago, Ill.) - Core $847,000

The CDFI Fund made 191 awards totaling more than $150 million to organizations in 37 states and the District of Columbia. The Fund received applications from 400 organizations, of which 389 were deemed eligible to advance to the review process. The Fund reported that 148 FA and 43 TA awards were made to 143 loan funds, 35 credit unions, 11 depository institutions/holding companies and 2 venture capital funds.

The 11 bank depository institutions/ holding companies received awards totaling $12.32 million (8.2% of the total awards). This is the largest number of bank depository institutions/holding companies to receive awards in recent years.  

| Wednesday, September 18, 2013

CDBANewsflash - Low Rez For Email 2

September 18, 2013

Member News

City First Foundation Presents Finance Summit
City First Foundation

The City First Family of Companies will be holding its inaugural finance summit, “The Resurgence of Neighborhoods: Fueling D.C.’s Economic Growth” on November 7, 2013 at the Omni Shoreham Hotel in Washington. The summit will focus on how small businesses, new housing options, increased transportation options and innovative financing are changing neighborhood dynamics, contributing to Washington's population growth and building the city's economic vitality. Speakers will discuss the success of Washington's highly desirable neighborhoods can be replicated in underserved neighborhoods while avoiding gentrification that jeopardizes equity and cultural diversification. Attendees are encouraged to register here.

Congressional Black Caucus Foundation Invests $5 Million in Black-Owned Banks
Washington Post

The Congressional Black Caucus Foundation, hosting its annual conference in Washington this week, announced a $5 million investment in five African American-owned banks to spur lending in communities of color. The donations are part of a broader effort to support small businesses and encourage private investment in minority banks. “Minority banks are an important source of accessible financial services and are key to reaching financially under-served communities,” said the foundation's Chief Executive Shaunise Washington. The Congressional Black Caucus Foundation selected five black-owned, fiscally sound banks scattered across the country: Industrial Bank in the District, Liberty Bank & Trust Co. in New Orleans, Mechanics & Farmers Bank in Durham, N.C., Seaway Bank & Trust Co. in Chicago and City National Bank of New Jersey in Newark. Each institution will receive $1 million through certificates of deposits guaranteed by the Federal Deposit Insurance Corp.

Greater Washington's 10 most and least profitable banks in Q2
Washington Business Journal

The Washington Business Journal ranked the D.C. area's top 10 most profitable local banks of Q2 2013. CDBA member City First Bank of D.C. ranked second, up 7 slots from last quarter. City First reported a net income of $1.2 million, up 175% from the first quarter. Their return on assets was 2.25%. City First Bank of DC provides financial and other services in low-to-moderate income communities in Washington. Washington area banks posted a median net income of $862,000 in the quarter, up 19 percent from a year earlier and up 8 percent from the first quarter.

New Regional Bank Aims to Grow Appalachian Economy

The Appalachian Regional Commission has announced the formation Appalachian Community Capital, a loan fund intended to attract capital to underdeveloped regions of Appalachia. Jane Henderson, Chairperson of CDBA as well as CEO and President of Community Capital Bank of Virginia, is a member of the new loan fund's Organizing Committee. At the Clinton Global Initiative conference in Chicago, Appalachian Community Capital was held as a model for other underdeveloped regions. At the conference, The Appalachian Regional Commission said it will invest $3.4 million to get the loan fund off the ground. It's firming up commitments for another $39 million from philanthropic foundations, public investors and large commercial banks. Over the next 24 months, the Appalachian Regional Commission plans to leverage $233 million in private capital to create a projected 2,200 jobs in the 13 states the commission serves.

