A message from Lenwood V. Long, Sr. on the death of Tyre Nichols

We are heartbroken and overwhelmed by the tragic and wholly unnecessary beating and death of Tyre Nichols.  

Tyre Nichols was a young, healthy Black man. He was a father to his four-year-old son and a great friend to many. Tyre worked alongside his stepfather at FedEx and during his downtime, enjoyed skateboarding and photography. Tyre’s life was special, layered, and cut short by senseless police brutality. A pattern that keeps repeating in the streets of America. 

For far too long, the Black community has been subjected to police brutality and racial profiling at an alarming and disproportionate rate. This has led to an increase in the number of deaths caused by law enforcement officers, the very people who pledged to protect us. We have not come far enough since the beating of Rodney King, the death of Breonna Taylor, or George Floyd’s killing. The system is broken, and we must collectively fight for humanitarian reform. We must act now before another life is taken away. 

When we talk about police brutality, it’s important to remember that this isn’t just a problem for Black people. It’s a problem for everyone who cares about justice and human rights. 

We all need to work together to callout and eliminate anti-Blackness in all aspects of law enforcement so that the system no longer devalues and criminalizes Black people, and instead protects and serves Black communities.    

At the Alliance, we are committed to addressing systemic oppression in order to ensure rights and life for Black people. We call on law enforcement, legislators, and policymakers to come together urgently to enact reforms that will preclude such tragedies from occurring in the future.  

We will not stop standing up and speaking up for economic and social justice for Black people and Black communities.   

Martin Luther King, Jr. stated “Law and order exist for the purpose of establishing justice and when they fail in this purpose, they become the dangerously structured dams that block the flow of social progress.” 

We will not stop fighting. 

Lenwood V. Long, Sr.

Response to Proposed Rulemaking on Small Business Lending Company Moratorium Rescission and Removal of the Requirement for a Loan Authorization

January 3, 2023

Dianna Seaborn

Director, Office of Financial Assistance, Office of Capital Access

U.S. Small Business Administration

409 3rd St, SW.

Washington DC 20416

Re: RIN 3245-AH92—Small Business Lending Company (SBLC) Moratorium Rescission and Removal of the Requirement for a Loan Authorization

Dear Ms. Seaborn:

On November 7, 2022, Volume 87, No. 214 of the Federal Register contained a Notice of Proposed Rulemaking on Small Business Lending Company (SBLC) Moratorium Rescission and Removal of the Requirement for a Loan Authorization (87 FR 66963).[1]  The proposed rule, if implemented, will lift the moratorium on licensing new Small Business Lending Companies (SBLCs), add a new type of entity called a Mission-Based SBLC, and remove the requirement for a Loan Authorization.

The African American Alliance of CDFI CEOs (the Alliance) is pleased to provide the following comments in response to the Proposed Rulemaking, 87 FR 66963. The Alliance 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. Since launching in 2018, the Alliance has established a network of 72 CEOs of Black-led Community Development Financial Institutions (CDFIs), which includes loan funds, credit unions, and venture capital funds. Alliance members reach historically underserved communities in all 50 states by providing financial services in the small business, affordable housing, and commercial real estate development sectors.

SBLC Moratorium Rescission

The SBA Proposed Rule lifts the moratorium on licensing new SBLCs and creates a new type of SBLC, the Mission-Based SBLC, to fill identified capital market gaps and provide targeted financial assistance to underserved markets.[2] The Alliance generally agrees with the intent of the Proposed Rule, as it purports to afford vulnerable entrepreneurs in markets historically overlooked by traditional financial institutions an opportunity to obtain critical financing on non-predatory terms. However, we urge SBA to provide additional clarification around some of the key pieces of the Proposed Rule, particularly as it relates to the conversion of existing Community Advantage lenders to Mission-Based SBLCs.

  1. Lack of Specificity Around Certain Aspects of the Proposed Mission-Based SBLC Designation

Costs Associated with Obtaining Mission-Based SBLC Status

The Small Business Act authorizes SBA to charge a fee for conducting safety and soundness examinations of SBA-Supervised Lenders. As such, prospective SBLCs – both regular and Mission-Based – will be subject to a minimum $10,000 initial safety and soundness examination at the time of application and at least once every two years thereafter.[1] Additionally, SBA will conduct targeted reviews of loan files in between the regularly scheduled safety and soundness exams, at a biennial cost of $50,000 to $150,000 per SBLC depending on the size of its loan portfolio.[2]

Currently, each SBLC that makes or acquires a 7(a) loan must maintain at least unencumbered paid-in capital and paid-in surplus of at least $5 million, or 10 percent of the aggregate of its share of all outstanding loans, whichever is greater.[3] SBA considered extending the $5 million capitalization requirement to prospective Mission-Based lenders but ultimately determined that such a requirement would limit the number of entities that would be eligible for an SBLC license.[4] Instead, per the Proposed Rule, “a Mission-Based SBLC must maintain a minimum amount of capital at the discretion of the Administrator in consultation with SBA’s Associate Administrator for SBA’s Office of Capital Access (AA/OCA), to ensure sufficient risk protection for SBA and lenders while not burdening smaller lenders with large capital requirements.”[5] The costs associated with safety and soundness examinations and targeted reviews compounded by the ambiguity surrounding Mission-Based SBLC capital requirements concerns the Alliance. We urge the SBA to avoid the adoption of any Mission-Based SBLC capital requirements that would dissuade institutions, including existing Community Advantage lenders, from pursuing a Mission-Based SBLC designation.

