The Alliance Rebrands to Celebrate a Bright, United Future for Black America

The African American Alliance of CDFI CEOs (The Alliance) is thrilled to announce its new brand identity. Guided by our Strategic Plan, this is a bold step forward for our organization, and we’re excited to be taking it. 

We’re proud of our history, and we’re committed to building on it—and shaping a brighter future. That’s why we’ve spent the past few months working on a new look that represents who we are as an organization now, and who we’d like to be in the future. As we evolve, it is our aim to be transparent and respond to the needs of our diverse Black community. 

New Logo:

The new identity is inspired by themes of afrofuturism—a way of imagining possible futures through a Black cultural lens. The logo utilizes an abstract icon, reminiscent of a rising sun, but symbolizing the Alliance as a community or collective. It represents our mission to build a movement of connected institutionally diverse, Black community leaders and their allies working to transform Black economies across the U.S.

The Alliance was formed because we saw that historically the racial wealth gap has profoundly impacted Black-Led CDFIs and Black communities. In generational wealth, home ownership, access to capital, and entrepreneurial investment, African Americans face significant and systemic challenges to reaching true economic freedom.  
We believe that when we come together as institutions and individuals committed to each other’s success—and share resources along with our expertise—we can build a better future for all of us together. 

A Movement for Economic Justice. 
We are excited to launch this new brand and a new website, which is central to the organization’s goal of creating a national network dedicated to increasing wealth and opportunities for Black communities. Through a variety of programs and events, we plan to accelerate a coordinated and sustained effort towards equitable Black economic empowerment. We can activate new strategies to tackle common racial wealth gap issues, while setting standards for all communities to follow in our footsteps. We do this work through our advocacy efforts as well as by creating capacity building opportunities for our members through access to capital, grant opportunities, peer-to-peer learning, and more. 

As we move forward, we look to future members to create a vibrant and lasting symbiotic relationship. We believe that together we will improve our communities through conscious investments, increased entrepreneurship, and the establishment of Black-led CDFIs in areas that need them most. 

If you have been following along, thank you for your unwavering support! If you’re new here, welcome! We are excited to continue our work empowering the next generation of Black leaders and working together to close the racial wealth gap. 

Be Steadfast! 

Lenwood V. Long, Sr. 
President & CEO, The Alliance

Alliance Member Spotlight: Economic Resilience and the Commitment to Community Development


Economic resilience means more than providing financial services and financial education to those who are underserved. It means an investment in leadership development, physical capital, building of human capital, and efforts to create positive perceptions of the community in which you serve. And it means doing so with a high level of commitment over a long period of time. For Baltimore Community Lending (BCL), President and CEO Watchen Bruce is that person.

Born in Liberia in a farming community, Watchen immigrated to the United States, attending the University of Houston and later receiving a master’s degree in Business Management from the University of Massachusetts.  She began her career as loan officer for the 1st International Bank of Houston in 1981 before being recruited by the Bank of New England.  Following her time at the Bank of New England, Watchen transitioned to the federal loan home bank in Boston, where she was the only black home loan officer at the time.  Watchen credits the mentorship of a supervisor as an instrumental force who encouraged her to ask questions, push the bank to diversify and improve outreach to minority communities. “Communities of color often receive information differently,” said Watchen. “You must meet people where they are and engage through the mediums that matter to them, whether that is the churches they attend or the radio stations they listen to. You must understand someone’s community to determine the resources they need and how you can increase access to them.”

Following her time in Boston, Watchen moved to D.C. to work with Neighbor Works America and PNC Bank, consulting with CDFIs and providing lending to community groups. In her role with PNC Bank, Watchen provided capacity building, technical assistance, and financial management training to underserved and low-income communities. Additionally, as a development advisor she managed economic development projects, lending, and investment programs for the community development-banking group, including a $100 million equity fund to invest in economic development projects in low-income communities. However, it was the opportunity to return to Liberia as part of USAID that served as a full circle moment for Watchen. Serving as chief of party on the $3.5 million USAID-funded Investing for Business Expansion (IBEX) , Watchen worked as “a liaison between the Government of Liberia, USAID, and other key stakeholders and implementing partners, ensuring an integrated vision among different actors and program components.”  From 2012-2016 the IBEX initiative provided technical assistance to nine financial institutions, including 2 DCA partner banks, and trained 331 banking professionals on cash flow lending, underwriting, and risk and portfolio management to develop institutional capacity and strengthen financial portfolios and strategies. “Being able to bring my expertise back to Liberia was an unbelievable opportunity,” said Watchen. “To return to my home country and use my skillset to assist in business development was truly a dream come true.”

Watchen Bruce became the President and CEO of BCL in October 2019 and began the development of 5-year strategic plan right before the start of COVID-19 pandemic. Under Watchen’s leadership, Baltimore Community Lending maintained a strong and trusting relationship with the Baltimore community, deploying funds to small businesses, and participating in the Payback Protection Program (PPP) providing loan packaging to those who needed financial assistance. In 2020, during the height of the pandemic, BCL provided more than 5.6 million dollars in loans to real estate developers and small businesses owners who were unable to get a loan from the bank. During that same year, BLC funded the construction of 21 affordable and mixed development housing units in underserved Baltimore neighborhoods.

“Proving resources for our communities is something we have to take personally,” said Watchen. “To have inclusion of communities in wealth building,, we must advocate and be at the table to shape policy.” As a member of the African American Alliance of CDFI CEOs and a Black executive , Watchen believes she plays a crucial role as an advocate for funding allocation and policy change. “With the Alliance, we can move froward with one agenda, which gives us strength in numbers. People must participate in dialogue when it comes to affordable housing and wealth building, and the alliance amplifies our ability to advocate as individuals and as a collective of CEOs.” 

As our nation pushes towards economic recovery, executives like Watchen Bruce continue to center the needs of community first, and her leadership with BCL reflects the prioritization of wealth building and economic opportunities for communities of color. For Watchen, policies are made to be transformed and we must consider how economic policy impacts us on a local, state, and federal level. Additionally, she encourages young people to discover their passion and seek out ways they can make an impact on the issues that matter to them. 

“Young people must find their passion,” said Watchen. “I would encourage them to get involved at the local level, joining political action teams, whether it’s education, healthcare, housing or economic development.” As a leader in the CDFI field and a fierce advocate for social and economic policy, Watchen Bruce is paving the way towards greater financial prosperity for all communities.

CRA Reform: A Call on Equitable Lending, Public Comment Letter from The Alliance

The Community Reinvestment Act (CRA) has served as a critical tool in mitigating the effects of redlining and increasing access to credit for low-income and minority communities. The CRA also incentivizes banks to reinvest in these underserved communities, as evidenced by increased lending activity after the financial crisis. However, as found in our research, banks continue to demonstrate disparities in their lending activities by race and ethnicity.