Of Interest

When Fed Trims Bond Purchases, How Remains Undecided
Wall Street Journal

Federal Reserve officials face a tough call on whether to pull back on an $85 billion bond-buying program. Though the jobless rate has fallen since the Fed launched the program last year, inflation is below its objectives and economic growth is weak. If they do decide to start winding down the program, they face a second tough call on whether to reduce their purchases of Treasurys, mortgage-backed securities or both. The Fed is currently buying $45 billion per month of Treasurys and $40 billion per month of mortgage bonds. One line of thinking is that the Fed should pull back on Treasury purchases first, because mortgage bond purchases do more to boost the economy and thus should be left in place longer. The second line of thinking is that the Fed should keep its exit from its bond buying programs simple, reducing its purchases of Treasurys and mortgage-backed securities proportionately in order to avoid market confusion. A third line of argument at the Fed argues that none of these programs work very well and the Fed should end them all as soon as possible.
Credit Union Times
The CDFI Fund has recognized 13 Missouri credit unions as CDFIs. The unusual mass recognition came of the Community Development Across Missouri initiative, led by the consultancy CU Strategic Planning and supported by the Missouri Credit Union League. “Our company’s analysis of credit unions in Missouri revealed that 100 of the state’s 134 credit unions meet the Treasury’s eligibility requirements. There are two more CDFI certifications pending in Missouri this year, and another 10 that will be submitted for approval in 2014," said Jamie Chase, CU Strategic Planning founder.
More mortgage originators could change hands in coming months as pressure mounts on small banks and servicers to deploy excess capital and pad revenue. More than a dozen mortgage lenders have sold this year. Charles Welch, a managing director at Deloitte Corporate Finance, said this type of M&A activity is expected to increase in 2014. "It is better today to sell as a mortgage company than it was a year ago, and it should be even better next year," Welch said. A number of small banks have capital in hand and credit under control but are struggling to book loans. Bankers continue to lament the midsummer increase in long-term interest rates, which simultaneously curbed refinancing and demand for new mortgages. That shift could motivate banks to buy an originator, particularly those with an established track record courting new home buyers, said Welch.
Payday Lending Abuses and Predatory Practices
The Center for Responsible Lending
A report by the Center for Responsible Lending describes the situation faced by payday loan borrowers. According to the report, 37% of payday borrowers experience default in the first year of borrowing and 44% experience default within the first two years. Despite the high risk of default, borrowers often re-borrow shortly after repaying their previous loan, the size and frequency of the loans increasing over time. Half of repeat payday loans were opened at the borrower’s first opportunity, 87% within two weeks and 94% within one month of the previous loan. Overall, the report states, borrowers were indebted an average of 212 days of the first year in which they had taken out a payday loan and continued to be indebted for over half of the second year. The report notes that "best practice" legislation often fails to prevent the industry's problems; in states with such legislation, about half of repeat loans were opened at the borrower’s first opportunity and nearly 90% were made in the same pay period the previous loan was paid off. The authors recommend stronger federal regulation of the industry, including a 36% APR limit and imposing more stringent ability to repay requirements on lenders.
The Federal Reserve Bank of Boston
A study by Dmytro Holod of the College of Business at SUNY -- Stony Brook and Joe Peek of the Federal Reserve Bank of Boston quantifies the value of small business lending. The study compares the book and market values of banks' small business loan portfolios to identify how maintaining relationships with borrowers affects the market value of banking organizations. The study finds that for commercial and industrial loans, relationship-based lending to small businesses does add value to banking organizations both overall and relative to large commercial and industrial loans. This effect was strongest among small and mid-sized banking organizations. The study also finds that the loan amount matters. The smallest category of loans, with original amounts of $100,000 or less, saw the greatest change in value. The study finds, however, that small loans which are not relationship-focused, such as many commercial real estate loans, did not benefit from the same added-value as commercial and industrial loans.


FDIC Seeks Community Affairs Specialist (Lexington, Ky.; Livonia, Mich.)
The Community Affairs Specialist communicates with community-based organizations, academic researchers, government officials, lenders and regulatory agencies to report on credit issues and the effectiveness of reinvestment policies. This specialist will assist in coordinating meetings to address specific community reinvestment issues, prepare community profiles and represent the FDIC as a speaker or participant at events. The Community Affairs Specialist will also assist in designing and conducting Community Reinvestment Act and community development training and develop educational materials related to community reinvestment issues. This position will provide written and verbal commentary to the Community Affairs Officer and senior management.  

| Thursday, May 2, 2013

CDBANewsflash - Low Rez For Email 2

May 2, 2013


Member News

Two Kansas City Entities Receive New Markets Tax Credits Allocations
Kansas City Business Journal

The U.S. Treasury Department is sending $90 million in federal tax credits to Kansas City community development entities, the department announced last Wednesday. Central Bank of Kansas City and the Kansas City, Missouri, Community Development CDE each will get $45 million in New Markets Tax Credits from the Treasury’s Community Development Financial Institutions Fund. Department spokesman Matt Bevens said the tax credits can be used only for projects designed to help develop impoverished areas as defined by U.S. Census Bureau data. Groups trade the tax credits for investments in projects. The Treasury is sending $225 million to five community development entities throughout Missouri, three of which are in St. Louis. Nationally, $3.5 billion in credits will be distributed as part of the 2012 allocation, Bevens said.