Mission-Based Lending Requirements Per the Proposed Rule, Mission-Based SBLCs will be subject to all the requirements imposed on regular SBLCs and SBA Supervised Lenders.[6] In addition to those requirements, the Proposed Rule requires that a certain percentage of a Mission-Based SBLCs loans be dedicated to filling an identified capital market gap.[7] However, in lieu of a uniform mission-based lending requirement applicable to all Mission-Based SBLCs, SBA will determine on a case-by-case basis the minimum acceptable percentage of loans that a Mission-Based SBLC must make in identified capital market gaps, maximum loan size, geographic area of operation, and capitalization. The Alliance has strong concerns that the lack of specificity around key concepts of the Proposed Rule (i.e., types of capital market gaps that will be sufficient to satisfy Mission-Based SBLC requirements, percentage of loans that must be made to fill identified capital market gaps, maximum loan size, application process, etc.) makes it difficult for existing Community Advantage lenders and other prospective Mission-Based SBLC applicants to determine if conversion to a Mission-Based SBLC is a prudent option for their institution. The Alliance also finds it troubling that for-profit institutions seeking regular SBLC status, unlike their mission-based counterparts, will not be required to dedicate a certain minimum amount of lending to filling identified capital market gaps, as this runs counter to the underlying aim of the Proposed Rule – i.e., increased and targeted lending to underserved capital markets. Though the individualized approach outlined in the Proposed Rule affords Mission-Based SBLCs a certain level of operational flexibility and reduced risk exposure, the Alliance fears that the absence of similar guardrails for the three new regular SBLCs proposed by SBA will not result in increased access to financing in undercapitalized markets.

  1. Proposed Rule Impact on Community Advantage Pilot Program

The Alliance’s general support of the SBLC proposal should not be construed as dissatisfaction with the Community Advantage Pilot Program. In fact, the Alliance was pleased to collaborate with SBA on the recent reforms to the Community Advantage Program adopted in 2022, including, but not limited to: (1) the extension of the pilot program through September 30, 2024; (2) the lifting of the four-year lender moratorium on new CA Lender participation applications; (3) the increase to the maximum CA loan size from $250,000 to $350,000; (4) the simplification of underwriting and collateral requirements for borrowers and lenders; (5) the allowance for lenders to make revolvers and lines of credit, interest-only periods, and other loan modifications that meet borrowers where they are to best serve their capital needs; and (6) the removal of restrictions that can keep individuals with criminal backgrounds from accessing the CA program.[1]

The Alliance firmly believes that the CA program can be a viable option for increasing lending volume in underserved markets. However, though the reforms of 2022 were greatly appreciated, the program must continue to evolve. Additional reforms to strengthen the CA program – e.g., the immediate extension of the program beyond the current program sunset of September 30, 2024; expansion of program eligibility to businesses owned and controlled by women and minorities; provision of technical assistance (TA) grants for CA lenders; reduction in the minimum CA program SBSS score from 140 to 130, etc. – will prove instrumental in attracting new lenders to the program to meet the growing demand for affordable capital in underserved communities. Ultimately, a strengthened CA program operating in concert with the proposed Mission-Based SBLC concept will result in a significant increase lending activity in underserved communities, particularly for the 51 percent of small employer firms with unmet financing needs.[1]

* * *

Removal of Requirement for Loan Authorization

Currently, the 7(a) Loan Program, including the Community Advantage Pilot Program, and the 504 Loan Program require a Loan Authorization providing the terms and conditions under which SBA will make or guarantee business loans.[1] The terms and conditions of each loan are also submitted into E-Tran by the SBA lender through the submission of the loan application data and conditions.[2] SBA proposes to remove the requirement for a Loan Authorization as a required document for 7(a) loans and instead rely on the use of the terms and conditions of the loan application as submitted by the SBA lender into E-Tran.[3]

The Alliance generally agrees with SBA’s assertion that the current process to capture the loan terms and conditions through the Loan Authorization is time-consuming, cumbersome, and duplicative. However, we do not support the elimination of the Loan Authorization requirement at this time. Lenders have come to rely upon Loan Authorizations as a means of validating that they have satisfied all requirements at or prior to closing of the loan. As such, the elimination of the Loan Authorization requirement could potentially lead to increased instances of Lender non-compliance.

* * *

The Alliance shares SBA’s goal to better meet the needs of America’s small businesses, create jobs, assist with recovery from the COVID-19 pandemic, and grow the economy, fueling American entrepreneurship, particularly in communities of color served by Alliance members. The Alliance looks forward to continued dialogue with SBA to develop a long-term solutions to combat capital market gaps through a strengthened Community Advantage Program working in unison with SBLCs, both regular and Mission-Based.

Thank you once again for the opportunity to comment.

Sincerely,


[1] Small Business Lending Company (SBLC) Moratorium Rescission and Removal of the Requirement for a Loan Authorization, 87 Fed. Reg. 66,967 (Nov. 7, 2022).


