Please join us in welcoming our newest field rep, Ayana Bass-Myers. Ayana will be serving Maryland, Delaware, Washington DC, Pennsylvania, Virginia, and West Virginia.
Ayana is a versatile professional with a background in hospitality and real estate. She holds a Bachelor of Arts in Communications from Palm Beach Atlantic College, where she studied communication and interpersonal skills. Building on her passion for hospitality, Ayana pursued a Master of Science in Hospitality Management, which equipped her with the knowledge and expertise to thrive at our Foundation and serve seniors in her region.
Could the final rule cause thoughts of early retirement?
By Steffani Jenkins
Have you read the new best-seller co-authored by the FDIC, the Federal Reserve and the OCC? It’s been as slow as molasses but it’s finally here, so put on your bifocals.
The publication is making us wonder if early retirement might be a better option than reading and implementing those 1,466 pages of the final rule on CRA modernization. I’m here to help you make that determination based on some of the main components discussed in the quite lengthy time.
WHO SHOULD CONSIDER RETIRING?
First, decide which set of requirements fits your bank’s asset size. The rule states that small banks are defined as those with assets of less than $600 million and they can either choose to be examined under the existing Lending Test or opt-in to the new Retail Lending Test.
If you decide to remain under the existing test, then it’s business as usual for you, and there’s no need to think about the tax implications of an early retirement. If you opt-in to the Retail Lending Test, then you should prepare to have your home mortgage, small business and small farm lending evaluated under a rigorous new quantitative framework where bank performance is compared to localized benchmarks to establish presumptive ratings.
For those banks whose assets are $600 million but less than $2 billion, you will be examined under the new Retail Lending Test and the existing Community Development Test, or you can opt-in to the Community Development Financing Test. Each test will carry equal weight and is designed to assess whether your bank is making sufficient home mortgage, small business and small farm loans in your assessment area(s). Early retirement could be a possible option for those CRA officers in this category, but please continue reading so that you can make a more informed decision.
Banks that have assets of $2 billion or more will be examined under all tests and the kitchen sink! This includes the Retail Lending Test, the Retail Services and Products Test, the Community Development Financing Test and the Community Development Services test.
The Retail Lending test will be weighted at 40%, the Retail Services and Products Test will be 10%, the Community Development Financing Test will be 40% and the Community Development Services Test will be weighted at 10%. Those banks with assets over $10 billion will also be evaluated on their digital delivery systems, as well as their deposit and grant products under the Retail Services and Products Test. Additionally, these banks will be required to report their Community Development Investments at the institution level.
Large banks that originate or purchase more than 20% of their retail loans outside of their facility-based assessment areas will also be required to delineate new Retail Lending Assessment Areas (RLAAs) when they have reported at least 150 closed-end home mortgage loans in each year of the prior two calendar years or at least 400 small business loans in each year of the prior two calendar years outside of their facility-based assessment areas.
For those CRA Officers in the large bank category under $10 billion, you should continue reading. For those $10 billion and over, please begin making a list of things you could sell to build up your retirement savings.
THE RETAIL LENDING TEST
As previously mentioned, the Retail Lending Test will apply to both intermediate and large banks and will assess the bank’s level of home mortgage, small business and small farm lending within its assessment area(s).
In addition, banks whose lending includes more than 50% automobile lending will be evaluated under that category, or a bank may opt-in to have their auto loans evaluated. Optionally, a bank may elect to report originated and purchased credit card loans and other secured and unsecured consumer loans. If your bank elects to report these consumer loans, please continue the list of sellable items, as well as make a list of to-do items to ensure you stay busy during retirement.
THERE ARE SOME POSITIVES
Though the book has its scary moments, there are also some good things. Large banks with 80% or more retail lending within their facility-based assessment areas are exempt from the Retail Lending Assessment Area requirement. All others must make 150 closed-end home mortgage loans and 400 small business loans to fall under the Retail Lending Assessment Area requirement.
