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#2227000 - 12/09/19 04:48 PM CD Investments in Rural Areas
TMatt87 Online
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TMatt87
Joined: May 2011
Posts: 1,987
Idaho
Our AA contains primarily rural areas. We always seem to struggle to find CD qualifying investments in our AA. Rural Idaho doesn't have much of an affordable housing issue, so there aren't a lot of LIHTC projects or investment funds available. We do invest in LMI mortgage backed securities in our AA, but at our last regional CRA conference, it was made clear that these investments were less desirable to examiners than other, more innovative investments.

So other than MBS, what kind of CD investments are other rural banks using?
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#2227096 - 12/10/19 05:19 PM Re: CD Investments in Rural Areas TMatt87
Pale Rider Offline
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under the Lone Star
How about digital and high speed internet to rural areas? Comb all your commercial loans greater than a million for LMI job creation or revitalize stabilize in LMI census tracts. It is a grind out in the boondocks.
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#2227106 - 12/10/19 06:39 PM Re: CD Investments in Rural Areas Pale Rider
Carolina Blue Offline
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Carolina Blue
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Lost in a regulatory fog
Not innovative, but we purchase CDs in minority owned financial institutions.

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#2227137 - 12/10/19 09:25 PM Re: CD Investments in Rural Areas TMatt87
TMatt87 Online
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TMatt87
Joined: May 2011
Posts: 1,987
Idaho
One of the problems we run into in our rural areas is that our census tracts are so large, they encompass the town and entire surrounding area, which includes a lot of farm ground. The people in the towns are likely LMI individuals, but the tract is almost always middle income because the rich farmers bring up the average income.
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#2227196 - 12/11/19 06:48 PM Re: CD Investments in Rural Areas TMatt87
Carolina Blue Offline
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Carolina Blue
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Lost in a regulatory fog
I'm not sure about other regulators but FDIC has said that investments in minority owned banks don't have to be in your assessment area. Here's the excerpt from the FIL (bold is my emphasis). Full FIL can be found here, https://www.fdic.gov/news/news/financial/2017/fil17064.html
Quote
Opportunities for CRA Consideration
In general, all financial institutions will receive consideration for activities that benefit geographies or individuals located within their geographically designated assessment area(s), or somewhere within a broader statewide or regional area that includes the institution’s assessment area(s) even if they will not benefit the institution’s assessment area(s), as long as the institution has been responsive to community development needs and opportunities in its assessment area(s). This is available whether partnering with an MDI or not, and is also available to partnerships between MDIs. If a non-minority owned institution wishes to reach beyond these geographic restrictions, additional CRA-eligible opportunities exist when financial institutions partner with minority or women-owned financial institutions or low-income credit unions (MWLI).7 The activities do not need to benefit the non-minority owned financial institution’s assessment area(s); however, they must help meet the credit needs of the local communities in which the MWLI is chartered.

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#2227219 - 12/11/19 08:32 PM Re: CD Investments in Rural Areas TMatt87
TMatt87 Online
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TMatt87
Joined: May 2011
Posts: 1,987
Idaho
The closest Minority owned FI to us is almost 700 miles away. While I understand that it doesn't have to be in our AA, that seems like a stretch.
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#2227222 - 12/11/19 08:42 PM Re: CD Investments in Rural Areas TMatt87
JobSecurity Offline
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What is your free/reduced lunch numbers? School bonds?

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