Trying to get an idea of what others might be doing or have done as far as assessing the needs of the communities you serve for CRA purposes....Any information/opinions would be appreciated

Lyndsey

The original requirement for a Community Needs Assessment has been watered down considerably. A formal written assessment is no longer required. However, examiners will expect you and others in the bank as residents of the community to know and be able to verbalize what the needs are.

What examiners have suggested is for a Bank to contact the Community Affairs desk of their agency and have them give you information on what your community needs are.

My opinions of what regulators are doing with this would be narrowed to words that do no exceed 4 letters in nature.

But, take a look around your community call some non profits ( They really don't bite) and ask then what they see as community needs. Call the city planning department. Are they working on redevelopment or rehab of areas. Ask someone on the school board what do the schools need. Are there any civic needs such as improved and expanded sewer systems the bank could float bonds for.

Of course their are very few communities that do not need low cost housing or job creation programs for LMI individuals.

Thank you for the response. I appreciate your input!

I strongly suggest that you identify any Enterprise Communities, Empowerment Zones and Renewal Communities as designated by HUD in your assessment area. Furthermore, you should contact your state DECD to see if there are any state-designated enterprise zones in your AA. These are areas targeted by Federal, state, local or tribal government for economic revitalization or stabilization and, as such, they present opportunities for community development activities. Recently we completed a CRA performance evalution for a bank that had 2 loans valued at more than $3 million that were located in Enterprise Zones that the bank did not know qualified the loans as community development! They had submitted their annual data without taking credit for these CD loans. Because we caught the error shortly after the filing deadline they were able to refile and have the data included in the A&D.
If you don't know how to identify these areas targeted by government entitities contact me. We are developing a national database of these zones that we will distribute to banks for a very modest fee.

Thanks again.