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Community Developments Investments Community Developments May 2018 Investments Profitable Partnerships Collaborating With Minority Depository Institutions Profitable Partnerships: Collaborating With Minority Depository Institutions A Look Inside … This edition of Community Developments Investments reviews how minority depository institution (MDI) collaborations with large and midsize banks can be profitable for the parties involved and help MDIs fulfill their missions and serve customers in a rapidly evolving industry. Community Reinvestment Act Consideration for Collaborations That Promote Community Development Banks may receive Community Reinvestment Act (CRA) consideration from partnerships with other financial institutions, including those with minority- and women-owned financial institutions and low-income credit unions. Catalyzing Impact: NCIF Fosters Bank Partnerships With MDIs The National Community Investment Fund (NCIF) has invested in mission-oriented banks, including MDIs. To encourage high- impact projects, the NCIF provides metrics and information that banks can use to analyze potential partnerships, projects, and investments. • Detroit: Liberty Bank and Trust Partners on Gateway Marketplace • East Baltimore: The Harbor Bank of Maryland and City First Bank Partnership Citibank: Partnering With Community Banks to Expand Financial Access The Citi Community Automated Teller Machine (ATM) Network allows customers of Continental Bank and several other community banks to use—without paying out-of-network fees—any of Citibank’s 2,400 branch ATMs, including those in Chicago, Los Angeles, Miami, New York, San Francisco, and Washington, D.C. Texas Capital and Texas National Banks: Collaborating for Mutual Benefit Texas Capital Bank is collaborating with and providing correspondent banking services to Texas National Bank and other MDIs and community development financial institutions. Resources A variety of resources is available to help banks interested in developing mutually beneficial partnerships with MDIs. On the cover A Diverse and Entrepreneurial History Minority depository institutions today are descendants of an entrepreneurial group of community banks founded by minority bankers dedicated to serving their diverse communities. This newsletter’s cover honors this rich heritage with images of (clockwise from top right): Façade of a bank in San Francisco (Alamy); Elouise Cobell, a Native American woman who spearheaded the capital campaign to fund Blackfeet National Bank, predecessor to today’s Native American Bank, N.A. (AP Images); St. Luke Penny Savings Bank employees (National Park Service); Romana Acosta Bañuelos, Latina co-founder of Pan American Bank in East Los Angeles, Calif. and U.S. Treasurer (1971-1974), pictured with James A. Conlon, Director, Bureau of Engraving and Printing (1967-1977) (Bureau of the Public Debt); Freedman’s Savings and Trust Co. passbook (U.S. Department of the Treasury); Maggie L. Walker, the first African American woman to charter a U.S. bank and founder of St. Luke Penny Savings Bank (National Park Service); Frederick Douglas, the first president of Freedman’s Bank, the first black-owned bank (Shutterstock). A Look Inside … Barry Wides, Deputy Comptroller for Community Affairs, OCC he Office of the Comptroller national banks and federal savings addition, MDIs help to ensure that of the Currency (OCC) associations (collectively, banks). the nation’s vibrant and diverse Trecognizes the vital role that MDIs represent a small2 but banking system benefits the financial minority depository institutions important part of the federal banking needs of all customers, businesses, (MDI) can play in improving system because they often serve and communities they serve. financial outcomes for their customers in minority, customers and promoting the This issue of Community low- and moderate-income (LMI), economic viability of minority Developments Investments highlights and underserved communities. In and lower-income communities. the OCC’s continuing efforts to Consistent with its mission of ensuring a safe and sound federal banking system, the OCC is committed to promoting the preservation of robust and healthy MDIs and, in so doing, fulfilling its congressional and regulatory responsibilities.1 Preserving MDIs is an important and timely goal for the nation and the OCC, which supervises Community Developments Citibank An ATM partnership between Citibank and Continental National Bank, in Miami, uses Investments Spanish materials to reach Continental’s Hispanic customers. Deputy Comptroller Barry Wides Editorial Staff David Black Janet Fix Emily Gold Design Staff Vincent Harris Richard Shacklette Questions or comments, please phone (202) 649-6420 or email [email protected]. This and previous editions are available on the OCC’s website at www.occ.gov. Disclaimer Articles by non-OCC authors represent the authors’ own views and not necessarily the views of the OCC. OCC Bank executives from women- and minority-owned banks gather at a recent meeting at OCC Headquarters. 