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#1733540 - 08/22/12 12:13 PM
Senior Housing Crime Prevention Foundation
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10K Club
Joined: Dec 2002
Posts: 40,766
Turnpike Exit 10
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Hello, we have made some considerable toans to this foundation in the sense that we were told they would be CRA qualified loans. I just received a missive from them stating that we may or may not receive CRA credit now. Has anyone had a CRA exam using SHCPF loans for CRA? What were the examiners' thoughts. We are OCC. Thanks!
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Get your facts first, then you can distort them as you please. - Mark Twain
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#1733545 - 08/22/12 12:28 PM
Re: Senior Housing Crime Prevention Foundation
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Power Poster
Joined: Jul 2002
Posts: 5,568
New Jersey
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What??!! I have a copy of a letter from an ADC of the OCC to a bank specifically stating that investment in or loans to the Senior Crimestoppers Program would qualify for CRA credit. The letter is dated in 2001, so perhaps the regulators have changed their position on this.
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Management is doing things right; leadership is doing the right things. Peter Drucker
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#1733555 - 08/22/12 12:47 PM
Re: Senior Housing Crime Prevention Foundation
Sinatra Fan
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What??!! I have a copy of a letter from an ADC of the OCC to a bank specifically stating that investment in or loans to the Senior Crimestoppers Program would qualify for CRA credit. The letter is dated in 2001, so perhaps the regulators have changed their position on this. SF, I will scan it and email you. OK?
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Get your facts first, then you can distort them as you please. - Mark Twain
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#1733614 - 08/22/12 02:26 PM
Re: Senior Housing Crime Prevention Foundation
Retired DQ
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Power Poster
Joined: Jul 2002
Posts: 5,568
New Jersey
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Thanks, I am going to reach out to them. They kepe narrowing the margins for CRA credit. I think we should just give free mortgages and write them off. My CEO has been saying that the regulators should just come up with a CRA assessment caluclation for each bank; bill us for the assessment; and give the money to some government program to waste spend.
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Management is doing things right; leadership is doing the right things. Peter Drucker
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#1733615 - 08/22/12 02:27 PM
Re: Senior Housing Crime Prevention Foundation
Retired DQ
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Joined: Dec 2002
Posts: 40,766
Turnpike Exit 10
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Thanks Al. I agree, SF. We shoudl just send them the money and let them do whatever the heck they want with it!
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Get your facts first, then you can distort them as you please. - Mark Twain
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#1733675 - 08/22/12 03:23 PM
Re: Senior Housing Crime Prevention Foundation
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Power Poster
Joined: Aug 2006
Posts: 4,266
Chillin an grillin
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Oh no. I've had an investment with them at my past FI but never any loans. I'm skeptical about the whole organization and try to stay away from them. Now here's another good reason.
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#1733687 - 08/22/12 03:40 PM
Re: Senior Housing Crime Prevention Foundation
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I am waiting on their response.
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Get your facts first, then you can distort them as you please. - Mark Twain
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#1733803 - 08/22/12 06:18 PM
Re: Senior Housing Crime Prevention Foundation
Sinatra Fan
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Joined: Aug 2002
Posts: 34,318
under the Lone Star
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Thanks, I am going to reach out to them. They kepe narrowing the margins for CRA credit. I think we should just give free mortgages and write them off. My CEO has been saying that the regulators should just come up with a CRA assessment caluclation for each bank; bill us for the assessment; and give the money to some government program to waste spend. Tell us how you really feel SF!
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#1734027 - 08/23/12 11:19 AM
Re: Senior Housing Crime Prevention Foundation
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OK, I found out the that regulators are drilling down to see what the qualifying collateral is for each loan; are they used by at least 50% LMI seniors?
SHCPF is conducting analyses 2Xs a year as of 2012 to determine the nursing homes/senior buildings/vet homes fall into the LMI area, and annually herreafter. Subsequently, these analyses will be provided to the lenders.
If your collateral is CRA qualified, full credit should be granted for the loan or investment, plus any annual interest given back to the SHCPF.
If the collateral is NOT CRA qualified, you may only get partial credit and that is for the interest only given up to the SHCPF.