The Alliance recommends that regulators consider reforms aimed at reducing such disparities through:

  • Explicit consideration of bank activity by race and ethnicity 
  • Objective performance measures that reduce CRA ratings inflation 
  • An expansion of CRA reviews to include quality of lending 
  • Further consideration of asset thresholds for bank classification, as proposed regulation could potentially impact community reinvestment activity 

Below is our full public comment letter on CRA and our recommendations:

Re: Notice of Proposed Rulemaking, Community Reinvestment Act Regulations

The African American Alliance of CDFI CEOs (the Alliance) appreciates the opportunity to comment on Docket ID OCC-2022-0002, the “Notice of Proposed Rulemaking on Reforming the Community Reinvestment Act Regulatory Framework,” the most comprehensive update to the CRA regulation and exams since 1995. As financial leaders directly serving diverse communities, the Alliance is a membership-driven intermediary organization of over 64 Black-led CDFIs that aims to: build the capacity of member organizations; build bridges to economic stability, well-being, and wealth for Black individuals, families, and communities; and build power in Black communities by challenging and influencing financial sectors to operate more equitably.

Since it was enacted in 1977, CRA has been one of the most impactful federal policies for affordable housing and community development financing. Between 2009 and 2020, banks have made more than $2.58 trillion in home loans to low- and moderate-income (LMI) borrowers or in LMI census tracts and $856 billion in loans to small businesses with revenues under $1 million.[1] The latest CRA regulatory proposal builds upon this progress and the Alliance believes the following reforms will be instrumental in meeting the CRA’s goal of meeting the credit needs of LMI communities:

  • Inclusion of CDFIs in the proposed list of Impact Review Factors. Current CRA guidance allows bank examiners to determine the extent to which a bank’s community development activity is responsive to the credit needs of LMI communities. In the interest of transparency, the proposal calls for a list of impact-review factors for the qualitative evaluation of community development activities, with one of the impact review factors corresponding to activities undertaken in partnership with Black-led CDFIs. This is an acknowledgement of the critical role these institutions play in meeting the unique capital and credit needs of underserved communities.
  • Updated assessment areas that reflect innovations in the financial services industry. Regulators will continue to use “facility-based assessment areas,” which are delineated by a bank’s deposit-taking networks, as the primary factor for determining if banks are meeting their CRA obligations. However, the proposed rule would provide banks with consideration for activities in areas where they have a concentration of retail loans and aggregate CRA-related activity in LMI areas across the entire country.
  • Expanded consideration of community development activities conducted outside of bank assessment areas. Bank branch locations do not always align with the neighborhoods most in need of investment, and this is particularly true for the communities many CDFIs serve. The proposed geographic flexibility can help bring community development capital to more neighborhoods. That said, the Alliance would oppose any efforts to close bank branch locations in underserved communities.
  • Increased reliance on data transparency. A CRA review process that is driven by data will give banks, regulators, and the public a more comprehensive understanding of lending and investment activity taking place across the country. Specifically, data related to race and ethnicity of borrowers, bank deposits, and small business lending statistics, will highlight the gaps in financial services in underserved communities and hopefully spur economic activity in those areas. However, this quantitative data must be accompanied by more flexible qualitative reviews to tailor innovative solutions to combat the challenges faced by specific communities.

Though the proposed reforms to the CRA are certainly a step in the right direction, they do not fully address the ugly legacy of redlining and its role in widening the racial wealth gap in the U.S. In 1968, a decade prior to the enactment of the CRA, a typical middle-class Black household had $6,674 in wealth, contrasted to a typical middle-class white household which had $70,786 in wealth.[2] Data from 2016 shows that the racial wealth gap is actually expanding, with a middle-class Black family holding $13,024 in wealth, relative to a middle-class white family’s $149,703 in wealth.[3] The racial homeownership gap is key to understanding racial wealth disparities in the U.S. According to the National Community Reinvestment Coalition in 2018, only 42 percent of Black people owned homes, compared to 73 percent of whites during the same period.[4] Not surprisingly, the denial rate for mortgage loans for Black applicants is nearly double that of whites and Black property values are often significantly lower than that of Whites.[5] These factors adversely impact funding for public education and, by extension, educational attainment in Black communities. These disparities translate to billions of dollars of unrealized Black wealth and results in Black Americans settling for lower paying jobs at a higher rate than of white Americans.[6] Sadly, by the time Black Americans reach retirement age, they have accumulated about $1.1 million less than their White counterparts.[7]  Unfortunately, the racial homeownership gap is not the only driver of the persistent racial wealth gap in the U.S. Additionally, though more than 2.2 million jobs are held by persons who find themselves either directly or indirectly employed by National Minority Supplier Development Council-certified Minority Business Enterprise (MBE)s, it is often difficult for many minority-owned businesses to expand and grow due to lack of financing.[8]  The 2021 Small Business Credit Survey found that Black-owned firms that applied for traditional forms of financing were least likely to receive all the financing they sought – 40 percent of white-owned firms received all the financing they sought, compared to 31 percent of Asian-owned firms, 20 percent of Hispanic-owned, and only 13 percent of black-owned firms. This trend persists even amongst Black-owned firms with good credit scores.[9]  A major reason for these disparities is fewer branches in communities of color and less competition among banks in those communities, which reduces choices for affordable bank products.[10]

For CRA to meet its goal of increasing bank reinvestment activity more effectively in underserved communities, it must meaningfully address the drivers contributing to the persistent racial wealth gap, promote the importance of community development finance and service responsibilities for all banks, and ensure that its designations of eligible activities are clear and serve important community needs, such as affordable housing.

Summary of Alliance Positions

CRA exams must explicitly consider banks’ records in serving people of color and communities of color

Although the CRA statute does not mention race, it required banks to serve all communities, which provides room for the federal bank agencies to incorporate race in CRA exams. However, if CRA is to properly address the persistent racial inequality plaguing the Black Community, it is imperative for its exams and ratings to explicitly consider bank activity by race and ethnicity. A recent national level analysis showed continuing disparities in loan denials by race and when people of color receive home loans, their equity accumulation was less.[11] The public information in the fair lending review on CRA exams has been cursory and has usually consisted of a few sentences stating that no discrimination was found.[12] The federal government instituted redlining practices in New Deal housing programs and which was later adopted on a widespread basis by the Federal Housing Administration (FHA) and the private sector. Persistent racial disparities in lending must compel the agencies to incorporate race and ethnicity in CRA exams. As stated in our joint letter with Pacific Community Ventures, a focus on LMI communities only, without specific requirements to target BIPOC borrowers, does not achieve racial equity.

The agencies proposed to use the Home Mortgage Disclosure Act (HMDA) data to produce exam tables describing lending by race, but not to use the results of these analyses to influence a bank’s rating. The National Community Reinvestment Coalition (NCRC) had asserted in a paper co-authored by Relman Colfax PLLC that changes to CRA would comply with legal standards if CRA examined lending by race and ethnicity in geographical areas experiencing ongoing discrimination or exhibiting significant racial disparities in lending.[13] NCRC had also proposed including analyses of lending in underserved neighborhoods with low levels of lending.[14]

While we believe the agencies can examine banks’ record of lending to race, the agencies should at least bolster fair lending reviews accompanying CRA exams for banks that perform poorly in the HMDA data analysis of lending by race. In addition, the agencies proposed using Section 1071 data on small business lending by race and gender of the business owner, and this data should be used as a screen for fair lending reviews. By including race and ethnicity, CRA can identify and address persistent racial disparities that have direct impacts on quality of life and health outcomes and combat the ugly history of redlining in our country and its impact on communities of color.