Another positive aspect is there are certain small business loans that, if they meet a size and purpose test, can now be counted under both the Retail Lending Test and the Community Development Financing Test in the Economic Development category.
Banks will also be able to receive consideration for all community development activities conducted nationwide. The activity does not have to be conducted inside an assessment area.
Additionally, the regulatory agencies will publish and update periodically a list of community development activities that will be eligible for CRA consideration. Banks can submit activities to the agency to receive preapproval of CRA qualification and the agency’s response will include a written response.
Though the highlights of the book are few, they can have an impact, so CRA officers, please consider these factors when making your career decision.
WHEN TO CONSIDER RETIRING
The effective date of the Final Rule is expected to be April 1, 2024, or the first day of the first calendar quarter at least 60 days after publication in the Federal Register. Most definitions, assessment area requirements and other general provisions will become applicable on Jan. 1, 2026. Reporting requirements will become applicable on Jan. 1, 2027, with data being reported by April 1, along with data collection and maintenance for operations subsidiaries, affiliates and third-party community development loans and investments.
THE BOTTOM LINE IS TO SERVE
If you decide that you want to read the Cliffs Notes® of the final rule and not the entire beast, I recommend starting on page 1,039. You can skip over the proposed rules, recommendations, etc., though these do provide context and rationale for the final rules.
Though this summary does not encompass all the requirements of the final rule, it should help you determine your future as a CRA officer. Keep in mind the mission of the CRA — ensuring we are serving all segments of the community. The rule may be cumbersome, but your efforts will have an impact on your communities and ultimately, that’s who we serve.
Memphis, TN – CRA Partners, a subsidiary of the Independent Community Bankers of America (ICBA), announced the addition of CRA support services under an agreement with Michael P. Wallace of Wallace Consulting Co. LLC to help community banks meet new Community Reinvestment Act requirements.
“Michael’s deep understanding of the complexities of CRA allows us to assist in the optimization of bank policies and practices in order to achieve the best outcomes in the markets where they operate,” said David Lenoir, president and CEO, CRA Partners. “As a former supervisory examiner with the Federal Reserve System, he’s provided oversight on more than 100 compliance and CRA examinations during his nearly 20-year regulatory career and regularly provided CRA and fair lending training to examiners, bankers, and the public, making him ideally suited for this work.”
Customizable CRA support services — including options for self-evaluations for banks of all sizes, community development activity evaluations, CRA rating appeals, strategic plan development, and more — will help banks determine the best path forward to fulfill community reinvestment goals and obligations, track them, and clearly communicate value to examiners.
“I’m delighted to be working with an established leader in the CRA space to help banks bridge any gaps they may be facing as they adjust to the new regulatory environment,” said Wallace.
Learn more at shcpfoundation.org/cra-partners.
About CRA Partners
CRA Partners offers CRA support services, the CRA Collaborative Peer Group, and compliance solutions powered by the Senior Housing Crime Prevention Foundation. Since its inception in 2000, it has helped banks across the country earn meaningful CRA credit for ensuring safe senior living environments through turnkey crime prevention programs. Funded exclusively by the banking industry and endorsed by bank associations in 30+ states, CRA Partners works with banks to protect low- and moderate-income seniors living in senior housing facilities, HUD communities, and state veterans homes from theft, abuse, and neglect—all with flexible funding options to make it simple for banks to get involved.
About Wallace Consulting Co., LLC
Wallace Consulting Co., LLC provides CRA, fair lending, and HMDA services to banks of all sizes. Since its inception in 2015, it has served banks with total assets ranging from as little as $65 million to over $200 billion. Between his regulatory and consulting background, President Michael P. Wallace has almost 28 years of CRA and compliance experience.
Holiday scams can happen at any time — from Black Friday and Cyber Monday to the weeks and months leading up to the end of the year.
Please join us in welcoming our newest field rep, Jean Taddonio. Jean will be serving Connecticut, Massachusetts, Rhode Island, New Hampshire, Vermont, Maine, New York and New Jersey.
