Community Development: The Economic Forum - The Community Reinvestment Act of 197710:00 AM
My first question regarding the CRA was "Who is keeping them accountable?" The video mentions an evaluation system which is actually completed by the Federal Financial Institutions Examination Council (FFIEC). You can view the exam schedule here. I tried searching for the exam schedule in my home town of Cleveland, but the process was a bit tedious and I can't seem to locate a small bank in the city. Exams are scheduled to occur every 48-60 months and members of the public may submit on a banks performance by commenting on FederalReserveConsumerHelp.gov.
Back in 2010 the CRA held public meetings in 4 major cities, Arlington, VA, Atlanta, GA, Chicago, IL, and Los Angeles, CA. These meetings were regarding the public's input on modernizing the CRA's regulations. The press release and call for comment collection was posted one (1) month before the first meeting was held in July of that year.
The public is also encouraged to engage with their local bank to create a Strategic Plan. The Act allow an institution to develop a plan with the community input detailing how the institution proposes to meet its CRA obligation. Here are the basics of the process:
- The bank informally seeks suggestions from the public
- Notice of the plan is published
- The public has 30 days of that publishing to comment
- The plan is submitted for approval
However, before I end this post I must be honest, the basic information and links provided above where the low hanging fruit. I still have yet to identify a bank that has been approved of a strategic plan in a predominantly-Black neighborhood, known to me anyway, and I can't find any information on what an example of "informally seeks suggestions" really means. The more research I do on the community development efforts of the Federal Reserve and all its supporting acts, policies, and affiliates I have found that they operate in an odd form of opaque transparency. One thing I may do at some point is call one of the banks listed that have an approved strategic plan to see if it is posted somewhere, ask how they collected their information, etc. as I am truly curious has to how this information is collected and the true turn time from suggestion to Fed approval. If I do so, I will be sure to update you all on it!
Until next time...