To this end, incorporating race into the CRA can be accomplished by adding racial demographics to the list of factors to consider when delineating assessment areas. Another option is the creation of specific benchmarks and metrics to evaluate lending and services to those communities and geographies within the retail lending, retail services, community development financing and community development services subtests of CRA evaluations. A third option is the incorporation of HMDA data analysis of lending by race into an institution’s CRA performance in those identified geographies/assessment areas. Finally, as noted by Alliance member, Hope Enterprise Corporation/Hope Credit Union/Hope Policy Institute (HOPE), race may also be included among the factors considered in lending tests and impact reviews would be to utilize the “other targeted population” framework already provided for in the Riegle Community Development and Regulatory Improvement Act of 1994. The Act’s definition of “targeted populations,” can either be individuals who are low-income or others who “lack adequate access to Financial Products or Financial Services in the entity’s Target Market.” This latter category is codified as “Other Targeted Population” in the CDFI Fund Certification Guidance. It is defined as “African-American, Hispanic, Native American, Native Alaskan residing in Alaska, Native Hawaiian residing in Hawaii, Other Pacific Islander residing in Other Pacific Islands, People with Disabilities and Certified CDFIs.[15]” The Fund allows other populations to be considered in this category only if “approved by the CDFI Fund before they can be included as part of an entity’s Target Market for CDFI Certification purposes.[16]

Use performance measures assessing lending to people of color

On an interagency basis, the federal bank agencies should conduct periodic statistical studies and identify metropolitan areas and rural counties that either experience ongoing discrimination or exhibit significant racial disparities in access to credit. In the geographical areas with significant disparities, like the Deep South, fair lending performance measures like percent of loans to people of color could contribute to CRA ratings.

As noted by NCRC, the performance measures could receive separate ratings or scores and thereby contribute to the ratings for the subtests and for the overall rating. Alternatively, the performance on the racial and ethnic measures could boost a rating if the performance is commendable. We would prefer the first alternative but offer the second in the interests of presenting various options for assuring success against a strict scrutiny standard. Of course, as occurs currently in federal CRA evaluations, if a fair lending review uncovers discrimination, the CRA exam should lower a bank’s rating, particularly if the discrimination is not confined to a rogue employee or branch office but is widespread across the institution.

Public input mechanisms in CRA exams and merger reviews must be robust and include consideration of community benefit agreements

Since CRA requires banks to meet the needs of communities, the agencies must elevate the importance of public comments regarding the extent to which banks meet local needs. The agencies proposed to continue the current practice of sending any comments on CRA performance to banks and are also considering publishing comments received on agency websites.

Posting comments on agency websites will establish accountability on the part of examiners to consider them. In addition, these comments can be referenced during future merger applications to determine if the banks addressed significant concerns of the public. Also, the agencies should establish a public registry that community organizations can use to sign up if they want to be contacted about community needs and bank CRA performance. Furthermore, we request that the agencies start to publish which organizations they consult with to understand local community needs, commit to collecting input from a diverse range of organizations that includes organizations led by people of color and women, follow up on needs identified and detail how community input was factored into the results of CRA performance evaluations. 

We agree with Acting Comptroller Hsu that the agencies must hold frequent public hearings on large bank mergers. CRA exams, if they are made more rigorous by a final rule, will help hold merging banks accountable.[17] However, merging banks must also submit a community benefits plan as part of their merger applications which could include community benefits agreements negotiated with community organizations. As further described in recent comments we agree with NCRC that an outstanding CRA rating must not be considered evidence that merging banks have satisfied the public benefits legal requirement. Finally, CRA exams following merger approvals must review compliance with community benefit agreements or conditional merger approvals.

CRA must include more objective measures of performance that reduce ratings inflation and provide clear guidance and rigorous training for its examiners

The current ratings distribution does not adequately distinguish banks in CRA performance. As evidence, about 98 percent of banks pass their CRA exams on an annual basis with just less than 10 percent receiving an Outstanding rating and almost 90 percent of them receiving a rating of Satisfactory.[18] CRA has successfully leveraged more loans, investments and services for LMI communities but it would be more effective in doing so if the ratings system more accurately revealed distinctions in performance.[19] However, more banks would be identified as significantly lagging their peers, which would motivate them to improve their ratings and increase their reinvestment activity.

The agencies bolstered the rigor on the large bank retail lending test by introducing performance ranges for comparisons among a bank’s lending and demographic and market benchmarks. This quantitative approach would decrease ratings inflation and result in more failing and low satisfactory ratings on the lending test. As a result of this proposed reform, several banks would likely respond by boosting their retail lending to underserved communities.

The agencies proposed improvements to the other subtests of the large bank exam but did not establish as many guidelines for the performance measures, which could contribute to inflation on the subtests. The community development finance test, for example, will consist of a quantitative measure of a bank’s ratio of community development finance divided by deposits. The bank’s ratio will be compared to a local and national ratio. The agencies, however, did not provide enough guidelines to examiners for comparing the bank’s ratio to either the local or national ratio, making it possible for an examiner to inflate a rating by choosing the lowest comparator ratio. Further, the impact review, the qualitative part of the test, must be more fully developed and must significantly contribute to the Community Development test score. 

The possibilities of misplaced examiner discretion can also occur on the retail services test and the community development services test. The retail services test contains quantitative measures comparing a bank’s branch distribution to market and demographic benchmarks but does not provide enough instructions to examiners about how to weigh these benchmarks.

We believe that it is possible for the agencies to further develop guidelines for how to use the performance measures on the community development and services subtests of the large bank exam in order to produce a uniformly rigorous CRA exam and guard against ratings inflation. We also believe the agencies should commit to increasing its examiner workforce and enhancing its training regimen. Examiners tend to be starved of critical resources and time necessary to properly assess bank compliance with CRA. A commitment to workforce expansion and training across all regulators would serve the dual purpose of helping alleviate the heavy workloads and tight deadlines associated with the examination schedule while also limiting the likelihood of vague and inconsistent eligibility determinations that do not accurately reflect a bank’s CRA performance.

Enhancements to community development definitions are needed to more effectively target activities to communities in need

The agencies proposed refinements to the definitions of affordable housing, economic development, climate resiliency and remediation, community facilities and infrastructure that we believe would more effectively target revitalization activities to communities such as persistent poverty counties and Native American communities.

The agencies have clarified that revitalization activities must not displace LMI populations.[20] The anti-displacement provision must be applied to all community development (CD) activities including affordable housing. A final CRA rule that does not adequately protect against displacement would not be upholding CRA’s requirement that banks serve the needs of LMI populations and communities. For example, multifamily housing that may initially be affordable but then involves rapid rent increases that pushes out LMI tenants is not serving the needs for housing. Further, needs are not met if housing is kept in poor condition and tenants face harassment. In addition, it will be important that the rule ensure sufficient income targeting, promote access to opportunity and promote fair housing and tenants’ rights.

Harmful projects like landfills or fossil fuel facilities that are disproportionately placed in LMI neighborhoods and communities of color must not receive CRA credit under the new definition of CD. Instead, they must be penalized by lowering scores on the CD finance test. The proposed addition of climate adaptation and resiliency measures for CRA credit is an important and positive step forward, reflecting the increasing harms of climate change for vulnerable communities and the ways in which climate resilience is a critical foundation for community health and economic stability and growth.

The NPR clarified that financing health services qualifies under the definition of community support services. Essential community facilities now include hospitals and health centers without current documentation requirements, applied inconsistently, that the financing attract and retain residents to the community.[21] This streamlining would boost financing of critical community infrastructure.