[1] “Biden-Harris Administration Expands SBA Pilot Program Targeting Access to Capital for Underserved Entrepreneurs.” U.S. Small Business Administration, March 30, 2022, www.sba.gov/article/2022/mar/30/biden-harris-administration-expands-sba-pilot-program-targeting-access-capital-underserved. Press Release.


[2] Id.

[3] Id.at 66,965.

[4] Id. at 66,969.

[5] Id. at 66,965.

[6] Id. at 66,965.

[7] Id. at 99,964.


National BIPOC Coalition Urges Minority Community Financial Organizations’ Participation in Greenhouse Gas Reduction Fund

Community Builders of Color Coalition comment on implementation of EPA’s Greenhouse Gas Reduction Fund and propose that minority led CDFIs can meet the demand for green energy funds 

[Orlando, FL. 12/8/2022] Nine BIPOC organizations of the Community Builders of Color Coalition (The Coalition) urge the U.S. Environmental Protection Agency (EPA) to ensure that minority communities can benefit equally from the Greenhouse Gas Reduction Fund (GHGRF) as authorized by the Inflation Reduction Act. The Coalition advocates for equity in all aspects of the GHGRF implementation, and that at least 40% of awarded capital goes to community financial institutions such as CDFIs, MDIs and credit unions. 

The Coalition, a group of nine organizations led by the African American Alliance of CDFI CEOs (The Alliance), provides comments in response to EPA’s request for information regarding implementation of the GHGRF. The Coalition urges that effective implementation of GHGRF requires a thorough understanding of underserved communities and the types of clean energy projects they will find most beneficial. 

“Climate and environmental effects are not an intangible threat to the U.S. Latino population. A 2021 study cited that 71% of U.S. Hispanic adults say climate change is affecting their local community (vs. 54% of non-Hispanic adults). In considering how EPA Greenhouse Gas Reduction Funds are allocated, there must be a concerted effort to tap organizations that are entrenched in brown and black communities. These organizations are uniquely and best positioned to reach the very populations that are most negatively affected by environmentally detrimental offenses.” – Marla Bilonick President and CEO, National Association for Latino Community Asset Builders.  

With their success in deploying critical capital to disadvantaged communities, minority-led Community Development Financial Institutions (CDFIs) are well-positioned to operationalize GHGRF funds for developing green energy projects in communities typically overlooked for climate investments. The GHGRF provides CDFIs with the opportunity to diversify their lending portfolios and meet the demand for clean energy solutions in low-income and disadvantaged communities. 

“Minority and underserved communities are often more vulnerable to the harmful impact of climate change. Our banks serve communities that are 77% a minority, providing financial support and access to much-needed resources. As we create a more equitable future, it’s long overdue that financial backing goes to deeply-rooted organizations that have historically served minority communities.”  – Nicole Elam Esq., President and CEO of the National Bankers Association. 

Additionally, the Coalition strongly recommends that the EPA explicitly make all certified CDFIs, FDIC-insured Minority Depository Institutions (MDIs), and credit union MDIs eligible participants and that the EPA uses an equity lens in implementing GHGRF and prioritize those applications where all members of the coalition are committed to projects that both reduce CO2 emissions and are committed to equity goals. Finally, the funding should be allocated to multiple community financial institutions such as CDFIs, MDIs and credit unions.  

“We firmly believe that the best strategy to effectively confront racial inequities and climate change in our country is to ensure local, community-based organizations led by people of color in partnership with organizations such as those represented by this coalition lead the implementation and deployment of the historic levels of capital and federal resources. Collectively, we have the relationship and social infrastructure in place that are necessary to successfully achieve the program goals,” – Seema Agnani, Executive Director, National CAPACD. 

The Coalition is comprised of nine member organizations below: 

“This alliance of Black and Brown led CDFI organizations, collectively serving underrepresented African American, Latino, Native and AAPI entrepreneurs, has not only demonstrated that we are able to come together and work together, but by doing so we are communally best positioned to mitigate outcomes for the communities most impacted by environmental catastrophe caused by greenhouse gases.”- Gary Cunningham, President and CEO, Prosperity Now. 

“Green energy solutions are often out of reach for Black communities. The Alliance seeks to level the playing field by working with a coalition that understands the Greenhouse Gas Reduction Fund’s potential to scale climate investments in Black and Brown disadvantaged communities. The Coalition is eager to use its unique expertise to help ensure that the GHGRF will have the greatest possible impact in low-income and disadvantaged communities and ensure it is implemented equitably.” – Lenwood V. Long, Sr., President and CEO, The Alliance. 

“As financial cooperatives, CDFI and MDI credit unions design solutions to be responsive to their local economies and to meet the needs of people who have been excluded from the mainstream financial system.  Equitable solutions to reduce greenhouse gas emissions must be grounded in scaling local solutions at the national level.” – Cathie Mahon, President and CEO, Inclusiv.

“As place-based peoples, Native communities are on the front lines of climate change, disproportionately feeling its effects more broadly and severely than most other Americans. From California to Louisiana to Arizona to Alaska, increased wildfires, pervasive drought, flooding, ocean acidification, and sea level rise already are devastating tribal economies and ways of life, impacting Native agriculture, hunting and gathering, fisheries, forestry, energy, recreation, and tourism enterprises. It is imperative that EPA’s Greenhouse Gas Reduction Funds allocate adequate funds to tribal governments and Native organizations that are proportional to the vast geographic extent of tribal lands and the gravity of the climate challenges Native communities face.” – Pete Upton, Interim CEO, Native CDFI Network. 

