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Community
Reinvestment Standards
I. LENDING
Access to credit is fundamental to economic vitality for Ohio’s families
and in building strong healthy communities. People of color and low-income
working people face real, current and historic barriers in acquiring credit.
All major Ohio financial institutions share responsibility to meet these
needs.
1. Fair Lending
• Lend to people of color and other protected classes at level at
least proportional to the populations of the area (e.g. 12% of Ohioans
are African American - some area have a higher percentage).
• Demonstrate aggressive efforts to reduce African-American and Hispanic
households’ loan declinations. At a minimum, there should be secondary
review by management staff and/or community review committees of all minority
declinations.
• Obtain a market share of minority loans at least proportional to
the financial institution’s share within its market area.
• Engage in aggressive and effective affirmative marketing activities
designed to attract potential minority and low-income applicants for home
mortgages. The marketing portion of its budget targeted at minority households
should be at least proportional to the minority population of the area.
2. Affordable Home Mortgage, Home Owner Rehab, and Home Refinancing
Lending
• Obtain a market share of loans to households between 30% and 80%
of area median income at least proportional to the financial institution’s
asset share within its market area.
• Offer a range of loan products, with down payment assistance or
no down payments, no private mortgage insurance, no minimum loan size,
no payment reserves, and special loan products to meet the needs of low
income households throughout the market area of the bank (in rural as
well as metro areas).
• Provide access to homebuyer counseling.
3. Rental Housing Development Financing -Development loans, lines
of credit for rental housing development, conventional financing
• Make available multi-family construction loans at 80% LTV or higher
and/or equity bridge loans for projects utilizing the Low-Income Housing
Tax Credit.
• Make available long-term, fixed-rate first mortgage loans for affordable
multi-family and single-family rental housing development.
4. Economic Development Lending
• Offer a wide range of products proportionately available to non-profit,
women and minority owned businesses and such as small business loans,
reduced interest rate product, mixed use loans (housing/commercial space),
and Micro enterprise loans.
• Make a significant number of non-government assisted small business
loans below $50,000 in low and moderate-income areas.
II. INVESTMENTS
1. Donations/Charitable Giving
• Donate a minimum of 2% of net profit to support community development
activities provided by homeless service, civil rights, non-profit housing/economic
development, advocacy and fair housing organizations.
• Match employee giving with equal or greater donations from the
financial service institution.
2. Tax Credit Equity
• Provide a proportional share of $50 million per year in equity
purchase of tax credits in Ohio based on the financial institution’s
total assets.
3. IOLTA - Interest on Lawyer Trust Accounts and IOTA - Interest
on Trust Accounts (Title Agents)
• Pay a net yield equal to or greater than half of prime.
• Participate in activities to improve yields through the Ohio Legal
Assistance Foundation.
4. Loan Pools
• Participate in loan pools and consortia to promote community development
and related activities such as Micro enterprise loans and head start facilities
funds (ie Community Development Finance Fund).
III. BANKING SERVICE
1. Cashing Government Checks
• Cash all state and federal government issued checks (ADC, Veterans
Benefits, Disability Assistance, SSI, Social Security, etc.) without any
service charges, or float period, for bank customers and non-customers
with adequate identification.
2. Low-cost Checking/Savings Accounts
• Allow an opening balance of $25 or less for checking or savings
account.
• Allow unlimited withdrawals from tellers.
• Allow service charge free savings accounts for active (1 or more
customer deposits/withdrawals annually) low balance accounts.
• Charge fees of no more than $3 per month for a basic low-volume
account.
• Allow customer 8 or more checks per month free.
3. Branches
• Increase number of full service branches within minority and low
income communities.
• Work with community groups to strategically locate ATMs, mini-branches
and other innovative approaches for banking services within minority and
low-income communities.
• Public notification of branch closings and notification to OCRP.
IV. OTHER BANKING POLICIES
1. Legislative Advocacy Support
• Work with housing advocates in support of federal and State housing
and community development issues, such as: Community Reinvestment Act,
HOME, CDBG, Fair Housing Initiatives, McKinney Homeless Assistance Grants,
Low Income Housing Tax Credit, etc.
2. Workplace Giving Programs
• Give equal access to alternative community based workplace giving
programs such as Community Shares, Black United Fund, in addition to the
United Way, so that employees have choice in their giving.
3. Minorities and Women in Decision Making
• Develop and implement aggressive hiring programs for minority and
women employees at every level - particularly in decision making and board
positions. Minorities and women should not be confined to “urban
lending” or “community affairs” positions, but should be
represented in decision-making positions throughout the financial institution.
4. Utilization of Minority, Women and Disabled Vendors
• Develop demographically reflective purchasing goals for minority,
women, disabled vendors and small business.
5. Leadership in Serving Minorities and Low-Income Communities
• The CEO of the bank should personally pledge that the financial
institution will be a leader in issues affecting the community and as
a matter of corporate policy, build alliances and partnerships with community
based organizations with the aim being to develop the most effective strategies
and products for servicing minority and low and moderate income communities.
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