The community development finance test will include an impact review[22] which must be further developed and include points and ratings like the other subtests so that the test can be more effective in stimulating responsive community development activities. We ask the agencies to reconsider their proposal to expand CRA consideration for financial literacy with no income limits[23]; scarce counseling resources need to be targeted to LMI and other underserved populations.

Finally, we ask the agencies to carefully develop their proposed list of illustrative activities that qualify for CRA to avoid the impression that this list is an exclusive list of approved activities. Novel and responsive activities like financing minority-owned media outlets, childcare centers and workforce development for people with disabilities should be highlighted.

Data improvements must provide more insight into banks’ records of meeting credit and community needs

As a network focused on Black wealth creation, the Alliance understands that lending practices to minority communities is a historical and systematic issue that has stymied the financial growth of Black and Brown communities. The collection of disaggregated race, ethnicity and other demographic data is key to dismantling these unfair lending practices. Such data collection must include disaggregated data for all the key sub-group categories such as race/ethnicity data.

The agencies correctly proposed to include new data collecting requirements for deposits, community development activities and automobile lending. Some of this data such as deposit and automobile lending would not be publicly available, which limits the extent to which the public can hold banks accountable for reaching underserved communities. We ask the agencies to reconsider this decision and to expand data collection to all large banks instead of just banks with assets of more than $10 billion in the case of deposits and automobile lending.[24] Finally, CRA exams should not only analyze access to deposit accounts for LMI communities but also affordability by comparing and refining, if necessary, fee information collected in call report data.

Anti-discrimination and fair lending reviews must be more transparent. CRA exams must examine affordability and sustainability of lending in order to prevent predatory lending

The agencies proposed to include all activities and products including deposit accounts in addition to credit in anti-discrimination and consumer protection legal reviews. This is an important advance, but we urge the agencies to expand their reviews to include the quality of lending. Massachusetts CRA exams include analysis of delinquency and default rates in home lending specifically highlighting mortgage companies.[25] Federal CRA exams should do likewise in all major product lines. Moreover, reviews of lending must include an affordability analysis and impose penalties when banks offer on their own or in partnerships with non-banks abusive, high-cost loans that exceed state usury caps and that exceed borrowers’ abilities to repay.

Assessment area changes must sufficiently capture online lending and deposit taking activity

For several years, advocates have urged the agencies to examine lending that occurs online. The agencies proposed to create retail assessment areas where a large bank does not have branches when a bank has issued 100 home loans or 250 small business loans.[26] This proposal would result in the great majority of total lending being incorporated on exams and would therefore hold non-traditional banks more accountable for serving LMI communities.

We ask the agencies to expand upon their proposal to include partnerships with banks and non-banks for retail lending. When a bank partners with more than one non-bank, the lending of all the non-banks needs to be totaled together for calculating if the threshold is exceeded for purposes of creating assessment areas.

In order to ensure that banks serve smaller metropolitan areas and rural counties, the agencies proposed requiring that banks with 10 or more assessment areas must receive at least a Low Satisfactory rating in 60 percent of the assessment areas in order to pass overall.[27] This still may not be an adequate solution since the smaller areas could represent a minority of areas, allowing a bank to pass the 60 percent threshold by focusing on the larger areas. One possible fix is to require banks to achieve at least a Low Satisfactory rating of 60 percent in each of its large metropolitan, small metropolitan and rural assessment areas. The overall passage rate for all assessment areas should be increased to 75 percent or higher to ensure banks are responding to community needs across their geographical footprint. Finally, a bank should be required to submit a public improvement plan with measurable performance goals for all assessment areas or subtests in which a bank receives a Low Satisfactory or lower rating.

The proposed asset threshold and bank classification changes would reduce community development financing and branching

By adjusting asset thresholds for qualifying for various CRA exams, the agencies proposed to reclassify 779 ISB banks as small banks, which would involve no longer holding these banks accountable for community development finance. NCRC estimates that community development finance would decline by about $1.2 billion annually as a result of this change.[28] In addition, the agencies proposed to reclassify 217 large banks as ISB banks, eliminating their service test and accountability for placing branches in LMI communities.[29] These changes, which would disproportionately impact small cities and rural communities, lack justification since these banks have been successfully performing these activities for several years. We urge the agencies to eliminate this aspect of the NPR since it would reduce reinvestment activity.

Increase weight of the Community Development Financing and Services test for large banks

The Alliance also opposes the NPR proposal for the weighting of the community development financing test for large banks, as it does not adequately promote community reinvestment. The proposal weights the retail lending test at 60 percent of the overall rating and the combined community development and services tests at 40 percent of the overall rating. The Alliance shares the concerns of the National Housing Conference and others that the proposal would allow banks to achieve a ‘Satisfactory’ rating despite completely failing the combined community development and services tests. Said differently, a bank will receive an overall ‘Satisfactory’ rating even if it earns a ‘Needs to Improve’ rating on the Community Development Finance and Service tests, provided it earns at least a ‘Low Satisfactory’ rating on its retail lending and service test. This is an incredibly low bar that most banks will clear and could disincentivize banks from pursuing community development activities. and significantly diminish the community finance ecosystem.

To ensure banks are committed to community development activities, the Alliance recommends that the community development test and the retail lending test be weighted equally, with community development services being a mandatory component of the test. At minimum, the agencies should ensure that any final scoring and weighing system must fail a large bank if it earns a Needs-to-Improve rating on either the two retail subtests or the two community development subtests. The agencies should consider failing a bank overall if it earns a Needs-to-Improve rating on any particular subtest, including the ones with lower weights. Further, a bank should be required to achieve at least a ‘Low Satisfactory’ rating on the community development test in order to obtain an overall ‘Satisfactory’ rating. 

Require equity investments in the Community Development Financing Test

The proposal, though mindful of community development financing, does so at the potential risk of devaluing other effective tools, such as the New Markets Tax Credit (NMTC) and the Low-Income Housing Tax Credit (LIHTC). Under the proposal, large banks will be evaluated under a “Community Development Financing Test.” This test combines many of the activities previously evaluated as community development lending and community development investments. This move towards a combined evaluation of community development loans, investments, and services could cause a shift in a bank’s CRA activity away from making equity investments in or grants to Black-led CDFIs, which are labor- and time-intensive but are incredibly impactful. Instead, banks might opt for making more community development loans, as these are typically less complex than equity investments. In addition to using the percent of equity investments and/or grants as a performance measure, the Alliance would also support development of subtests within the Community Development Finance test that would separately consider community development investments and loans, with equal weights assigned to those subtests.

Special Purpose Credit Programs (SPCPs) should be eligible for CRA credit on the community development test

The effects of redlining and racial discrimination that took place decades ago continues to haunt Black communities today. Though not a cure-all, SPCPs, which allow lenders to create credit products with favorable terms that are targeted to historically underserved classes, can help to reverse some of the economic disadvantages faced by Black communities due to historical discriminatory practices. The NPR discussed SPCP programs serving the needs of LMI borrowers, but the final regulation must explicitly recognize that these programs usually have been utilized to extend credit to people of color and communities of color. The final regulation should mention that SPCP programs can include home lending, small business lending, consumer lending or deposit products.