1 Section 367 of the Dodd–Frank Wall Street Reform and Consumer Protection Act; OCC, “Policy Statement on Minority National Banks and Federal Savings Associations,” June 7, 2013. 2 Less than 3 percent of the depository institutions in the United States are MDIs. Only 30 percent of MDIs operated continuously throughout 2001 to 2013, compared with 57 percent of community banks, according to “Minority Depository Institutions: Structure, Performance, and Social Impact,” FDIC Quarterly, Volume 8, No. 3, 2014. May 2018 1 support and encourage new and LMI communities. The OCC’s critical resources into low-income existing MDIs through collaboration roundtable discussions, which began communities and strengthen MDIs. roundtables. These roundtable in 2016, are continuing, and some of The NCIF explains its work in discussions bring together the senior the collaborations that came out of “Catalyzing Impact: NCIF Fosters executives of MDIs and those those initial meetings are highlighted Bank Partnerships With MDIs.” of midsize and large banks. By in the articles “Citibank: Partnering By highlighting MDI collaborations collaborating with MDIs, the OCC With Community Banks to Expand and resources in this publication, believes, large and midsize banks Financial Access” and “Texas the OCC hopes to encourage can help MDIs better serve the Capital and Texas National Banks: similar collaborations. The OCC’s credit needs of their communities, Collaborating for Mutual Benefit.” District Community Affairs Officers while expanding their own business Nonprofit organizations have been are available to answer technical opportunities, fulfilling strategic critical in facilitating collaborations. questions, and the OCC’s website goals, and potentially receiving The National Community Investment (www.occ.gov) has helpful resources. Community Reinvestment Act (CRA) Fund (NCIF), a nonprofit private In addition, MDI executives are consideration. These partnerships can equity trust and impact investor, is encouraged to attend the OCC’s be profitable for the parties involved dedicated to supporting mission- bank director workshops on risk and help MDIs fulfill their missions oriented MDIs and other banks governance, credit risk, compliance and serve customers in a rapidly operating in and serving LMI risk, and other important banking evolving industry. communities. The NCIF’s goal is issues. In 2015, the OCC issued a to channel financial products and MDIs and midsize and large banks, paper titled “An Opportunity for services to LMI areas, minority as well as their customers, benefit Community Banks: Working communities, and other underserved from a healthy, diverse federal Together Collaboratively.” The areas. To encourage high-impact banking system. After reading paper highlighted the benefits projects, the NCIF provides metrics this publication, you will better of bank partnerships pooling or and information that banks can use understand the important role that sharing resources to reduce costs, to analyze potential partnerships, MDIs play in their communities. We achieve economies of scale, and projects, and CRA-qualified hope you also will share the OCC’s leverage specialized expertise to investments. NCIF has also been commitment to ensuring the future serve customers and communities, using the New Markets Tax viability and preservation of the particularly those in minority and Credit Program as a way to bring nation’s MDIs. 2 Community Developments Investments Community Reinvestment Act Consideration for Collaborations That Promote Community Development David Black, Community Development Expert, OCC he Community Reinvestment Act (CRA), passed in 1977, Tencourages national banks and federal savings associations (collectively, banks) to help meet the credit needs of all segments of their communities, including low- and moderate-income (LMI) neighborhoods. Today, federal financial supervisory agencies, including the OCC, evaluate financial institutions on their performance regarding activities that qualify for consideration under the CRA. This article reviews ways in which banks may receive CRA consideration from partnerships with OCC other financial institutions, including The East Baltimore Development Initiative used new markets tax credits, which is an eligible minority depository institutions community development activity under the Community Reinvestment Act. (MDI), women-owned financial institutions, and low-income credit unions (MWLI financial institutions). of “community development,”
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