To learn more about the Alliance’s GHGRF advocacy efforts, please visit www.aaacdfi.org. For the full EPA response for feedback submitted by the Coalition, click here. 

### 

About The African American Alliance of CDFI CEOs  

The African American Alliance of CDFI CEOs (The Alliance) is a coalition of more than 70 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 its programs at http://www.aaacdfi.org

Greenhouse Gas Reduction Fund: Minority-Led CDFIs Aim to Make Green Investments 

The Alliance, NALCAB, Alliance to Save Energy propose that minority led CDFIs can meet the demand for green energy funds 

[Orlando, FL. 11.8.2022] – The African American Alliance of CDFI CEOs (The Alliance), in partnership with Alliance to Save Energy and NALCAB, urge the Environmental Protection Agency (EPA) to ensure that minority communities can benefit equally from the Greenhouse Gas Reduction Fund (GHGRF). In its joint comments, the Alliance advocates for equity in all aspects of the GHGRF implementation, and that at least 40% of awarded capital goes to non–depository community lenders.  

With their success in deploying critical capital to disadvantaged communities, minority-led Community Development Financial Institutions (CDFIs) are well-positioned to operationalize GHGRF funds for developing green energy projects in communities typically overlooked for climate investments. The GHGRF provides CDFIs with the opportunity to diversify their lending portfolios and meet the demand for clean energy solutions in low-income and disadvantaged communities. 

“Green energy solutions are often out of reach for Black communities. The Alliance seeks to level the playing field by building a coalition that understands the Greenhouse Gas Reduction Fund’s potential to scale climate investments in disadvantaged communities. It is crucial that these communities are positioned to maximize this opportunity. As members of the communities they serve, Alliance members can address the unmet need for green investments in these communities and ensure the GHGRF is implemented equitably.” – Lenwood V. Long, Sr., President & CEO of The Alliance. 

“The GHGRF provides a once in a generation opportunity for green investment in low-income and disadvantaged communities, and it’s critically important to ensure that the funding for this initiative also goes to community lenders who are representative of and embedded in the communities they serve,” said Paula Glover, President of the Alliance to Save Energy. “Energy equity and affordability are essential to ensuring a just energy transition and it’s our duty to make certain that BIPOC communities are able to access vital funding for transformational energy efficiency, zero emissions, and climate resiliency projects.” 

“NALCAB applauds the creation of the GHGRF, a first of its kind program to help further environmental justice by providing competitive grants to support projects that reduce greenhouse gas emissions particularly in low income and disadvantaged communities. We look forward to working with the Environmental Protection Agency (EPA) in ensuring equity in the program’s implementation.”- Marla Bilonick, President and CEO, NALCAB 

To become a member of The Alliance or for more information about the GHGRF comment letter and our advocacy efforts, please visit www.aaacdfi.org. 

### 

About The African American Alliance of CDFI CEOs  

The African American Alliance of CDFI CEOs (The Alliance) is a coalition of more than 69 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 its programs at http://www.aaacdfi.org

About NALCAB 

The National Association for Latino Community Asset Builders, NALCAB, is the hub of a national network of more than 190 mission-driven organizations in 45 states, DC and Puerto Rico that serve ethnically diverse Latino communities across the US. Members of the NALCAB Network invest in their communities by building affordable housing, addressing gentrification, supporting small business growth, and providing financial counseling on issues such as credit building and home ownership. Our mission is to strengthen the economy by advancing economic mobility in Latino communities. As a grant maker and US Treasury-certified CDFI lender with offices in San Antonio and Washington DC, NALCAB serves hundreds of thousands of low- and moderate-income people, advancing economic equity and inclusivity. 

About the Alliance to Save Energy 

Founded in 1977, the Alliance to Save Energy is a nonprofit, bipartisan alliance of business, government, environmental and consumer leaders working to expand the economy while using less energy. Our mission is to promote energy productivity worldwide – including through energy efficiency – to achieve a stronger economy, a cleaner environment and greater energy security, affordability, and reliability. 

Response Letter: $200M SSBCI Technical Assistance Opportunities for Black Businesses

 The SSBCI Black Business Working Group, which is comprised of the leaders of some of the best and brightest in the Black business policy ecosystem – including the U.S. Black Chambers, Inc., Prosperity Now, Hope Credit Union, Association for Enterprise Opportunity and the African American Alliance of CDFI CEOs takes this opportunity to respond to the Department of Treasury’s Request for Information regarding TA opportunities in the SSBCI.

Below is the response ———————————————————–

Mr. Jeffrey Stout 

Director 

State Small Business Credit Initiative 

U.S. Department of the Treasury 

1500 Pennsylvania Avenue NW 

Washington, DC 20220 

VIA ELECTRONIC SUBMISSION: Submitted to Regulations.gov (87 FR 57558) Document #2022-20326 

Re: Request for Information (RFI) on $200 million in remaining Technical Assistance funds as authorized by the American Rescue Plan Act 

Dear Director Stout: 

The SSBCI Black Business Working Group, which is comprised of the leaders of some of the best and brightest in the Black business policy ecosystem – including the U.S. Black Chambers, Inc., Prosperity Now, Hope Credit Union, Association for Enterprise Opportunity, and the African American Alliance of CDFI CEOs – appreciates this opportunity to respond to the Department of Treasury’s Request for Information regarding technical assistance (TA) opportunities in the State Small Business Credit Initiative (SSBCI). 