CRA credit for loan originations and secondary loan purchases should be reconsidered

The purpose of CRA is to measure and incentivize credit and banking services in underserved communities of color and LMI areas. However, this goal cannot be met if new mortgages are not being originated in these areas. Furthermore, the current regulations allow banks to resell loans purchased on the secondary market to other banks and those very loans are allowed to generate CRA credit for multiple banks. Continuing the practice of allowing secondary market loan purchases to generate CRA credit runs counter to the original intent of the CRA. 

The Alliance recommends that CRA credit be contingent upon a lenders’ demonstration of retail lending activity in LMI communities, evidenced by actual loan originations or the purchase of loans originated by a Black-led CDFI or MDI that services majority-minority communities.



In an event held earlier this year honoring Dr. Martin Luther King, Treasury Secretary Janet Yellen astutely noted that “From reconstruction, to Jim Crow, to the present day, our economy has never worked fairly for Black Americans – or, really, for any American of color.”[30]  CRA alone cannot reverse the effects of the systematic economic injustices that have given rise to the ever-expanding racial wealth gap. However, by directing banks to expand access to credit and capital to historically underserved populations, the CRA can play a pivotal role in revitalizing distressed communities, allowing individuals who live in those communities to build equity and begin the process of breaking down the barriers to intergenerational wealth accumulation that have stood in the way of Black and Brown communities for far too long.

The NPR is a good start and promises to make parts of CRA exams more rigorous but we urge the agencies to extend the rigor of the large bank lending test to the other tests. We also ask the agencies to incorporate race in CRA exams, to expand the public reporting of data collection proposals, to bolster their assessment area proposal to make sure that smaller communities are not left out and to refrain from reducing reinvestment requirements for any segment of banks. For America to succeed we need to make sure that African Americans have equal opportunities to contribute to the economy as business owners who create jobs and build wealth. If CRA is improved while maintaining public input and accountability, the proposed rule could help reduce inequalities, disinvestment, and other disadvantages in America’s overlooked communities.

Martin Luther King Jr. was prescient when he embraced what he coined “the fierce urgency of now.” Today, the agencies have an opportunity to remove the deep stain of racism that has blotted our nation’s history for generations. Today, the agencies have an opportunity to create a community development framework that fundamentally alters the social and economic trajectories of Black and Brown Americans that have been neglected for generations. This CRA reform is truly a once-in-a-lifetime opportunity. Given that the last significant CRA reforms took place 27 years ago, this might be our only bite at the apple for the foreseeable future. We must get this right now. We simply cannot afford to wait any longer.

Once again, thank you for the opportunity to comment on this most important matter. Please do not hesitate to contact me at [email protected] if you have any questions.


Lenwood V. Long Sr.

President and CEO

African American Alliance of CDFI CEOs

Sources, Links, Citations:

[1] CRA Qualified Lending 2009-2020 | Tableau Public

[2] Income and Wealth Inequality in America, 1949-2016 | Opportunity & Inclusive Growth Institute (

[3] Income and Wealth Inequality in America, 1949-2016 | Opportunity & Inclusive Growth Institute (

[4] 60 percent Black Homeownership: A Radical Goal for Black Wealth Development » NCRC

[5] Why the homeownership gap between White and Black Americans is larger today than it was over 50 years ago (





[10] Kristen Broady, Mac McComas, and Amine Ouazad, An analysis of financial institutions in Black-majority communities: Black borrowers and depositors face considerable challenges in accessing banking services, Brookings Institution, November 2021,

[11] NCRC 2020 Home Mortgage Report: Examining Shifts During COVID » NCRC


[13] Adding Robust Consideration of Race to Community Reinvestment Act Regulations: An Essential and Constitutional Proposal » NCRC

[14] Adding Underserved Census Tracts as Criterion on CRA exams » NCRC

[15] 12 CFR § 1805.201(b)(3)(iii)(a).

[16] CDFI Fund, CDFI Certification Application (For Public Comment Only), May 2020, Page 56.

[17] Acting Comptroller of the Currency Michael J. Hsu Remarks at Brookings on Bank Mergers and Industry Resiliency, May 9, 2022 (

[18] Do CRA Ratings Reflect Differences in Performance: An Examination Using Federal Reserve Data » NCRC

[19] ‘Don’t Know What You Got Till It’s Gone’ — The Effects of the Community Reinvestment Act (CRA) on Mortgage Lending in the Philadelphia Market by Lei Ding, Leonard I. Nakamura :: SSRN

[20] NPR, pp. 73-74.

[21] NPR, pp. 75-77.

[22] NPR, p. 107.

[23] NPR, p. 94.

[24] NPR, p. 553.

[25] Massachusetts CRA for Mortgage Companies: A Good Starting Point for Federal Policy » NCRC

[26] NPR, pp. 131-133

[27] NPR, pp. 368-369

[28] Adam Dettelbach, Josh Silver, Bruce C. Mitchell, Intermediate Small Banks: The Forgotten But Significant Resource For Affordable Housing And Community Development, NCRC, November 2017,

[29] Mark Pearce, Director, Division of Depositor and Consumer Protection, Memo on Notice of Proposed Rulemaking on Community Reinvestment Act Regulations, April 27, 2022, p. 4,

[30] US economy ‘has never worked fairly for Black Americans,’ Treasury chief says – ABC News (

Fintech and Transparency in Small Business Lending: Testimony of Lenwood V. Long, Sr., to the House Small Business Subcommittee on Oversight, Investigations, and Regulations

President / CEO of the Alliance, Lenwood V. Long, Sr., submitted the testimony below delivered to the House Small Business Subcommittee on Oversight, Investigations, and Regulations:


Chairman Phillips, Ranking Member Van Duyne and distinguished members of House Small Business Subcommittee on Oversight, Investigations, and Regulations Subcommittee, my name is Lenwood V. Long, Sr., President and CEO of the African American Alliance of CDFI CEOs ( “the Alliance”). The Alliance is a membership-driven intermediary organization of over 60 Black-led CDFIs that aims to: build the capacity of member organizations; build bridges to economic stability, well-being, and wealth for Black individuals, families, and communities; and build power in Black communities by challenging and influencing financial sectors to operate more equitably. As advocates for public policy and support for underserved communities, we are uniquely positioned to understand and engage the communities we serve.

Mr. Chairman and Ranking Member, I would like to thank you and the subcommittee for your commitment to ensuring fair and transparent fintech industry practices that protect our entrepreneurs as they pursue critical capital for their small businesses.

As we all know, minority-owned businesses are critical to job creation and preservation in chronically underserved communities. In fact, more than 2.2 million jobs are held by persons who find themselves either directly or indirectly employed by National Minority Supplier Development Council-certified Minority Business Enterprises (MBEs).  It is often difficult for many minority-owned businesses to expand and grow due to lack of financing. The 2021 Small Business Credit Survey found that Black-owned firms that applied for traditional forms of financing were least likely to receive all the financing they sought – 40 percent of white-owned firms received all the financing they sought, compared to 31 percent of Asian-owned firms, 20 percent of Hispanic-owned, and only 13 percent of Black-owned firms. This trend persists even amongst firms with comparable good credit scores. Often, Black businesses will rely on financing from alternative institutions such as minority-led CDFIs or MDIs. These institutions, which lend to Black communities at a greater rate than that of white-led and traditional financial institutions, specialize in lending to individuals, organization, and businesses in under-resourced communities. As evidence, research conducted by the Association Enterprise Opportunity showed that the wealth gap between Black and white business owners (3:1) is significantly lower than the overall Black/white wealth gap (13:1), a testament to the effectiveness of these minority-led institutions in reaching undercapitalized communities of color.

