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#1149992 - 03/23/09 09:05 PM SB 5651 Microenterprise Dev. Proj data collection
Chocaholic Offline
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Joined: Aug 2005
Posts: 443
Northwest
OK, this is the first I have heard of this requirement, how about others out there..
My question is, if you read RCW 30.60.010 it sounds like whatever you do for FDIC, or report for CRA purposes will suffice and examiners will look to this to judge CRA compliance.. OR do we need to start capturing this data even if we are not required for FDIC.

What do others think?

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#1150385 - 03/24/09 04:10 PM Re: SB 5651 Microenterprise Dev. Proj data collection Chocaholic
dfh Offline
Member
Joined: Jan 2005
Posts: 65
We received the survey today also and it is the first I've heard of it also. I guess I need to figure out how they communicate these changes and get signed up.

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#1150479 - 03/24/09 05:34 PM Re: SB 5651 Microenterprise Dev. Proj data collection dfh
Chocaholic Offline
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Joined: Aug 2005
Posts: 443
Northwest
once you figure out how to sign up would you let me know.. I did not see anything on the Access WA DFI site for communications..

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#1150595 - 03/24/09 07:04 PM Re: SB 5651 Microenterprise Dev. Proj data collection Chocaholic
dfh Offline
Member
Joined: Jan 2005
Posts: 65
Near as I can tell they wrote SB 5652 which requires CTED to create these nonprofit microenterprise development organizations. These organizations are responsible for seeking out Financial Institution support. Then they added the Microenterprise participation to our CRA assessment criteria. We've never been communicated with on this from DFI and we've never been contacted by one of these development agencies. The craziest thing is that they don't even define a Microenterprise in SB 5652 or in SB 5651. So the survey comes out and defines it as five employees or less. How are we to know that?

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#1150601 - 03/24/09 07:11 PM Re: SB 5651 Microenterprise Dev. Proj data collection Chocaholic
RFitzpatrick Offline
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RFitzpatrick
Joined: Apr 2002
Posts: 424
Pacific NW
The letter sent to the bank CEOís.

They are looking for tracking of loans to businesses of 5 employees or less (their definition). I believe the state always had to consider CRA ratings. The change to the legislation only added the reference to microenterprise development in section (h).

It appears this will mean a new burden of data collection and report generation to satisfy this requirement.

I didnít see a definition of microenterprise in the referenced section. I agree that loan size and revenue are the standard for CRA, but neither would directly correlate to the number of employees as a basis for tracking.

It was a surprise to all the banks I've heard from.
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#1152386 - 03/26/09 09:33 PM Re: SB 5651 Microenterprise Dev. Proj data collection RFitzpatrick
Chocaholic Offline
Gold Star
Joined: Aug 2005
Posts: 443
Northwest
I contacted the DFI to ask their expectations since the bank I do work for is a small bank under CRA and does not currently accumulate a lot of data. The response I got back was that the DFI did not require banks to collect anything beyond what our primary regulator requires (FDIC)in our case... so, go figure..

The best I can determine then, is if you currently accumulate data ( optional service test for small banks) then they will use it during a CRA exam... but if you don't collect/accumulate data you will be OK?

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