Jean brings extensive years of bookkeeping and banking experience to SHCPF. She began her banking career as an Analyst on Wall Street, and has also lived and worked in France and London. More recently, Jean provided bookkeeping and client management services, and general office management responsibilities for small to medium-sized businesses.
The Community Bankers Association of Kansas recently endorsed CRA Partners as a means to help reduce incidents of crime in area nursing homes, while offering banks the opportunity to earn CRA credit. CRA Partners is a subsidiary of the Independent Community Bankers of America (ICBA).
The Senior Housing Crime Prevention Foundation is a 501(c)(3), established in 2000 as a way for banks to earn Community Reinvestment Act (CRA) credit through CRA-qualified loans and investments. The structure of the SHCPF opens a segment of society to service by banks – the residents, family members and staff of nursing homes and senior HUD housing properties. Supporting low-to-moderate income Senior housing residents is an approved CRA activity designated by the federal regulatory agencies, allowing banks to receive CRA credit for supporting Foundation programs in nursing homes, HUD senior housing projects and the nation’s Veterans Nursing Homes. The focus of the SHCPF is to reduce all aspects of crime and provide ongoing, effective crime prevention programs that ensure a safe and secure environment for the residents of senior housing. In part, this is accomplished through the installation of the Senior Crimestoppers program.
“It’s a win-win proposition for everyone,” says CEO David Lenoir. “The banks receive a return on their investment while helping nursing home, HUD housing residents and elderly veterans live in safe, crime free environments. “
For more information about the Senior Housing Crime Prevention Foundation or to enroll in the program, visit www.SHCPFoundation.org, contact Kristine LaVigna at the Senior Housing Crime Prevention Foundation at (901)529-4781 or email her at [email protected] .
Kim Phillips earned her bachelor’s degree in Education and master’s in Administration and Supervision from Tennessee Technological University. She has dedicated thirty years to teaching in Tennessee public schools, with the last seventeen years specializing as an ESL teacher. Additionally, she gained experience through part-time roles as a home study writer for DCS and in selling Medicare insurance.
Residing in middle Tennessee throughout her life, Kim is married to Chris Phillips. Together, they have raised two adult children, Riley Phillips and Carly Phillips. Kim finds joy in spending time with her family and friends, whether its traveling, exploring the outdoors, or enjoying social outings.
Kim possesses a deep-rooted love and passion for assisting others. Her enthusiasm is palpable as she embarks on this new chapter of her journey as a field representative for the SHCP Foundation.
We are delighted to announce some new additions to our team that will be serving as regional field representatives across the country:
Charlie is a native of Gary, Indiana. He currently resides in Allen, TX where he has lived for the past 15 years. Charlie brings more than 35 years of work experience to SHCPF where he has worked in various roles ranging from designer, product engineer, project manager, program manager, customer success director, loss control consultant, field Interviewer, and small business owner.
Charlie graduated from Cardinal Stritch University in Milwaukee, WI with an MBA in Finance, BA in Business Administration, and an AAS in Mechanical Engineering Technology. Charlie served ten years in the US Army and was deployed to various combat operations during his time in the military.
In his recent role as a field interviewer, Charlie’s responsibilities included collecting data associated with the quality of care in assisted living and nursing homes and reviewing associated safety risks throughout the state of Texas. Charlie is excited to be part of a team that protects our seniors and elders from fraud, and believes his experience coupled with his understanding of technology will be beneficial to the mission of SHCPF.
A Baltimore native – O’s and Raven fan for life, an alumnus of Morgan St. University, Towson University and the University of North Dakota Law School; where she was the co-founder and former Vice-President of UND Black Law Student Association (BLS) Mid-West Region – the largest student group in the nation. Former John’s Hopkins Hospital Children’s House Volunteer, Youth Mentor/Life Coach and Ameri-Corps alumnus since 2003. Current Professor of Business Ethics & Law and Management Leadership – Montreat College, former Professor of Communications Law – Clark Atlanta University, previous Faculty member of the Business & Technology Division –Howard County Community College, licensed sports agent –New York State, continuous Red Cross supporter and annual Children’s International contributing donor.
