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Preserving Minority Depository Institutions

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Preserving Minority Depository Institutions Preserving Minority Depository Institutions May 2020 B O A R D O F G O V E R N O R S O F T H E F E D E R A L R E S E R V E S YSTEM Preserving Minority Depository Institutions May 2020 B O A R D O F G O V E R N O R S O F T H E F E D E R A L R E S E R V E S YSTEM This and other Federal Reserve Board reports and publications are available online at https://www.federalreserve.gov/publications/default.htm. To order copies of Federal Reserve Board publications offered in print, see the Board’s Publication Order Form (https://www.federalreserve.gov/files/orderform.pdf) or contact: Printing and Fulfillment Mail Stop K1-120 Board of Governors of the Federal Reserve System Washington, DC 20551 (ph) 202-452-3245 (fax) 202-728-5886 (email) [email protected] iii Preface: Implementing the Dodd-Frank Act The Board of Governors of the Federal Reserve efforts implementing the Dodd-Frank Act and a list System (Board) is responsible for implementing of the implementation initiatives completed by the numerous provisions of the Dodd-Frank Wall Street Board as well as the most significant initiatives the Reform and Consumer Protection Act of 2010 Board expects to address in the future.1 (Dodd-Frank Act), including mandates to preserve and promote Minority Depository Institutions (MDIs). The Dodd-Frank Act requires, among other things, that the Board produce reports to Congress on a number of topics. 1 Board of Governors of the Federal Reserve System, “About Regulatory Reform,” https://www.federalreserve.gov/regreform/ about.htm;“Implementing the Dodd-Frank Act: The Federal The Board maintains a Regulatory Reform website, Reserve Board’s Role,” https://www.federalreserve.gov/ which provides an overview of regulatory reform regreform/milestones.htm. v Contents Abbreviations ............................................................................................................................ 1 Executive Summary ................................................................................................................ 3 State Member MDIs ............................................................................................................... 5 Geographic Dispersion ................................................................................................................ 5 Minority Ownership Type ............................................................................................................. 5 Partnership for Progress Programming ............................................................................ 7 Collaboration with Trade Groups and Other Partners .................................................................... 9 Research on MDIs and Low- and Moderate-Income Communities .................... 11 Efforts and Initiatives ........................................................................................................... 15 Preserving the Character and Number of MDIs ........................................................................... 15 Promoting the Creation of MDIs ................................................................................................. 15 Training, Technical Assistance, and Educational Programs .......................................................... 15 Partnership for Progress Website ............................................................................................... 15 Publications and Webinars ........................................................................................................ 16 Appendix A: Section 308 of FIRREA ........................................................................... 17 Appendix B: MDI Tables and Figures ............................................................................ 19 1 Abbreviations BSA/AML Bank Secrecy Act/Anti-Money FRB Federal Reserve Bank Laundering LMI Low- and moderate-income CDFI Community Development Financial MDI Minority depository institution Institution NBA National Bankers Association CRA Community Reinvestment Act PFP Partnership for Progress FIRREA Financial Institutions Reform, Recovery, and Enforcement Act of 1989 3 Executive Summary The Board submits this report pursuant to sec- in traditionally underserved areas. As such, the Fed- tion 367 of the Dodd-Frank Act. Section 367 of the eral Reserve remains strongly committed to identify- Dodd-Frank Act requires the Board to submit an ing and implementing all opportunities to support annual report to the Congress detailing the actions MDIs. taken to fulfill the requirements outlined in sec- tion 308 of the Financial Institutions Reform, Throughout 2019, the System supervised 15 MDIs Recovery, and Enforcement Act (FIRREA) of 1989, with combined