Community Developments Investments (January 2021)

Measuring the Impact of Qualified Opportunity Fund Investments

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Letty Ann Shapiro, Community Development Expert, OCC

Banks can view opportunity zone investing in two ways—as an attractive tax-advantaged investment and as a new community development tool to make a positive social and economic impact in communities they serve. With careful planning and implementation, banks may ensure both views come true.

To ensure positive, long-term economic and social impacts and avoid unintended consequences, banks such as Woodforest National Bank, and other investors, adopted the Guiding Principles and Reporting Framework for Opportunity Zones (OZFramework) with the goal of maximizing the social impact and economic returns from their investments in qualified opportunity funds.

The Beeck Center for Social Impact and Innovation at Georgetown University developed these guiding principles and reporting framework for opportunity zone investing in partnership with U.S. Impact Investing Alliance and the Federal Reserve Bank of New York. The partnership began in 2018 and released the framework in February 2019. The framework is designed to help banks and other investors ensure that their opportunity zone capital addresses the economic barriers facing low-income and underserved communities.

To develop the OZFramework, the partners convened training and work sessions with over 50 organizations representing community development investors, researchers, policymakers, and other stakeholders. The goal was to craft strategies for ensuring that opportunity zone investments result in long-term, meaningful, and inclusive community and economic development. This work resulted in the formation in June 2019 of the Opportunity Zones Investor Council. The council's 15 original members included investors, developers, and fund managers who debated ways to positively affect the nation's opportunity zones; cross-pollinate best practices; and develop new models for community investment.

The framework's five guiding principles for qualified opportunity funds are as follows:

• Community engagement: Integrate the needs of local communities, including low-income and underserved communities, into the formation and implementation of how the capital will be used and the types of projects funded.
• Equity: Seek to generate equitable community benefits, leverage other available incentives, and aim for the funds' responsible exits from the communities.
• Transparency: Engage in practices that are transparent, accountable, fair, and clear.
• Measurement: Monitor, measure, and track progress against expected impact objectives.
• Outcomes: Apply and track both quantitative and qualitative metrics to assess real changes in communities over time.

The framework recommends collecting, tracking, and reporting on basic transaction-level data, which enables measurement of the economic and social impacts of QOF activities. Transaction-level data include the size and location of the investment property; identification of commercial tenants; and the type of qualifying property.

In addition, the reporting framework recommends that projects collect the following data:

• Net new jobs created.
• Net new employees hired and maintained.
• New entrepreneurs (including whether they are women-owned or minority-owned enterprises and first-time businesses).
• Housing units built or renovated, including those identified as affordable housing.

Adopting the OZFramework can help banks, and other investors in qualified opportunity funds, measure the impact that fund-financed projects are having on their communities.

For more information, contact Letty Ann Shapiro at LettyAnn.Shapiro@occ.treas.gov.

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