One PacificCoast Bank Featured on RainMakers Television
RainMakers Television

RAINMAKERS, an original documentary television series, showcases both the heroic efforts made by impoverished people around the world who every day strive to lift themselves out of dire circumstances, and those philanthropic individuals and organizations that reach out and provide strategic support. Focused not on aid -- but on comprehensive strategies that have sustainable outcomes, such as education, health, rule of law, engaging governments, empowering women and girls, clean water resources, and micro-credit -- RAINMAKERS tells stories that inspire global transformation. This RAINMAKERS video features One PacificCoast Bank CEO Kat Taylor discussing whether "triple bottom-line banking" is and should be the new standard for banking.

Broadway Financial Replaces CFO
American Banker

Broadway Financial in Los Angeles has named a new chief financial officer. Brenda Battey has been approved by the Federal Reserve Bank of San Francisco to be CFO of the company. It also plans to name her CFO of its Broadway Federal Bank subsidiary, pending approval by the Office of the Comptroller of the Currency, President and Chief Executive Wayne-Kent Bradshaw said. Battey succeeds Sam Sarpong, who was terminated on Jan. 31, the company disclosed in February. Broadway was forced to restate its earnings last year after the OCC ordered it to increase its loan losses. Both Broadway and its bank have been under regulatory orders since 2010. It made a profit of $588,000 in 2012, after losing over $14 million in 2011.

Mission Valley CEO Named President of Indie Bankers Group

Tamara Gurney, President and CEO of Mission Valley Bank, has been selected as the California Independent Bankers’ 2013 incoming president. “With more than 33 years in banking, Tamara is a natural leader whose great wealth of experience in community banking will be a valuable asset in leading our association as president,” said CIB Executive Director David Haithcock. “Tamara has a deep understanding of community banking issues and is the right fit to support our causes at the forefront.” Gurney believes in the importance of developing strong affiliations within the community and with clients. Her dedication and philosophy were contributing factors by the CIB Board of Directors when selecting Gurney as the 2013 incoming president. The California Independent Bankers, an affiliate of the Independent Community Bankers of America (ICBA), has approximately 7,000 members statewide and represents more than 240 community banks of various sizes and charter types within the state. It is dedicated exclusively to representing the interests of the community banking industry and its membership through effective advocacy, superior education, and high-quality products and services.

12 Companies Considered "Best for the World"

Founded by two former basketball apparel entrepreneurs and the former manager of Michael Dell’s private investments, B Lab is a seven-year-old non-profit based in Berwyn, Pa. that invented the concept of a “Benefit Corporation,” a company that turns a profit while benefiting its workers, its community, and the Earth. B Lab puts applicant companies through a rigorous vetting process, where it uses a 200-point system to measure companies’ performance in five areas: accountability, employee impact, consumer, and community. In the world of scoring companies that focus on the so-called triple bottom line, meaning people, planet and profit, B Lab has one of the most rigorous rating systems. Using its point system, B Lab has come up with a list of 67 out of its 730 certified companies which score in the top 10% of its point system. Recently it announced that list and dubbed those companies “Best for the World.” Among B Corps with more than 50 employees, a dozen are in the U.S. Ranked by the number of points scored, CDBA members Sunrise Banks (St. Paul, MN) and One PacificCoast Bank (Oakland, CA) were numbers #3 and #4 on the list, respectively.