To miss out on this opportunity to support Black businesses would be catastrophic. Already, Black business owners are cut out of the private financial markets with the Federal Reserve finding that Black business owners are three times less likely to receive all non-emergency funding requested compared to their white counterparts. Furthermore, 80% of Black-owned businesses fail within the first 18 months of operation, primarily due to lack of adequate funding, compared to 30% of all small businesses over the same time frame. SSBCI capital can be the catalyst Black-owned businesses need to survive and thrive in the current economic landscape. 

On behalf of the hundreds of thousands of Black business owners that we represent and have in our collective network, these comments express our feedback to the RFI on the Treasury Department’s plan to disburse the remaining $200M in SSBCI TA funding. 

Other Comments: 

With the consent of the states, Treasury should publish approved state plans. 

We would be remiss if we did not strongly advise Treasury to publicly publish each state’s approved SSBCI plan. We fundamentally believe that residents of each state deserve an understanding of how the funding is being disbursed and the thinking behind those plans. Furthermore, without knowledge of what states intend to do with the funds, or promised 

Treasury it would accomplish, experts such as us are curtailed in our ability to be helpful and responsive to states that might be struggling. 

What criteria should Treasury consider in selecting recipients and sizing awards if Treasury conducted a program to provide competitive TA grants to jurisdictions? 

States currently have access to a generous amount of non-competitive SSBCI TA. We have heard from implementing partners that some states are even considering not seeking that funding. Given this, we recommend that any additional funds dispersed on a competitive basis should be highly targeted to those states that are most interested in making their SSBCI programs as equitable as possible. 

Implicit in this is a strong recommendation to not be hasty in getting the funds out the door. From our perspective, additional TA to states should be based on need and demonstrated progress made towards the SEDI goals, particularly those with greater track records of effectively meeting the needs of Black entrepreneurs. This way, we can ensure that additional TA dollars are going to those that are truly investing in the spirit and intent of the program. 

In terms of distinct criteria for evaluation of the above, we urge you to consider the following when prioritizing which jurisdictions get the additional TA funds: 

  • Jurisdictions that are committed to providing holistic wrap-around services that not only address the various levels of local small business funding needs, but also help connect business owners to free or low-cost accountants, business planning resources, legal services, and other wrap-around resources to ensure businesses have a sustained ecosystem of support. 
  • Jurisdictions that have shown a real commitment to transparency by publicly releasing demographic data – broken out by race, ethnicity, and gender, etc. – on an ongoing and reliable schedule beyond that of Treasury’s annual reports. 
  • Jurisdictions that create and publicly disseminate goals for Black business participation in programming, with plans for improvement where necessary. These goals should be on par with Black population or demonstrated Black business owner need in the state. 
  • Jurisdictions that understand the deep need for cultural competency and therefore prioritize working with Community Development Financial Institutions (CDFIs) and Minority Depository Institutions (MDIs) that can demonstrate a deep track record of meeting the needs of the State’s local Black communities. Cultural competency, or rather the ability to understand, appreciate, and respectfully interact with people from cultures or belief systems different than one’s own, has long been absent in the private, public, and even parts of the non-profit financial sectors. 
  • Jurisdictions that are working across and engaging with regional public, private, and social sectors (e.g., local government leaders, major regional industry representatives, CDFIs and local philanthropies) to understand the diverse – and sometimes conflicting – cross-sector needs and challenges that will either break or make the state’s SSBCI program long-term impact. These partners should be diverse in terms of demographics, but also perspectives and backgrounds. 
  • Jurisdictions that work with local Black communities to educate about the need for data collection, emphasizing that the collection cannot be used to harm their prospects and explaining how the information provided will be kept secure, separated from the funding decision-makers. 

What gaps exist in the types and availability of TA to small businesses that seek small business financing? 

Support across the business life cycle. Beyond discrimination in the capital markets, one of the other dampening factors on Black businesses being able to access capital at fair rates is the community’s lack of access to legal, accounting, and financial advisory firms. Despite the known linkage between business development and mentorship with business success, McKinsey and Company found that only 58% of Black business owners sought out professional advisory services, citing cost, accessibility, and mistrust as barriers. Just as these resources are critical for setting one’s personal economic success, these kinds of wrap-around services are even more critical at all stages of the business life cycle. Black-owned businesses need affordable professional advisory services provided by people and institutions that have given their local Black communities a reason to trust them. 

Analyzing different funding options. There are now more legitimate, regulated, and unique funding methods to support business startup and growth than possibly ever. One thing TA must do within the SSBCI is help Black business owners – who come from an array of backgrounds, including different socioeconomic classes and education levels – thoroughly understand the various funding options available to them to allow them to make the best, most educated decision for their business. This understanding should come in the form of financial literacy about all the options from trusted sources, provided in ways that align with styles of communication and cultural expectations unique to Black founders. 