The continued erosion of what qualifies for credit is making me sick.
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Get your facts first, then you can distort them as you please. - Mark Twain
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#1734037 - 08/23/12 12:05 PM
Re: Senior Housing Crime Prevention Foundation
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For more info: Their site: http://www.shcpfoundation.org/Relationship Mgr: George.Clinard@schpfoundation.org
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Get your facts first, then you can distort them as you please. - Mark Twain
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#1734040 - 08/23/12 12:28 PM
Re: Senior Housing Crime Prevention Foundation
Retired DQ
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Joined: Dec 2002
Posts: 40,766
Turnpike Exit 10
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:applauds Care4: Exactly. We all do 'community reinvesting' and support our towns, but this is driving me over the edge.
Re question: Medicare eligible and just basic LMI folk.
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Get your facts first, then you can distort them as you please. - Mark Twain
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#1764298 - 12/05/12 10:38 PM
Re: Senior Housing Crime Prevention Foundation
Retired DQ
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100 Club
Joined: Aug 2002
Posts: 133
SOMEWHERE
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If you are interested in this, you need to lay out a letter, way in advance of the investment, as to exactly how it will be structured (collateral, security to be used for the investment, etc.) and get approval specific to your circumstances prior to investing. And you are still not guaranteed. Our examiner said, "Just because someone else counted it erroneously, does not mean I should."
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#1962706 - 09/17/14 09:37 PM
Re: Senior Housing Crime Prevention Foundation
Retired DQ
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100 Club
Joined: Aug 2012
Posts: 241
South
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Okay, I keep seeing more and more about this Senior Housing Crime Prevention Foundation and how it will be 'guaranteed credit'.
It sounds interesting, could be a good way to earn credit... Is there anything I should know that I'm not reading from the pamphlets?
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The worst question is the one that goes unasked.
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#1974974 - 11/06/14 10:36 PM
Re: Senior Housing Crime Prevention Foundation
Retired DQ
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New Poster
Joined: Oct 2014
Posts: 8
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I suggest that everyone read the CRA Q&A that was publised last November. One questions was written specifically to clarify how an institution received CRA credit in a SHCPF type senario.
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#1975921 - 11/12/14 10:13 PM
Re: Senior Housing Crime Prevention Foundation
Retired DQ
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100 Club
Joined: Feb 2006
Posts: 128
DuPage County, IL
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Here in Chicago, I believe that the FDIC took the position that if, say you made a $2MM investment, you would only get CRA credit for the interest that was earned on the investment. Also, I would suggest that you look into their financials, before you make an investment. (And I'm not talking about the "Annual Report" that they send out, which, IMHO, is nothing but a marketing piece with no financial information.)
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#1975927 - 11/12/14 10:49 PM
Re: Senior Housing Crime Prevention Foundation
Retired DQ
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Diamond Poster
Joined: Dec 2013
Posts: 1,399
CA
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Stay away from this organization. The most recent Q & A's clarified that unless the underplying pledged investment was CRA qualified, you would only receive the 1% used by the organization. This is a for profit entity that uses your funds to provide "services" that already exist for free (i.e. Crimestoppers). I would not recommend them at all.
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The opinions expressed are mine, do not represent the opinions of my employer, and they are not to be taken as legal advice.
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#2022123 - 06/23/15 02:40 PM
Re: Senior Housing Crime Prevention Foundation
Retired DQ
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Platinum Poster
Joined: Oct 2004
Posts: 822
midwest
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We are a small community bank under CRA, recently received marketing type information from these folks. Has anyone been examined recently for CRA with SHCRF loans or investments used? We are an OCC bank. Also, is the November 20, 2013 FFIEC CRA Q&A issued the most recent regulatory guidance on this topic? Thanks.
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#2023899 - 06/29/15 08:56 PM
Re: Senior Housing Crime Prevention Foundation
Retired DQ
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Diamond Poster
Joined: Dec 2013
Posts: 1,399
CA
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Sorry to hear that Flyboat. Out of curiosity who is your regulator?
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The opinions expressed are mine, do not represent the opinions of my employer, and they are not to be taken as legal advice.
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