Of Interest

Brown-Vitter Rearranges Financial Reform Battlefield

Bloomberg - View

A year ago, the big U.S. banks were focused on repealing, or at least eliminating large parts of, the Dodd-Frank financial-reform law. Recently, this lobby let it be known that the line from big banks and their allies had shifted and that their new refrain is “let’s implement Dodd-Frank.” This Bloomberg opinion piece argues that the reality remains the same -- a very powerful lobby is working flat out to ensure that the industry keeps its dangerous, nontransparent and unfair subsidies. Yet, the article argues that the winds are shifting against the megabanks for three main reasons. First, the Brown-Vitter legislation, which was introduced April 24, changes everything. Now, Senator Brown has a Republican co-sponsor, and they have converged on a strong message. Vitter, who is on the right of the political spectrum, articulates well the case for ending the implicit subsidies that exist because creditors understand that the government and the Federal Reserve won’t allow a megabank to fail. This broad and sensible message resonates across the political spectrum. Second, small banks are increasingly focused on the ways megabanks have achieved an unfair competitive advantage -- primarily through implicit government subsidies. Third, what Brown, Vitter and Fine express isn’t populist anger, but rather a thought-out plan for making the financial system safer.

Treasury Announces $3.5 Billion in New Markets Tax Credit Awards

U.S. Department of the Treasury

Building on the Obama Administration’s commitment to increase economic opportunity in distressed areas of the United States, the U.S. Department of the Treasury’s Community Development Financial Institutions Fund (CDFI Fund) announced $3.5 billion in New Markets Tax Credit (NMTC) awards nationwide. Treasury will provide 85 organizations with tax credit allocation authority under the tenth award round of the NMTC Program. “The New Markets Tax Credit addresses one of the most significant obstacles to economic development that low-income communities face: a lack of access to patient, private investment capital,” said Treasury Assistant Secretary for Financial Institutions Cyrus Amir-Mokri. “The $31 billion worth of tax credits awarded in past years have gone toward preserving hundreds of thousands of jobs and bringing community facilities and new businesses into neighborhoods that desperately needed them. I expect today’s awardees will continue that trend.”

The S.B.A. Wants to Encourage More Small Loans

The New York Times - Small Business Blog

For the last several years, the Small Business Administration has attempted to expand its loan-guarantee programs by making them available to bigger businesses. But with the 2014 budget that the White House sent to Congress last week, the Obama administration is trying to solve a problem at the other end of the spectrum: how to induce banks to make smaller loans, to smaller businesses. S.B.A.-guaranteed general business, or 7(a), loans for $150,000 or less have fallen from $3.5 billion in 2007, and about 24 percent of all such loans guaranteed by the agency, to $1.4 billion in 2009. Of course, 2009 was the pit of the recession, and S.B.A.-backed lending — if not all lending — had dropped to its lowest level in recent memory. But while the agency’s loan programs have since fully recovered, the total lent in these small loans has remained flat, and constituted just 9 percent of the 7(a) program, the S.B.A.’s biggest, in 2012. The new budget for the S.B.A. would waive the agency’s fees for guaranteeing loans of less than $150,000, and this follows recent efforts to streamline one program to encourage more small loans. But some observers in the S.B.A.-lending industry doubt these moves will be sufficient.



Center for Financial Services Innovation - Manager, Advisory Services and Nonprofit Investments (Chicago, IL)
The Center for Financial Services Innovation (CFSI) is currently hiring an experienced and versatile Manager, Advisory Services, to deepen relationships with nonprofit organizations, particularly those working to improve the financial health of low- and moderate-income individuals and families. The Manager will deliver technical assistance and consulting services to leading nonprofits serious about increasing their impact by incorporating financial products and services into their programmatic offerings. The Manager will assist nonprofits in assessing the financial needs of their clients, developing new strategies involving financial products to meet those needs, vetting product offerings, negotiating with financial service providers, and effectively implementing solutions. CFSI is looking for someone who understands how to build bridges and broker strategic and sustainable partnerships between the for-profit financial services sector and nonprofits and who can facilitate innovative thinking about new strategies to improve access to high-quality financial products and to build the financial capability of underserved consumers.

Capital One - Senior Manager, CRA Compliance (McLean, VA)
As a Community Development (CD) Project Manager you are responsible for the full range of activities related to qualifying and documenting Community Development (CD) Lending, Investment, and Service data. Other duties could include participating in the development of the performance context and self-evaluation reports. You manage the collection and qualification of all CD activities, promptly identify weaknesses in CRA performance and/or processes, bring to the manager’s attention, and actively engage in the creation of CRA procedures and process improvements. You act as a consultant to lines of business by providing training and advisory services which address CRA performance and other matters. In addition, you assist in gathering data and preparing for CRA examinations/audits, quarterly performance reports and annual CRA self-assessments. With a mission to always be exam-ready, you ensure data and reports are current at all times.