Diversity in equity-based funding. States need to understand that “diversity investing” is good investing. Beyond this fact, when we talk about venture capital (VC) or other equity-based financing (including revenue-based financing), we often make the mistake of only viewing it from the perspective of how it will help the recipient business. The other, even more lucrative side, however, is those doing the investing – the fund managers. While VC funds continue, year-over-year, to break records in fundraising, less than 3% of VC funds employ Black and Latinx investment professionals, meaning that the success of Black-owned firms that are VC-backed will be a financial boon for white, largely male, investors. This simply reinforces the status quo. Therefore, who is investing equity capital matters almost just as much as who is receiving the investment, and states need to seriously consider this if they are looking to set up equity-based financing products through the SSBCI. Black-run equity firms are Black-run businesses and must be included in the effort to craft equity-based products that respond to Black business needs. We further encourage those states with the highest concentrations of Black Americans, which are predominantly southeastern and include Mississippi, Louisiana, Georgia, Maryland, Alabama, and South Carolina, to not only have an equity-based product as a component of their SSBCI product mix but to also take care to partner with Black-led funds in doing so. Numerous resources exist to help states tap into the depth of Black fund and finance professional talent that exists, and we at the SSBCI Black Business Working Group are happy to work with Treasury and states to make those connections. 

How can the deployment of TA funding under 12 U.S.C. 5708(e)(1) and (3) most effectively impact VSBs and SEDI-owned businesses in communities throughout the United States? 

The most effective way TA funding can be deployed in a way that truly impacts SEDI-owned businesses is to be race-conscious. We understand that programs that exist to undo the harms of past discrimination and, hopefully, lead to an equitable economy, are under attack, with many governments opting for proxies to race that, ultimately, are ineffective at reaching the goal. The fact that the wealth gap is worse now than it was during the Civil Rights Movement proves that. It is the opinion of this group that a problem that was created through explicit racial discrimination can only be rectified with solutions that are explicitly racially integrative. 

If Treasury contracted with legal, accounting, and financial advisory firms to provide TA to qualifying SEDI-owned businesses under 12 U.S.C. 5708(e)(3), what types of entities are best positioned to provide TA to address gaps in TA availability? 

As you saw above, one of our core criteria for states seeking additional, competitive TA funds is that they connect business owners to free or low-cost accountants, business planning resources, legal services, and other wrap-around resources. The data show that this is the best way to ensure businesses have a sustained ecosystem of support. 

With the prospect of Treasury directly contracting with SEDI-owned businesses that provide those services, we recommend tapping into Black-owned businesses within the 8(a) program and those certified by our member organization, U.S. Black Chambers, Inc.’s (USBC), ByBlack initiative. As a complement to certified Black-owned businesses, the entities that are best positioned to provide TA to address gaps in TA availability are those small business TA providers with expertise providing services to immigrant communities, communities of color, low-income communities and other historically excluded communities. Demonstrated expertise reaching aspiring Black entrepreneurs and very small businesses (VSBs), as well as experience advising small business owners with Individual Taxpayer Identification Numbers (ITINs), are also critical to ensure no Black business owners get left behind. 

Not-for-profit financial services providers, like community development credit unions and CDFIs (particularly Black-led ones), are a key example of the value of this approach. Many of them provide small business TA, including for VSBs and small businesses that are not yet loan ready. Then, when a business is ready to borrow, they already have a strong relationship with financial services staff who know their business model and can support them through the process and ensure the loan they take out is appropriate for their needs and finances. This approach sets a business up for long-term success. 

It is with this knowledge that we further strongly suggest Treasury direct a portion of the remaining funds to CDFIs, Minority Depository Institutions (MDIs), and small business development organizations (including chambers of commerce) that can demonstrate reach into and trust with their local Black communities. CDFIs and MDIs know how to create and underwrite the products that Black-owned businesses need while providing wrap-around services. However, these deep investments – fiscal and otherwise – require capacity and capital. Investing in the portions of the small business ecosystem that have a demonstrated track record of meeting the needs of Black entrepreneurs will help ensure SSBCI capital leads to the long-term sustainability of Black-owned small businesses, especially low income and rural Black business owners who face additional hurdles because of lack of wealth or geographic isolation. 

The Working Group stands as a resource with a ready pipeline to meet Treasury’s needs and looks forward to an ongoing conversation about how our pipeline can tap into Treasury’s contract dollars. 

How could the Federal TA funding crowd in and leverage private, nonprofit, and philanthropic funds for the same purposes? Are there existing private sector, nonprofit, and philanthropic funded TA services for VSBs and SEDI-owned businesses and how could Treasury’s efforts leverage that funding? 

Part of what makes the SSBCI Black Business Working Group unique is its mix of member organizations that provide direct TA to Black businesses and those that have deep private and philanthropic sector connections. 

In our experience, the private sector is most willing to fund concrete ideas that can make it easier for the business community to find Black-owned businesses or those that will make sure said Black-owned businesses are “ready” – from the perspective of the private sector – for private investment, either through contracting or direct dollars. 