A more recent development has been the rise of financial technology (fintech) lending in the minority-owned small business space. A major reason for fintech’s late success is that they, relative to traditional banks, CDFIs and MDIs, are arguably better equipped to make quick decisions regarding customer creditworthiness and offer a more seamless and efficient customer experience. Despite fintech’s role in expanding access to credit for small business, these firms present unique challenges for prospective borrowers. For instance, many fintech lenders provide borrowers with scant information about promoted loan products, often omitting critical information regarding rates, fees, and repayment schedules. Ambiguous or opaque product descriptions makes it extremely difficult for borrowers to accurately access the cost of a particular fintech product offering, thus leaving borrowers vulnerable to irresponsible lenders. Further, some fintech lenders promote predatory repayment methods, such as Merchant Cash Advances (MCA). MCAs allow the fintech lender to receive a fixed percentage of future sales until the loan is repaid; however, MCAs are often accompanied by high APRs and daily repayments, resulting in an unmanageable debt cycle for the small business owner. In the most unfortunate cases, these repayment mechanisms can result in the closure of the small business. To that end, the Alliance would support efforts to extend the federal Truth in Lending Act (TILA) APR disclosure requirement to small business owners who apply for loans and financial credit products. Finally, fintech underwriting lacks the level of transparency exercised by traditional banks, CDFIs and MDIs. Specifically, information collected by fintech lenders in underwriting small business loans could be based on race or gender, characteristics protected by fair lending laws. In turn, this could lead to small business applicants being unfairly denied or offered products at a higher APR.

Mr. Chairman and Ranking Member, I thank you for this opportunity to provide written testimony on this important topic. The Alliance believes that small businesses are America’s backbone, employing nearly half of all employees and accounting for 44 percent of economic activity in the U.S. The Alliance believes that fintech can be a positive force in expanding access to capital to small business owners who have long been excluded from or marginalized in our capital markets. However, it is imperative that the continued growth of this promising, yet nascent, industry is not stymied by a few bad actors that utilize exploitative methods to take advantage of unsuspecting entrepreneurs. Rather, there should be a commitment to making fintech a safe, predictable, and cost-effective means of finance for our nation’s entrepreneurs. We look forward to working with you in meeting that goal.

Triangle Entrepreneurial Leadership Awards Lenwood V. Long, Sr., with the Lifetime Achievement Award 

The Triangle Entrepreneurial Leadership (TEL), a regional leadership network that empowers business owners in Raleigh/Durham, has awarded Lenwood V. Long, Sr., with the Lifetime Achievement Award, in recognition of his work in supporting Black entrepreneurship for over 30+ years.

Mr. Long is the cofounder and President & CEO of the Alliance, a membership-driven intermediary organization that aims to: build the capacity of member organizations; build bridges to economic stability, well-being, and wealth for Black individuals, families, and communities; and build power in Black communities by challenging and influencing financial sectors to operate more equitably.

Mr. Long has expertly directed organizations through periods of transformational growth and strategic shifts. He is especially noted for his work with African American small businesses, women entrepreneurship, veterans, and Historically Black Colleges and Universities.

Since the establishment of the Alliance in 2018, Mr. Long has more than doubled its membership, has received funding support from 17 banks, public and private foundations, and corporations, and has played an active role in promoting policies, practices, and programs to close the racial wealth gap nationwide.     

Mr.  Long previously served as CEO of Carolina Small Business Development Loan Fund, a North Carolina CDFI loan fund, before retiring in 2019.  He has more than 30 years of experience in community economic development, human resources, and business management. He has held leadership positions in a variety of organizations, including statewide economic and community development agencies, national consulting firms, and nonprofit organizations. Mr. Long also served as the Minority Affairs Assistant in the office of former North Carolina Governor James E. Holshouser and as the Chief of Staff for former congresswoman Eva M. Clayton. 

The Lifetime Achievement Award will be presented at TEL’s Inaugural YBE Awards Luncheon and Symposium on April 30, 2022 at the Life Enrichment Center located at 3805 Tarheel Club Rd, Raleigh, NC 27604. For more information, visit

Juneteenth: The Struggle Continues

About six months after the 13th amendment was adopted into the constitution, enslaved Black Americans in Galveston, Texas, were the last to be notified of their freedom on June 19, 1865. This hallmark moment when slavery officially ended would later become an annual celebration called Juneteenth.  

For many, Juneteenth is a day to remember, reflect, and recommit to the fight for freedom and racial equality. But how can we celebrate freedom when freedom is not equally experienced by all people. We are still facing racial injustice on so many levels, and our celebration will not be complete until all people are able to enjoy the constitutional freedoms that we thought were ours one hundred and sixty-five years ago. Silence is a luxury that we simply can’t afford. The most recent uprisings have led many organizations and communities to take action and join the fight against racial injustice. Let us move forward boldly, unafraid, and as one voice. 

We are still living in an era of “should.” Access to capital and business success support should not be racialized, but it is.  Exponential wealth growth for Black families should be a demonstrated priority for all CDFIs, but it is not. Federal policy should create accountability for the targeted support of those historically locked out of the labor and business markets, but it fails to do so. The Community Reinvestment Act should require banks to report the race of those receiving mortgage and small business & consumer loans, but the moral courage to do so is lacking. African American CDFI CEOs should have greater access to the support necessary to meet the financial needs of the communities they serve, but they do not. Black homeownership rates and equity should be growing, but they are shrinking. [Source] 

We have a lot of work to do. But we are stronger together. At the Alliance, we fight every day to close the racial wealth gap that persists in Black communities. We believe in redesigning systems to benefit those who are most marginalized. Our policy efforts are the central hub for voicing support for and influencing public policies that respond to the urgent needs of the CDFI CEOs, their institutions, and the communities they serve. We ensure that all Black communities have full and fair access to equitable financial tools, to build prosperity and wealth. We hold finance sectors accountable to equity in their leadership, capital flow, and in the impacts in Black communities.

As you go into the week, I invite you to reflect on what Juneteenth means to you and how you can dismantle racial and systemic barriers in your community. Yes, let’s celebrate the work of Black Americans who have made this a more just and equal country. But ask yourself: what can you do today to make a difference in your community?

In honor of Juneteenth, we are closed on Monday. I hope you have a reflective week ahead and continue to fight for our freedom, intentionally and passionately. My prayer is that we unite to Fight the Good Fight against the evils of systematic racism, inequality, inequity and injustice.


Be Steadfast!


Lenwood V. Long, Sr.

It Takes Community: Building Financial Prosperity for All: An Interview with James H. Bason, President and CEO of TruFund Financial Services

As communities across the country face an unprecedented economic landscape, the need for community centered leadership has never been greater. The impact of historical divestment in communities of color has only been exacerbated by the COVID-19 pandemic, increasing the financial burden on families, while limiting their financial security and access to financial assets. To truly address historical inequities and increase financial and business development in Black and Brown neighborhoods, it’s important to remember that “a community is only as strong as those who are willing to serve it.” That is the resounding message we learned from our conversation with James H. Bason, President and CEO of TruFund Financial Services.