Leviticus 25:23 Alternative Fund - Executive Director (Elmsford, NY)
The Executive Director is the chief staff member and the Fund’s primary liaison to borrowers, investors, private and public funding sources, financial institutions, community organizations, and the media. S/he insures that the mission is clearly stated and understood by the staff and the Board; that all programs and policies are in concert with the organization’s mission; and the mission is updated, as conditions change. The Executive Director is ultimately responsible for management and program operations, hires and supervises staff, interfaces with staff in specific program areas, manages the Board and its committees, and supervises consultants, when necessary.

Partners for the Common Good - Multiple positions (Washington, DC)
Loan Fund Administrator: PCG is seeking a Loan Fund Administrator. This position is an excellent opportunity to learn community development lending. The Loan Fund Administrator reports to the Director of Lending. The position is responsible for managing loan servicing and portfolio administration and also assists the Director of Lending in other responsibilities related to originating and closing new loans and managing the existing loan portfolio.

Public Policy and Communications Associate: PCG seeks a creative and dynamic candidate for the position of Public Policy and Communications Associate. The Associate will support our public policy agenda and online communications strategies. This position reports to the Chief Executive Officer, but works with all members of the PCG team. This is a full time 40 hour per week position. The position is located at PCG's offices in Washington, DC.

| Thursday, April 18, 2013

CDBANewsflash - Low Rez For Email 2

April 18, 2013


Member News

Canton Housing Authority Announces the Start of Rehab Project

In the coming months, the Canton Housing Authority will provide critical home repairs for 45 very low- to low-income homeowners in Canton, Mississippi. This initiative is funded by the Housing Authority, the Federal Home Loan Bank of Dallas, and CDBA member BankPlus. FHLB Dallas and BankPlus awarded the housing authority a $495,000 Affordable Housing Program (AHP) grant in 2012 to help fund the project. "I'm excited to work with the Canton Housing Authority to assist eligible households in Canton with needed home repairs," said BankPlus First Vice President and Director of Affordable Housing Mark Ouellette. "This is something we've discussed over the years and upon presenting the grant application in 2012, the Federal Home Loan Bank of Dallas decided to fully fund the request. I believe this collaboration will have a tremendous impact on many deserving families."

De Novo Banks Need a Niche
American Banker

Eighteen investors—many of them Amish—are planting the seeds for a new community bank outside Lancaster, PA. If the investors can convince regulators that the new institution will thrive, Bank of Bird-in-Hand would become the first de novo in the United States in more than two years. Though many are watching its progress with regulators closely, the hopeful startup is unlikely to see much company, at least over the next year, according to lawyers, consultants, and investment bankers. The regulatory and economic factors that froze de novo activity for the last few years remain in force. In addition, changes in technology and customer behavior could conspire to make the traditional startup a thing of the past—or at least a lot more difficult. Many attorneys and consultants feel the FDIC has been discouraging the formation of new banks since late 2008, preferring that investors plow money into existing institutions that need capital to survive. In 2009, the agency tightened oversight of startups, which have been rare in the years since. The country's last new bank, the $39 million-asset Start Community Bank in New Haven, CT, opened in the fourth quarter of 2010.

Of Interest

Community Development Investment Review - Pay For Success Financing

The Federal Reserve Bank of San Francisco

This newest issue of the Community Development Investment Review, published by the Federal Reserve Bank of San Francisco, provides 2 types of resources for those interested in Pay For Success models: First, it seeks to serve as a comprehensive resource for the most current thinking on the origins, models, and potential implications of Pay for Success. The second is to encourage readers to weigh its exciting potential against its possible pitfalls. Pay for Success is a tantalizing idea, but it raises important questions. Are we privatizing important government services that should remain under public control? How can we accurately measure and enforce “success”? Can we guard against fraud? Can we effectively balance our often-conflicting goals of equity, efficiency, and efficacy? Understanding and answering these, and other, questions is a crucial first step before widespread adoption of Pay for Success tools.