For example, the USBC’s aforementioned ByBlack certification and accompanying Black business directory was made possible through private funding. The Association for Enterprise Opportunity’s (AEO) direct-to-consumer product, myWay to Credit, which is a referral platform that connects small businesses to business mentors and credit options from trusted community lenders, was initially sponsored by the U.S. Treasury’s CDFI Fund, with follow-on financial support from the JPMorgan Chase Foundation. In addition, CDFIs and MDIs receive grants and loans to relend from philanthropic investors, private social investors and mainstream banks. These funds will help leverage SSBCI funds. Through their deep reach into the communities that they serve and their regional partnerships of service delivery, CDFIs and MDIs are well positioned to direct technical assistance funds. 

On the other hand, there are gaps that Treasury could take the lead in servicing and helping us make the case for additional private and philanthropic support. For example, the African American Alliance of CDFI CEOs exists because Black-led CDFIs, on average, receive fewer philanthropic and public dollars than their counterparts. This lack of investment – and, in some cases, strategic disinvestment – keeps Black leaders from infusing more capital into their communities. In particular, there is a dearth of organizational capacity grants and other unrestricted funds that are critical to the development of locally based, Black-led organizations. In 2020, we saw a spike in more unrestricted and administrative grantmaking, however, unfortunately, those efforts seem to be losing steam. Promoting or incentivizing this investment for existing, Black-led TA providers will go a long way towards ensuring Black communities can receive what AEO refers to as trusted business guidance, especially if the funding is multiyear. 

Finally, at the same time, racial equity dollars do not always flow towards the regions that most need assistance in infusing Black equity into the ecosystem. Another member organization, Hope Credit Union and its related Policy Institute know this firsthand working in low-income communities and communities of color predominantly in the Deep South, where dollars are desperately needed, but leaders do not always seek them. Bringing public, private, and philanthropic funds to the geographic areas where the data support they are needed, but local politicians are not seeking it, should be a priority for Treasury. 

These are all considerations for Treasury to keep in mind as it looks to leverage its position with private, nonprofit, and philanthropic funders. 

In closing, the SSBCI Black Business Working Group greatly appreciates this opportunity and Treasury’s support of our work thus far. We look forward to keeping an open dialogue with the agency and being a resource to the states as they begin to implement their SSBCI programs. 

Sincerely, Members of the SSBCI Black Business Working Group 

The Alliance Awards Capacity-Building Grants to CDFIs led by Black Women

As part of the Alliance’s Women-Led Initiative, 18 Black Women Leaders in Finance, receive $20-25k capacity-building grants to support their organizations

10.25.22, Orlando, FL –Today, the Alliance announced that it has awarded $445k in grants to 18 community development financial institutions (CDFIs) led by Black women. The funds are a part of the Alliance’s $1M Women-Led Initiative, established to address the unique challenges and scale the impact of Black women-led CDFIs within the Alliance membership and in underserved communities.

CDFIs play a crucial role in serving disadvantaged communities, providing flexible credit and financial products and often dedicating more time and resources to technical assistance programs than traditional banks. Despite the impact they have on underserved BIPOC communities, Black Women-led CDFIs are often underfunded and have limited resources compared to other CDFIs.

“By intentionally supporting our Black women CEO members, we’re creating a pipeline of greater investment in marginalized communities. This investment recognizes the importance of Black women-led CDFIs and their unique ability to serve their communities. This capacity-building grant will strengthen the Alliance’s mission to address racial and gender inequities in the CDFI Industry,” said Lenwood V. Long, Sr., President & CEO of the Alliance.

Each grantee received between $20,000-25,000 to support one-time capacity building projects or general operating costs for one year period. Funded projects include the creation and expansion of products and services, professional development, fundraising activities, and projects to improve organizational effectiveness.

“This grant will help Community First Lending to expand its capacity by hiring a consultant to assist with grant applications. CDFIs seem to be perennially under-resourced, so it is extremely meaningful to receive assistance that directly addresses our needs,” said Monica Edwards, Director of Investing and Lending at Community First Lending. “The Alliance has provided so much value to our organization, and we have only been members for a year.  I cannot overstate how appreciative we are to have the Alliance as a partner.”

The grant recipients are the following Black Women-led CDFIs and Alliance members:

  • ACT! Albany Community Together, Inc.
  • AmPac Business Capital
  • Appalachian Community Capital
  • Baltimore Community Lending, Inc.
  • Black Business Investment Fund
  • Business Investment Growth (BiG AUSTIN)
  • C3 Fund, LLC
  • Central County Community Development Corporation
  • Community First Lending
  • FSC First – Prince George’s Financial Services Corporation
  • Greenwood Archer Capital Inc.
  • Legacy Redevelopment Corporation
  • Neighborhood Development Center
  • Neighborhood Housing Services of South Florida
  • NewCorp Inc.
  • ProsperUs Detroit
  • Steppingstones Community Federal Credit Union
  • Village Capital Corporation

“The $25,000 grant, provided by the African American Alliance of CDFI CEOs through the generous support of Capital One, underscores an important commitment to women-led Community Development Financial Institutions (CDFIs). Having served FSC First as President and CEO for over two decades, I see this funding as a unique opportunity for our organization to further invest in transformative technology that will enhance processes. All of this helps us continue to improve our ability to provide access to capital for those most in need. Additionally, our current management team of women leaders will have the opportunity to participate in innovative executive-level professional development and be better positioned to lead FSC First to new levels of service related to both our lending and technical assistance initiatives,” said Shelly M. Gross Wade, President and CEO of FSC First.

