Community Developments Investments (May 2018)
A Look Inside …
Barry Wides, Deputy Comptroller for Community Affairs, OCC
The Office of the Comptroller of the Currency (OCC) recognizes the vital role that minority depository institutions (MDI) can play in improving financial outcomes for their customers and promoting the economic viability of minority and lower-income communities. Consistent with its mission of ensuring a safe and sound federal banking system, the OCC is committed to promoting the preservation of robust and healthy MDIs and, in so doing, fulfilling its congressional and regulatory responsibilities.1
Preserving MDIs is an important and timely goal for the nation and the OCC, which supervises national banks and federal savings associations (collectively, banks). MDIs represent a small2 but important part of the federal banking system because they often serve customers in minority, low- and moderate-income (LMI), and underserved communities. In addition, MDIs help to ensure that the nation’s vibrant and diverse banking system benefits the financial needs of all customers, businesses, and communities they serve.
This issue of Community Developments Investments highlights the OCC’s continuing efforts to support and encourage new and existing MDIs through collaboration roundtables. These roundtable discussions bring together the senior executives of MDIs and those of midsize and large banks. By collaborating with MDIs, the OCC believes, large and midsize banks can help MDIs better serve the credit needs of their communities, while expanding their own business opportunities, fulfilling strategic goals, and potentially receiving Community Reinvestment Act (CRA) consideration. These partnerships can be profitable for the parties involved and help MDIs fulfill their missions and serve customers in a rapidly evolving industry.
In 2015, the OCC issued a paper titled “An Opportunity for Community Banks: Working Together Collaboratively.” The paper highlighted the benefits of bank partnerships pooling or sharing resources to reduce costs, achieve economies of scale, and leverage specialized expertise to serve customers and communities, particularly those in minority and LMI communities. The OCC’s roundtable discussions, which began in 2016, are continuing, and some of the collaborations that came out of those initial meetings are highlighted in the articles “Citibank: Partnering With Community Banks to Expand Financial Access” and “Texas Capital and Texas National Banks: Collaborating for Mutual Benefit.”
Nonprofit organizations have been critical in facilitating collaborations. The National Community Investment Fund (NCIF), a nonprofit private equity trust and impact investor, is dedicated to supporting mission-oriented MDIs and other banks operating in and serving LMI communities. The NCIF’s goal is to channel financial products and services to LMI areas, minority communities, and other underserved areas. To encourage high-impact projects, the NCIF provides metrics and information that banks can use to analyze potential partnerships, projects, and CRA-qualified investments. The NCIF has also been using the New Markets Tax Credit Program as a way to bring critical resources into low-income communities and strengthen MDIs. The NCIF explains its work in “Catalyzing Impact: NCIF Fosters Bank Partnerships With MDIs.”
By highlighting MDI collaborations and resources in this publication, the OCC hopes to encourage similar collaborations. The OCC’s District Community Affairs Officers are available to answer technical questions, and the OCC’s website has helpful resources. In addition, MDI executives are encouraged to attend the OCC’s bank director workshops on risk governance, credit risk, compliance risk, and other important banking issues.
MDIs and midsize and large banks, as well as their customers, benefit from a healthy, diverse federal banking system. After reading this publication, you will better understand the important role that MDIs play in their communities. We hope you also will share the OCC’s commitment to ensuring the future viability and preservation of the nation’s MDIs.
1 Section 367 of the Dodd–Frank Wall Street Reform and Consumer Protection Act; OCC, “Policy Statement on Minority National Banks and Federal Savings Associations,” June 7, 2013.
2 Less than 3 percent of the depository institutions in the United States are MDIs. Only 30 percent of MDIs operated continuously throughout 2001 to 2013, compared with 57 percent of community banks, according to “Minority Depository Institutions: Structure, Performance, and Social Impact,” FDIC Quarterly, Volume 8, No. 3, 2014.