Financial Regulators Find "To Big to Fail" Too Hard to Define


Members of a House Financial Services subcommittee sparred with federal regulators Tuesday as the lawmakers sought to define which financial institutions may be considered “too big to fail” and whether the Dodd-Frank financial law adequately addressed the issue. Under Dodd-Frank, the Federal Reserve and the Financial Stability Oversight Council may dismantle some of the largest firms if they are deemed to pose a “grave threat” to the financial stability of the country. But members of the Oversight and Investigations Subcommittee and witnesses from the Federal Reserve Board of Governors and the Federal Deposit Insurance Corp. struggled to nail down how to define “grave threat.” Scott G. Alvarez, General Counsel of the Federal Reserve Board of Governors, told the subcommittee that “no, we have not” defined grave threat. Alvarez noted it would depend on the size and type of institution and the circumstances.

Breakthroughs with Martin Sheen Reporting on Community Bank Popularity

San Francisco Chronicle

This summer, Breakthroughs with Martin Sheen will debut a new report showcasing the growing popularity of community banking institutions. Martin Sheen Breakthroughs is talking to banking customers and banking executives to learn more about the growing popularity of community banks. Ever since the economic collapse of 2008, many people have moved their accounts from large banking institutions to small community banks and credit unions. The additional personal attention, involvement in the community, and different loan qualification practices have made small banks an attractive alternative for many banking customers. In this new report, Martin Sheen PBS will show how these small banks are thriving in a marketplace where many of their customers have left larger banks behind.

FRB Chairman Bernanke Speech - Creating Resilient Communities

Federal Reserve Board of Governors

Successful government and private strategies to rebuild poor neighborhoods cannot focus narrowly on a single problem, but must address several factors in a coherent way, Federal Reserve Board Chairman Ben Bernanke said last Friday. In a speech at a Fed conference on community redevelopment, Bernanke said this holistic approach "is easier said than done." "Community development is a complicated enterprise," Bernanke said. "But substantial coordination and dedication are needed to break through silos to simultaneously improve housing, connect residents to jobs, and help ensure access to adequate nutrition, health care, education, and day care."


City First Bank of DC - Multiple positions (Washington, DC)
Chief Credit Officer: Responsible for managing the credit administration and loan documentation functions of the Bank’s loan portfolio. This role will also ensure that the lending culture of the bank is effectively communicated, implemented, and reinforced within all lending areas as well as establish written loan and credit policies, practices, and procedures which meet regulatory safety and soundness standards for Board approval. The CCO will oversee the bank’s non-performing and underperforming loans and assets to ensure acceptable level of problem loans, past due loans, and loan documentation issues are managed. The CCO will provide management reports on all loan and Allowance for Loan and Lease Loss (ALLL) calculations and making recommendations to executive management and the Board of Directors for quarterly allocations to the Allowance for Loan Losses.

Relationship Manager: Responsible for soliciting new business and managing customer relationships to real estate customers, small businesses, and not-for-profit organizations (including churches and charter schools, among others). Real estate activities generally include loans for the acquisition or renovation of nonresidential owner-occupied real estate. In addition, the prospects include office, retail, shopping strips, warehouse, industrial, facilities, and land development, primarily for investment purposes. The position reports to the Chief Lending Officer. The Relationship Manager is also responsible for all phases of loan and deposit production, including lead generation, underwriting, closing, relationship management, and portfolio monitoring and is an officer of the Bank, participating in the Directors’ Loan Committee (DLC) of the Bank, and other staff meetings as required.

Senior Underwriting Specialist: Responsible for reviewing loan applications from individuals and businesses, calculating the credit risk, and recommending a decision on the application. The individual is highly knowledgeable in all aspects of commercial and commercial real estate lending and has the capacity to offer expertise on loan structuring and financial assessment. Based on the their expertise, the Specialist has the capacity to support other Bank Staff in conducting financial analysis and providing loan decisions and credit recommendations based on a review of all underwriting criteria including collateral, interest rate, loan structure, and fees.

Mission Housing Development Corporation - Director of Housing Development (San Francisco, CA)
Mission Housing Development Corporation develops high-quality, well-managed, affordable, and sustainable homes and communities that promote the self-sufficiency of low and moderate income families, seniors, and persons with diverse needs. The Director of Housing Development is responsible for the completion of permanent affordable housing projects, the preparation and completion of affordable housing project applications, and the research and securing of future sites for permanent affordable housing.

