Have any OCC regulated banks received CRA credit for investments with the SHCPF? In a former life, the OCC did give us credit for our investments. However, I've heard recently that some peer banks did not receive credit. I saw some posts dating back to 2012, but I was hoping someone got some form of feedback from the OCC more recently?

Thank you.

I attended the SHCPF convention 2 yrs ago in NYC and the OCC head of Compliance Policy, Grovetta Gardineer, spoke and stated the OCC actually helped put this program in place, and it does get CRA credit. However, management here has decided not to particpate at this time.

The new Q&A's published in November 2013 severely impact and reduce the credit for community development purposes of the SHCPF. In particular, Q&A § __.12(t) – 9 states:

"If an institution invests in (or lends to) an organization that, in turn, invests those funds in instruments that do not have as their primary purpose community development, such as Treasury securities, and uses only the income, or a portion of the income, from those investments to support the organization’s community development purposes, the Agencies will consider only the amount of the investment income used to benefit the organization or activity that has a community development purpose for CRA purposes."

So you will continue to get credit for participating in the program but the value will be diminished by at least 95% since the total loan value will not count, only the investment income value will be credited for CRA community development credit purposes.

Thanks Len.

My understanding is that the underlying investment must be for a community development purpose so why wouldn't a bank get full credit? What am I missing here?

Only the income from the investments is going toward community development, not the full amount. Reread Len's post above for the regulatory cite in the Q&A.

From talking to the Senior Crime Prevention Foundation, the underlying investment is required to be CRA qualified and therefore both the principal & interest can be counted.

It's a shell game. When you look at the money that is actually spent on the community development purpose, it isn't much.

The Q&A is interesting especially in light of the fact that I keep getting emails from various bank associations that are sponsoring free webinars on an "innovative way to get CRA credit" through the SHCPF.

Thanks for the info!

I can tell you that on our last CRA exam in 2012, the FDIC counted only 1.875% of the yield earned on our investment indicating that only this amount actually goes to support the low- and moderate- income seniors in the bank's assessment area.

I have to echo BankerBA. But we did get credit as one of our investments covered a Veteran's Home that was 80% LMI.