A lifelong New York resident, James Bason graduated from SUNY Oswego University with a degree in business administration before attending the American Institute of Banking, where he received a degree in banking and financial services after which he earned a master’s degree in Nonprofit Management and Leadership from Fordham University. Pursuant   to his education, James spent 30 years in the private lending field, first with Barclays Bank International and then with the Bank of New York’s divisional credit team on Wall Street, James transitioned to community development lending, putting him at the forefront of conversations and protest regarding the failure of banks to invest in low-income communities. During this time, he became passionate about equal access to capital and through hands on experience, learned more about the day-to-day realities of communities that had been excluded from the financial sector and were starving for greater investment and business opportunities. He later joined Carver Federal Savings Bank, in Harlem, NY the nation’s largest black owned financial institution in the nation. where he led the bank’s lending, credit, and loan servicing operations. Working in Harlem, Queens, Brooklyn, and the Bronx with a majority Black and Brown client base, it became readily apparent that the perception that Black and Brown communities were “riskier investments” couldn’t be further from the truth. These experiences provided James with a clearer understanding of what it takes to serve Black and Brown people, and eventually guided him to his current position as President and CEO of TruFund Financial Services.

James became President and CEO of TruFund in 2011 and had an immediate impact in the CDFI space. TruFund provided James with a new platform to look “beyond perceived credit risk and profitability and consider the quality of financial assets.” Over time TruFund developed a reputation as an effective bridge between capital lending, grants, philanthropy and Black and Brown Communities. The economic impact of the COVID-19 pandemic and the greater attention placed on racial disparities, exemplified the need for TruFund’s leadership and guidance, as more institutions and organizations shifted their focus to investing in Black and Brown communities. Trufund has a long track record of providing emergency relief to small businesses, assisting with the economic recovery from the 9/11 World Trade Center Attacks, Hurricanes Katrina and Rita the 2010 BP Oil spill, and Hurricane Sandy. In 2020, the organization activated their disaster response unit, and began providing small business owners with financing through loans and grants as well as virtual business trainings. As of Feb. 28, 2022, TruFund had approved “approximately $232 million in small business loans to over 3,500 small businesses”. Approximately 84% of these loans were granted to minority-owned and women-owned businesses, or to borrowers located in low- or moderate-income communities.

TruFund, in July 2020, in partnership with Morgan Stanley and the Ford Foundation, launched a $26 million dollar Impact Developer Fund (“IDF”), IDF was established to provide equity capital and technical support to   established BIPOC real estate developers actively pursuing affordable housing development opportunities. In October 18, 2021, TruFund  in partnership with the Community Perseveration Corporation a New York State affordable housing lender, launched the  Developers Equity FundThis $6 million dollar fund “ which will similarly  provide equity capital and technical assistance to smaller emerging  BIPOC housing developers who  lack access to affordable capital and support from conventional sources”.    

For James, evolution and adaptability is key. “The current social moment and the racial awakening that took place during the summer of 2020 has provided us with an opportunity to bring our voices,” he said. “We can offer our years of experience and take this opportunity to structure a strategy for capital deployment to Black and Brown people and low-income communities.”

Additionally, advocating for policies that prioritize capital investment outside of the traditional debt structure, such as patient capital and equity-based structures can provide greater opportunities to people who “can’t afford to add any additional debt to their balance sheets.” By focusing on community and addressing uneven economic development, capital can be transformed from a historical barrier to a tool for investment and building long term wealth. As a member of the African American Alliance of CDFI CEO’s, James’s efforts with TruFund are amplified and the organization provides a collective voice, allowing African American CEOs to form a unified front when speaking on issues of racial equity, affordable housing, and economic justice. With the African American Alliance “Black CEOS have moved from the power of one to the power of the collective.,” said James. “It has given us greater recognition for our work, empowered us to be agents of change in our communities, and helped us engage in the national conversation around economic and social inequities and the need for change.”

As our country looks towards economic recovery from the COVID-19 pandemic, the need for organization, advocacy, and leadership regarding economic justice and racial disparities has never been clearer. Executives like James Bason, not only offer a wealth of experience but also a commitment to service that goes beyond personal accolades and touches the roots of financial insecurity and historical exclusion from the financial marketplace. The path towards economic prosperity for all requires individuals and organizations to make equitable access to capital a priority, while bringing Black and Brown communities to the forefront of economic development.

The Alliance and Pacific Community Ventures Join Forces to Advance Racial Justice in the CDFI Industry

e-centering Civil Rights and Increasing Accountability to BIPOC Communities in the CDFI Industry

March 8, 2022 – The African American Alliance of CDFI CEOs (“The Alliance”), and Pacific Community Ventures (“PCV”) announced today they entered a partnership to recenter Civil Rights within the CDFI industry and elevate industry practice, through policy changes, to ensure CDFIs work toward racial equity and economic justice with greater intentionality, transparency, and accountability to their communities, meeting the mission for which our industry was born to address out of the Civil Rights movement. 

 At large, the CDFI industry has fallen short of serving their founding purpose of closing systemic gaps in capital access for Black and Brown communities because their lending strategies are too closely tied to SBA guidelines or the financial incentives of their investors and traditional bank funders – for example, most Black entrepreneurs have credit scores, or collateral, below SBA and bank minimum requirements. These entrepreneurs often turn to CDFIs to serve their capital needs: Nearly two-thirds of borrowers of CDFIs that serve small businesses are people of color.  But with just over 70% of CDFIs reporting serving people of color, we still have a long way to go. 

“We see an urgent need within the CDFI industry, where CDFIs are uniquely positioned to break down barriers and capital access for BIPOC communities. Our partnership with PCV will help us to change the odds and outcomes for these communities by building greater accountability and greater impact where it is needed,” said Lenwood V. Long, Sr, President / CEO of The Alliance. 

With the support of a grant from the Tipping Point Fund, PCV formalized a year-long partnership with the Alliance to develop an agenda centering Civil Rights within the CDFI industry. Both organizations will collaborate by building a coalition of community investing stakeholders committed to advancing policies that recenter racial justice within the CDFI industry, as well as advance a set of policy priorities that reform the CDFI Fund and rethink industry practices.  

PCV and the Alliance will hold a series of roundtables this year that bring together government officials, CDFI leaders, and industry thought leaders to discuss how we can better center racial justice within the mission of the CDFI industry, and to draft research and policy proposals out of those conversations. The first roundtable will be held on April 5, 2022 and will focus on updating the Community Reinvestment Act to better serve BIPOC communities. The 1977 Community Reinvestment Act (CRA) is the landmark law designed to encourage lending to lower-income borrowers and to end redlining. 

“We need to take this opportunity to break with the past and create systems that meet business owners of color where they are – and that’s exactly what Pacific Community Ventures is committed to working with The Alliance as we move toward restorative capital that empowers small businesses and creates good jobs with dignity across America, with missions firmly rooted in the Civil Rights movement that gave birth to CDFIs in the first place,” said Bulbul Gupta, President & CEO of Pacific Community Ventures. 