assets of over $101 billion.4 This rep- as amended by the Dodd-Frank Act in 2010 (see resents approximately 2 percent of the 754 commu- appendix A). In addition to the annual reporting nity and regional banks in the System’s community requirement, FIRREA section 308 requires the Fed- and regional banking organizations portfolios. To eral Reserve System (System) to devote efforts support these institutions and to accomplish the toward preserving minority ownership of minority broader minority depository-related FIRREA goals, depository institutions (MDIs). the Federal Reserve leadership continues to dedicate resources to engage in proactive outreach and techni- In 2019, the House Financial Services Committee cal assistance activities. Throughout 2019, staff from held two hearings on MDIs, one of which included a the Board and PFP-dedicated staff from each of the panel of regulators, including the Federal Reserve.2 12 Federal Reserve Banks (FRBs) engaged in activi- Art Lindo, deputy director of the Division of Super- ties to support MDIs. Highlights of those activities vision and Regulation, testified about the Federal included Reserve’s commitment to and efforts to assist • planning and executing the 2019 Interagency MDI MDIs.3 The Federal Reserve recognizes that there is and CDFI Bank conference, in collaboration with more to be done, especially as it relates to the decline the Federal Deposit Insurance Corporation in African American owned banks. This report (FDIC) and Office of the Comptroller of the Cur- details programing and outreach from 2019 and rency (OCC); includes a preview of efforts underway in 2020. • co-sponsoring Banking and the Economy: A The System’s Partnership for Progress (PFP) pro- Forum for Minorities in Banking, which was held gram was established in 2008 because Federal at the Federal Reserve Bank of St. Louis; Reserve leadership recognized the importance of • participating and hosting an exhibit table at the MDIs and wanted to independently take steps to National Bankers Association (NBA) 72nd Annual preserve and promote these institutions. Leadership Convention in Washington, D.C.; at the Federal Reserve supports an inclusive financial system and understands the challenges inherent in • partnering with the FDIC for a MDI collaboration providing access to credit and other financial services roundtable held November 7, 2019, in Chicago, Illinois; 2 “An Examination of Regulators’ Efforts to Preserve and Pro- mote Minority Depository Institutions,” Subcommittee on • commissioning two research papers to understand Consumer Protection and Financial Institutions, November 20, the challenges and opportunities faced by the MDI 2019, https://financialservices.house.gov/calendar/eventsingle industry; .aspx?EventID=404651. 3 Arthur Lindo, “Minority Depository Institutions” (testimony • providing technical assistance to MDIs on a wide before the House Financial Services Subcommittee on Con- sumer Protection and Financial Institutions, U.S. House of variety of topics, including improving regulatory Representatives, Washington, D.C., November 20, 2019), https://www.federalreserve.gov/newsevents/testimony/ 4 This was an increase of one institution from year-end 2018 due lindo20191120a.htm. to a charter change in the first quarter of 2019. 4 Preserving Minority Depository Institutions ratings, navigating the regulatory applications pro- • coordinating with the Board’s CRA Policy team to cess, complying with the Bank Secrecy Act (BSA), represent the interests of MDIs in the CRA regula- understanding changes to the Community Rein- tory modernization process. vestment Act (CRA), and refining capital-planning practices; • maintaining a website that provides a full menu of banking resources—including regulatory guid- ance—relevant to MDIs;5 and 5 For details on the Partnership for Progress program and the range of available resources, see https://www.fedpartnership .gov. 5 State Member MDIs Throughout all of 2019, the System retained primary Table 2. State member MDI distribution supervisory responsibility for 15 state member 6 MDIs, which, with few exceptions, are community Reserve Bank Total assets Percentage of Number of MDIs banks,7 have total assets of $10 billion or less (see District ($'000) total assets table 1). (For more details on the 15 state member Atlanta 1 418,130 0.41 MDIs discussed in this report as well as a compari- Chicago 2 435,028 0.43 son of the number, assets, and demographics of state Dallas 1 236,063 0.23 member MDIs from 2015–19, see appendix B.) Kansas City 4 683,226 0.67 Accordingly, the System’s community banking orga- New York 2 51,682,910 50.86 8 Philadelphia 1 238,451 0.23 nizations program, which is responsible for the risk- San Francisco 4 47,928,578 47.16 focused supervision of state member banks with less Total 15 101,622,386100.00 than
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