# # # 
  

About The African American Alliance of CDFI CEOs

Founded in 2018, the African American Alliance of CDFI CEOs (The Alliance) is a coalition of more than 69 CEOs of Black-led Community Development Financial Institutions (CDFIs), comprising loan funds, credit unions, venture capital firms, and non-profit developers that serve 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 its programs at http://www.aaacdfi.org.

Alliance Member Spotlight: Neighborhood Development Center Turns Challenges into Opportunities

The Neighborhood Development Center (NDC) believes that economic development serves as a tool for social justice and the evidence is clear: their work is making an impact.  

In 2020, NDC was evaluated by Wilder Research, and their findings showed that 78% of employees at NDC-assisted businesses were people of color and 71% of business owners hire residents of their local neighborhood. 

This means that NDC is creating jobs for people who need themand helping those same people get ahead by creating opportunities for themselves. They know that economic development can be an effective way to fight poverty and they’re proud to say that they’re doing just that. 

NDC is a nonprofit organization that has been helping entrepreneurs in low-income neighborhoods for over 25 years. They’ve done this through a variety of initiatives, such as their Midtown Global Market—a hub that offers space for entrepreneurs from all walks of life to collaborate, network, and create. 

And that’s not all. NDC prides itself on being responsive and aware of current trends and needs. This has resulted in special initiatives such as Tech Pack, which addresses tech needs and Mindset Reset, which provides mental wellness awareness; and more. 

Fighting the ‘Minnesota Paradox’ 

NDC is committed to fighting the Minnesota Paradox. The Minnesota Paradox is a term used by economist Samuel L. Myers to describe the larger-than-average gap in measures of quality of life between white Minnesotans and BIPOC Minnesotans. This includes one of the largest racial wealth gaps in the nation: as NPR reported last year, the median Black family in the Twin Cities earns $38,178 a year, which is less than half of the median income for white families ($84,459). 

NDC is dedicated to addressing these challenges through its work supporting individuals’ ability to build wealth and revitalize disinvested neighborhoods through entrepreneurship and small business ownership. 

When entrepreneurs of color utilize NDC’s programs and services, including Entrepreneur Training, Technical Assistance, and Lending, their annual income increases by $25,860, on average. NDC focuses on their 10 Priority Neighborhoods to channel these services to the places where they are most needed and have the biggest impact.  

Renay Dossman, President & CEO of NDC

“NDC advances racial equity by supporting individuals’ ability to build wealth and revitalize disinvested neighborhoods through entrepreneurship and small business ownership. All our programs and operations have been specially designed and refined to achieve those ends,” said Renay Dossman, CEO of NDC. 

Grand Opening of New Building: Frogtown Crossroads 

Just recently, the NDC announced the grand opening of their building, Frogtown Crossroads. The new building serves as a beacon of hope in St. Paul’s Rondo and Frogtown neighborhoods, which were torn apart to put in Highway 94.  

Decades later, these areas are still rebuilding, and have become the heartbeat of St. Paul. 

The building has first floor retail/restaurant space for businesses – with two, black woman-owned businesses Urban 29 and Flava Café as tenants. In addition, NDC’s offices are in this new project, providing open and inspiring space to do their work and welcome entrepreneurs in. The top floor features their Training Center, which allows NDC to host trainings and workshops onsite and provide community space. In addition, there are 40 units of family affordable housing in the project; most of which went to people who already lived in the neighborhood. 

Check it out below:

The NDC has made a big impact on their community. With their core focus on supporting entrepreneurs in diverse, inclusive, and influential ways, NDC is poised to make an even bigger impact in the years to come. With exciting programs like their entrepreneur in residence program and a brand-new space that’s literally rising from the ground up, they’re a group you should definitely keep your eye on.  

If you’d like to learn more about what NDC is up to, visit their website or give them a like or follow on social media. 

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! 
Sincerely, 

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

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

ECONOMIC RESILIENCE AND THE COMMITMENT TO COMMUNITY DEVELOPMENT: AN INTERVIEW WITH WATCHEN BRUCE, PRESIDENT AND CEO OF BALTIMORE COMMUNITY LENDING

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.

 

Conclusion

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.

Sincerely,

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 (minneapolisfed.org)

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

[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 (cnbc.com)

[6] https://himarkcapital.com/opinion-the-2-cent-solution

[7] https://apps.urban.org/features/wealth-inequality-charts/

[8] https://www.nmsdc.org/wp-content/uploads/Economic_Impact_Report_FINAL.pdf

[9] https://www.fedsmallbusiness.org/medialibrary/FedSmallBusiness/files/2021/sbcs-report-on-firms-owned-by-people-of-color

[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, https://www.brookings.edu/research/an-analysis-of-financial-institutions-inblack-majority-communities-black-borrowers-and-depositors-face-considerable-challenges-in-accessing-bankingservices/

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

[12] https://ncrc.org/adding-underserved-census-tracts-as-criterion-on-cra-exams

[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, https://www.cdfifund.gov/sites/cdfi/files/documents/cdfi-certification-application-for-comment-may-2020.pdf. Page 56.

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

[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, https://www.ncrc.org/intermediate-small-banks-forgotten-significant-resource-affordable-housing-communitydevelopment/

[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, https://www.fdic.gov/news/boardmatters/2022/2022-05-05-notice-dis-a-mem.pdf

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