About The African American Alliance of CDFI CEOs

The African American Alliance of CDFI CEOs (The Alliance) is a coalition of 58 CEOs of Black-led Community Development Financial Institutions (CDFIs), comprising loan funds, credit unions, venture capital firms, and non-profit developers. Since 2018, The Alliance has represented all 50 states and the District of Columbia. As a result, members are uniquely positioned to address issues related to housing and access to capital for African American populations and communities. Learn more about the Alliance and initiatives at

About Pacific Community Ventures

Pacific Community Ventures supports small business owners and their communities in the fight for economic, racial, and gender justice. We work side-by-side with growing small business leaders and solopreneurs through our integrated model: combining impact-first Restorative Capital and Pro Bono Business Advising with our Good Jobs Innovation Lab that propels thriving communities with equitable jobs. Pacific Community Ventures is a 501c3 nonprofit impact investor and community development financial institution (CDFI).

Our Strategic Plan: Building a Better Future for Black America

I’m excited to announce the launch of our strategic plan, designed to mobilize and amplify advocacy, prosperity, and wealth for Black communities and leaders of Black-led Community Development Financial Institutions (CDFIs). 

Our goal is to build a future where Black-led CDFIs are resource-rich and unrestricted in their ability to be catalysts for economic mobility, prosperity, and wealth building for Black families and communities. To help us design an actionable path forward, our board, members, staff, and other invested stakeholders, underwent a 14-month intensive process to develop our three-year strategic plan.

Rooted in an analysis of the nature and impact of economic exclusion of Black-led CDFIs, Black families and Black communities, and the multitude of interventions required to close the racial wealth gap, we are guided by three pillars:

Building Capacity

  • Expand Financial Capacity of Members through Collective and Cooperative Strategies
  • Strengthen Technological and Operational Capabilities of Member Institutions
  • Build a More Robust Human Capital Pipeline for Black-Led CDFIs
  • Develop a Culture of Learning and Support for Black-Led CDFIs

Building Bridges

  • Amplify the financial preferences and needs of Black communities to inform product development, marketing, research, and policy action
  • Expand AAA members’ ability to offer a slate of financial products and services that prevent wealth-stripping and lead to full financial inclusion for African Americans.
  • Increase the number of regions and market segments served by Black-led CDFIs.

Building Power

  • Amplify the narrative of Black CDFI leaders as key actors and power brokers within the racial economic-justice ecosystem becoming a Racial Economic-Justice Ecosystem Influencers.
  • Hold Community Development Finance Sector Investors Accountable to Proportionate Investment in Black CDFIs.
  • Support and Advance Public Policies and Advocacy Efforts That Benefit the Stabilization and Growth of Black-led CDFIs

The three pillars resulted in the revision of our mission statement to the following:

AAA is a membership-driven intermediary organization that aims to: build the capacity of member organizations; build bridges to economic stability, well-being, and wealth for Black individuals, families, and communities; and build power in Black communities by challenging and influencing financial sectors to operate more equitably.

In addition, we’ve added six passionate and talented individuals to our team, in various positions. You can meet them here.

In the next few months, we’ll continue to implement our strategic plan with a brand refresh and a focus on growing our ecosystem for Black communities. I am excited to join you in bringing this plan to life by releasing the work that we’re doing for Black communities.

Be Steadfast!


Lenwood V. Long, Sr. President & CEO, The Alliance

The Alliance Welcomes 6 New Staff Members

The African American Alliance of CDFI CEOs (The Alliance) has been working towards amplifying the priorities and voices of Black-led CDFIs, Black families, businesses, institutions, and communities since its founding in 2018. With over 56+ members across the nation, we believe that advocacy will drive a shift in both the financial sector and national policy that result in Black stability, prosperity, and wealth.

Our goal is to build a community of support and uplift Black CDFI CEOs by providing them access to learning opportunities designed to develop more impactful and sustained CDFIs.

 As part of growing our impact across the nation in this New Year, The Alliance is excited to announce the addition of 6 passionate and talented individuals as new members of our team. Please join us in welcoming them and get to know them below:

Angela Milton serves as Membership Director. In her role, Angela is responsible for building member capacity, collecting and sharing best practices and membership engagement. She works closely with the President/CEO to plan, coordinate, and manage the creation of high-quality training activities for the members. Formerly an enlisted member of the U.S. Air Force, Angela has been an entrepreneur for more than 20 years, experienced in leadership, relationship-building, organizational development, project management, and implementation. She has numerous certifications and licenses and produced measurable results for her clients and in this role.

Charmaine Grafton serves as Executive Assistant and Office Manager. In her role, she ensures the smooth operation of the organization with her robust knowledge of office management and efficient handling of administrative tasks as well as her role as “The Gatekeeper” for the President/CEO. With over a decade of experience in professional office executive assistant positions, Charmaine skillfully manages administrative duties. Outside of work, Charmaine is active in the community and volunteers her time with several nonprofits that focus on youth, single moms, and housing insecurities. She’s also founded Sacred Beautè, where her vision is a world where single moms are fully empowered and self-sufficient.

Chavelle Sangokoya serves as Project Director. Driven by her passion for economic development and racial equity, Chavelle is responsible for leading The Alliance’s Women-led Initiative as well as the African American Equity Scorecard. Over the past seven years, she has effectively facilitated focus groups and working sessions with community stakeholders and entrepreneur support organizations (ESOs) to collaboratively build solutions to advance diversity, equity, and inclusion in entrepreneurship. Leveraging her business operations and management background, Chavelle has designed and evaluated curriculum for early-stage entrepreneurs and launched a flagship rewards program that incentivizes Black entrepreneurs to work on their business and engage in local entrepreneur ecosystems.

Eleanor Reid serves as Development Director. In her role, Eleanor leads the fundraising efforts for AAA including grant writing, relationship building, and reporting. She has extensive grant writing experience among her more than 20 years of C-level consulting work including the successful raise of more than $30 million for a CDFI from a variety of public and private sources. She also served as COO for a NY-based blockchain company and partner for a boutique investment advisory firm. Eleanor holds a B.S. in Metallurgical Engineering from Carnegie Mellon and MBA from Stanford University.

Janice Rojas serves as Marketing & Communications Director. Bringing over 8+ years in marketing, Janice is passionate about storytelling, Janice takes on The Alliance’s marketing strategy efforts, content development, social media management, and elevating the organization’s impact. Prior to The Alliance, she led marketing efforts at several organizations, including Girl Scouts – N.C. Coastal Pines, Carolina Small Business Development Fund, and worked in internal communications at Blue Cross Blue Shield NC. Janice attended the University of North Carolina at Chapel Hill, where she obtained a Bachelor of Arts in Journalism and Mass Communication with a concentration in Public Relations. When she’s not working, Janice enjoys reading contemporary fiction and nonfiction, journaling, and writing her own novels.

Ryan Gremillion serves as Policy & Research Director. In his role, he drives strategic initiatives and coalition building aimed at enhancing community and economic development, business growth, wealth creation, and financial protections in African American communities, particularly through the organization’s public policy activity. A native of Louisiana, he previously served as the Chief of Staff for the Office of Legislative Affairs, Policy and Workforce Support at the Louisiana Department of Education (LDE). Gremillion was a key figure in developing and implementing the regulatory and legislative strategies for both the LDE and its governing board, the Louisiana Board of Elementary and Secondary Education (BESE). Prior to his LDE tenure, he served as Policy and Research Project Manager at the Baton Rouge Area Chamber where he managed policy issues related to entrepreneurship and small business, regional transportation, healthcare, and criminal justice.