Professional experience in capital industries such as legal aid (Washington, D.C Attorney General’s Office, and State of Maryland Office of The Public Defender), Government Policy (US SSA), Consulting, Public Relations, Radio/Television promotion and production( CBS Radio & Network), Community Development, Sports and Entertainment Agency.
Member of the Southeast Asian Bar Association of D.C, the National Black Prosecutor’s Association and Maryland Chapter MS Society. Renee is the former Executive Director of the Waverly Main Street Inc. Community Development non-profit organization and currently the managing partner of the ER Edwards Consulting Co. Sports and Entertainment Agency division. A veteran of the United States Army and former political candidate for the Baltimore City Council 2012 Mayoral election. Previous Varsity Head Basketball Coach for the Forest Park Senior High School, former Assistant Head Coach – Friends School of Baltimore. Renee enjoys warm travels; philanthropic endeavors, volunteering with community service projects emphasizing civil rights, environmental protection, education and youth empowerment.
Rob resides in Pennsylvania with his family. He has worked in the management field for over 25 years with some companies like, Round 1 Entertainment, Wawa, Save-A-Lot, and Aldi’s. Rob has also worked in the Medical Field as a Community Field Representative for Horizon’s Hospice. For the past 7 years, he has operated a family business of 4 Frozen Yogurt/Ice Cream Parlor’s which his 2 children recently took over this year.
Welcome Charlie, Renee and Rob! We are very pleased to have you all as a part of our team!
Many of the banks that sponsor our senior protection programs, particularly those in the Northeastern U.S., may already be familiar with Kristine LaVigna. She has served as the Northeast Regional Field Rep for over ten years. In that role, she worked with area bankers, as well as with health care administrators at senior communities enrolled in Senior Crimestoppers and Senior Secure programs to help them utilize the program benefits.
In order to better serve the banks that sponsor our Foundation’s programs that protect seniors, Kristine has been promoted to Business Development Manager, where she will serve to unite banks across the country with low- to moderate-income senior facilities in their assessment areas, creating opportunities for CRA lending and investment test credit.
“Kristine’s long history with us and deep understanding of our programs and services will be invaluable to CRA professionals that wish to expand their CRA strategy to include these innovative and essential programs that benefit some of the most vulnerable members in their communities,” said David Lenoir, President & CEO, CRA Partners.
Kristine spent 18 years in investment banking in NYC before starting her own consulting practice, helping small businesses in her community develop and implement effective business plans. She is based in Ridgefield, CT, working remotely out of our Memphis headquarters.
About the Senior Crimestoppers program
CRA Partners and Senior Crimestoppers are operated by the Senior Housing Crime Prevention Foundation (SHCPF), headquartered in Memphis, Tennessee.
The SHCPF mission is to provide protection and an enhanced quality of life for vulnerable senior housing residents through meaningful turnkey CRA compliance for community focused banks.
Funded exclusively by the banking industry and endorsed by the ICBA and over 30 state bankers associations, the Foundation has developed a low-risk, profitable solution — CRA Partners — for banks of all asset sizes and charter types – to fulfill their federally mandated Community Reinvestment Act (CRA) requirements in the form of qualified loans, investments or grants through the operation of the nationally acclaimed Senior Crimestoppers program.
For more information about Senior Crimestoppers, visit SeniorCrimestoppers.org or call 800-529-9096.
Please join us in welcoming our newest field rep, Aaron Reid. Aaron will be serving the upper Great Lakes states of Michigan, Indiana, Ohio and Kentucky.
Aaron Reid is an Ohio native currently residing in the Cincinnati area. During his career, he has been a high school teacher and worked in various management positions in the nonprofit education, health and human services sectors. Aaron has a Bachelor’s in History from Florida Atlantic University and a Master’s in International Enterprise Management from the University of Maryland. He enjoys spending time with his fourteen-year old son, playing and watching sports, and hiking with his dogs along the Little Miami River.