Tag Archive for: banking

HAC CEO Responds to Executive Order Impacting Rural CDFIs

I’ve worked in enough small towns across America to know this: rural communities prosper when they have financial partners ready to invest in homeownership dreams and small business start-ups. A recent Executive Order targeting Community Development Financial Institutions has me concerned that rural America could lose access to the $6 billion in business CDFIs generate in their local economies.

For years, rural areas faced dwindling access to financial services. The number of rural headquartered banks fell by over 3,600 since 1995, an astounding 57% decline. Thankfully over that same 30-year period over 500 rural CDFIs have been created, filling gaps in the banking landscape of every State. And they do it effectively, leveraging $8 in private investment for every $1 in federal support. This has been especially helpful for local organizations with projects that are too small or specialized for the remaining banks or distant commercial lenders to finance.

HAC is one of those rural-serving CDFIs. Our work is supported by the resources the recent Executive Order is trying to undermine. We want to continue delivering real results for real people.

  • In Clearfield County, PA, where 45% of grandparents are raising grandchildren due to the opioid epidemic, HAC’s financing helped build the Village of Hope, a multigenerational affordable housing development designed for seniors and youth to live together.
  • In Pahokee, FL, our loan helped Diverse Housing Services breathe new life into Amaryllis Gardens, 44-units of workforce housing for employees of the surrounding farms.
  • In Visalia, CA, HAC’s $12 million in financing to Self-Help Enterprises has enabled over 300 low-income families to help construct their own homes as “sweat equity” downpayments.

The good news here is that the Executive Order is to be “implemented consistent with applicable law and subject to the availability of appropriations.” The CDFI Fund is not a discretionary policy—it’s embedded in federal statutes such as the Riegle Act, the Community Renewal Tax Relief Act, the Housing and Economic Recovery Act, and the Small Business Jobs Act. And funds for CDFI’s were included in this year’s appropriations and continuing resolutions.

It also helps that the CDFI Fund programs were created and supported by bipartisan consensus. Leaders across political lines and branches of government understand that rural America’s need for economic opportunity and stable housing is a shared national priority. We are encouraged by Treasury Secretary Bessent’s recent statement recognizing “the important role that the CDFI Fund and CDFIs play in expanding access to capital” and affirming that “CDFIs are a key component of President Trump’s commitment to supporting Main Street America.” For over 50 years, HAC has worked directly with rural policy-makers — Republican, Democrat, and Independent alike — to make affordable housing a reality. We hope that under the current Administration, the CDFI Fund will continue to be staffed and funded as Congress has legislated.

HAC stands ready to continue serving the millions of Americans who depend on the stability and opportunity CDFIs’ investments create. The path forward must strengthen, not undermine, our ability to serve hardworking rural families. They deserve nothing less.

HAC Submits Community Reinvestment Act Comments

 

The Community Reinvestment Act is essential to communities across the nation. Through CRA, financial services have been made available to many places that might otherwise be overlooked. In spring 2022 the three federal agencies that regulate banks and other lenders – the Office of the Comptroller of the Currency, the Federal Reserve Board, and the Federal Deposit Insurance Corporation – jointly issued a proposed new CRA rule. This proposal, and the many efforts which will follow, are critically important to ensure not only that current CRA-related activities and investments continue but that they expand to reach populations and communities for which access to affordable finance is still elusive.

This is especially important in rural communities across the country as many are considered high credit need areas. CRA modernization will help incentivize more lending in these areas and increase community development activities. As rural communities continue to change, the CRA must adjust as well to reflect modern lending practices. The proposed rule has the potential to further increase lending in high need rural areas, but HAC has a number of recommendations to optimize CRA’s impact.

HAC believes a final rule could further increase CRA’s impact on underserved rural communities if it:

  1. includes activities in rural communities as an additional impact factor, informed by the most precise, density-based definitions already used by policymakers and the research community;
  2. ensures uniform treatment of all CDFIs and supports the most transformative CDFI activities in underserved rural communities;
  3. modifies the definition of affordable housing to enable housing providers to respond effectively to the unique income demographics and constraints on government capacity of rural communities;
  4. clarifies how consequential the impact factors can be for a bank’s community development test performance and overall rating; and
  5. prevents banks with a substantial number of rural assessment areas from “gaming” the NPR’s performance benchmarks under the retail lending test.

To learn more about HAC’s full recommendations, read our full comment letter.

Other comments submitted to OCC are posted online and can be reviewed here.

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