ACCION Texas - Loan Officer (Dallas/Fort Worth, TX)
ACCION Texas seeks two Loan Officers in the Dallas/Fort Worth area. The Loan Officer will be responsible for development and growth of ACCION Texas small business lending in the Dallas-Fort Worth market by interfacing with banks, borrowers, and the business community to identify small businesses that do not have access to loans from commercial sources.

| Thursday, April 11, 2013

CDBANewsflash - Low Rez For Email 2

April 11, 2013


Member News

United Bank Restructures; Promotes Three Senior-Level Executives

Three senior-level officers with United Bank in Atmore have been promoted to newly created executive vice president positions.Gwen Braden will now serve as executive vice president and chief operations officer; Mike Vincent will serve as executive vice president and chief credit officer; and Casey Gay Zito will serve as executive vice president and chief retail officer. “As we continue our momentum and focus our vision beyond 2013, each will play a critical role in the direction of the bank and in shaping our future,” Robert R. Jones III, president and chief executive officer of United Bank, said of the promotions already approved by the bank’s board of directors. 

Of Interest

Bailed Out Banks Haven't Met Goals of Small Business Lending Program, Report Says

Washington Post

Banks used billions from a small-business lending program to repay government bailout funds, rather than for its intended purpose — making more loans to mom-and-pop operations, according to a watchdog report released Tuesday. The Small Business Lending Fund dished out more than $4 billion to 332 community banks, credit unions, and community development financial institutions to lend to Main Street businesses. By signing up for the lending program, banks could convert their TARP obligations into a lower-interest loan and escape restrictions on executive compensation. But in return, the banks were supposed to increase their lending to small businesses. Instead, 132 TARP recipients participating in the small-business program used about $2.1 billion they were awarded to exit TARP, rather than increasing lending, according to the report from the TARP special inspector general. “For some TARP banks, SBLF turned out to be little more than a TARP exit strategy,” said Christy Romero, special inspector general for TARP.

Six Ways Banks Can Defeat Hackers and Reduce Data Breaches


When it comes to dealing with hackers and data breaches, small banks have more to lose than big banks: They face an uphill battle to win back customer trust once it’s gone, and customer trust is a core value proposition for small and mid-sized banks. They also have fewer resources at their disposal than larger financial institutions. So how can small and regional banks reduce the risk of breach? Consider these six steps to jumpstart your bank’s security plan: 1) Manage information assets like all other assets; 2) Perform a security assessment; 3) Appoint a Security Officer; 4) Educated employees about security best practices; 5) Monitor social media exposure, and 6) Limit data access to only those who need to know.

Bluebird Gains FDIC Insurance

CU Times

Skeptics who saw the seeds of an eventual bank charter in the advent of American Express and Walmart had a change of heart and last week announced that the jointly sponsored Bluebird prepaid card will carry FDIC deposit insurance. Dan Schulman, group president, enterprise growth at American Express, said, “Bluebird is designed to help make their everyday financial lives easier, more convenient, and less expensive. [This] announcement, which reflects feedback from consumers, advocacy groups, and government officials, represents the next set of enhancements that further distinguish Bluebird from other financial services options.” In another change, the company announced that Bluebird cardholders would be able to obtain checks for their accounts that the company will pre-authorize in order to prevent overdrafts.

PayDay Lending Drains Nearly $1 Billion from Communities

Washington Informer

One of the worst ironies of the nagging economic recession is that consumers with the fewest financial resources have lost the most. Now, a new report finds that payday loans not only strip much-needed income from low-income families, but harms the economic viability of the communities where they operate, draining nearly $1 billion a year. Written by the Insight Center for Community Economic Development (Insight Center), it also reveals other net negative impacts of these small-dollar, high cost loans on economic growth and personal bankruptcy filings. The Insight Center examined the net economic impact of the $3.3 billion in interest that borrowers paid to non-bank payday lenders in 2011. The study found that if consumers collectively had an additional $3.3 billion in discretionary spending, it would have resulted in $6.34 billion in economic activity and created 79,000 jobs. In comparison, payday lending activity added $5.56 billion to the national economy and created 65,000 jobs. Combining these figures shows a net loss from payday lending of $774 million in economic growth and more than 14,000 jobs. That's in addition to $169 million lost through Chapter 13 bankruptcies.


Innovations for Poverty Action - Director U.S. Household Finance Initiative (New Haven, CT or Washington, DC)
Innovations for Poverty Action (IPA) seeks a qualified applicant for the position of U.S. Household Finance Initiative Director. The position offers an opportunity to manage and lead a growing research initiative which supports cutting-edge development research. The position will be based out of New Haven, CT and will travel frequently within the United States. The position reports to the Deputy Executive Director for Research and Policy and works closely with the researchers that lead the initiative.

NCB Capital Impact - Community Engagement Associate (Arlington, VA)
The Cornerstone Partnership, an initiative of CSG/NCB Capital Impact, supports local and state homeownership programs that preserve long-term affordability and community stability. Since 2010, it has grown to over 700 members located across the U.S. The partnership  engages with its members through a variety of communication and programming activities, including monthly e-newsletters, bi-monthly webinars, and program assessments. The Community Engagement Associate will help coordinate member programming activities by supporting communications, marketing, and member engagement activities for Cornerstone Partnership. Cornerstone is seeking a strong self-starter with the ability to manage many responsibilities in a fast-paced, creative environment.

Mission Housing Development Corporation - Director of Housing Development (San Francisco, CA)
Mission Housing Development Corporation develops high-quality, well-managed, affordable, sustainable homes and communities that promote the self-sufficiency of low and moderate income families, seniors, and persons with diverse needs. The Director of Housing Development is responsible for the completion of permanent affordable housing projects, the preparation and completion of affordable housing project applications, and the research and securing of future sites for permanent affordable housing.

ACCION Texas - Loan Officer (Dallas/Fort Worth, TX)
ACCION Texas seeks two Loan Officers in the Dallas/Fort Worth area. LO will be responsible for development and growth of ACCION Texas small business lending in the DFW Market by interfacing with banks, borrowers, and business community to identify small businesses that do not have access to loans from commercial sources.

| Tuesday, April 9, 2013

From the Washington Post: "Banks used billions from a small-business lending program to repay government bailout funds, rather than for its intended purpose — making more loans to mom-and-pop operations, according to a watchdog report released Tuesday. The Small Business Lending Fund dished out more than $4 billion to 332 community banks, credit unions, and community development financial institutions to lend to Main Street businesses. By signing up for the lending program, banks could convert their TARP obligations into a lower-interest loan and escape restrictions on executive compensation. But in return, the banks were supposed to increase their lending to small businesses. Instead, 132 TARP recipients participating in the small-business program used about $2.1 billion they were awarded to exit TARP, rather than increasing lending, according to the report from the TARP special inspector general. 'For some TARP banks, SBLF turned out to be little more than a TARP exit strategy,' said Christy Romero, special inspector general for TARP."

| Monday, April 8, 2013

On April 8, 2013 the membership of the Community Development Bankers Association submitted a comment letter to the CDFI Fund in response to the Community Development Financial Institution Fund’s (CDFI Fund) request for public comment on the Interim Final Rule implementing the CDFI Bond Guarantee Program (CBGP). The Interim Final Rule was published in the Federal Register on February 5, 2013. We thank the CDFI Fund for the opportunity to comment and urged the U.S. Department of Treasury to implement the program in a manner that enables the entire, diverse CDFI sector to use the program for the benefit of distressed communities across the country.

Our comments focused primarily on explaining how the CBGP presents an opportunity to enable CDFI banks to significantly expand provision of credit in Low-and Moderate-Income (LMI) communities given the program's design and a rapidly changing and restrictive bank regulatory environment. Among the recommendations, our highest priority is ensuring that the Use of Bond Proceeds and Secondary Loan Requirements are consistent with allowing CDFI banks to use proceeds as Tier 1 capital if approved by the Federal banking regulatory agencies. As such, we asked for the US Treasury’s and CDFI Fund’s support as we seek an exception to the Basel III rule for the CBGP. A second tier set of recommendations was focused on ensuring the CDFI Bond Program proactively mitigates potential conflicts with other regulatory rules that might otherwise prevent CDFI bank participation. A third tier set of recommendations focused on issues of general concern regarding the program's structure and requirements. Like our colleagues in other sectors of the CDFI industry, overall program fees and other costs are the greatest concern. The subsequent recommendations were listed in descending priority order in the letter.