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Having clear goals is critical to the success of a community coalition if its members expect the bank to consider its position for increased investment. CRA activism can position both the community and banks to win. There is a common interest between the community getting its financial needs met and the bank making a reasonable profit from its products.
A broad-based alliance of community-based organizations can become a powerful force. Balancing the size and diversity of a coalition is a key challenge for starting and managing a CRA campaign. Evaluate banking issues to assess which allies to recruit :
If a branch closes, reach out to seniors and merchants who need a local branch nearby.
If deposit accounts are too expensive, organize youth and low-income people who need low cost checking and savings accounts.
If lending is discriminatory, identify merchants who need small business loans; neighbors who need home purchase loans; seniors who need equity loans to fix up their houses; local and state regulators and politicians who can champion fairness in lending.
If significant capital is needed for revitalization efforts, work with labor unions who will secure construction and development contacts; congregations and nonprofit developers that have worked to develop a community plan.
Developing targets for the bank commitments is fundamental to successful CRA advocacy. Organizations should strive for the deepest commitments possible to secure resident stability and ensure development without displacement in low-income communities. Banks engaged in CRA negotiations should be pressed to adopt the targeted investment criteria:
| Target |
Goal |
| Culturally Appropriate Lending |
Develop flexible underwriting that responds appropriately to cultural borrowing habits of low-income people and people of color. |
| Affordable Housing Lending |
Single
Family Housing: Target loans to purchasers with incomes at or below
80% of median income; perform secondary review of denials. |
| Subprime Mortgage Lending |
Maintain a lending program that matches conventional loans in terms of fees charged, insurance required and other elements. Ensure cross-referrals to conventional mortgages. |
| Small Business Lending |
Confirm at least 50% of loans at or below $50,000; perform secondary review of denials. |
| Consumer Lending |
Match percentage of loans to low- and moderate-income borrowers to percentage of low- and moderate-income households in the bank's assessment area. |
| Consumer Services |
Provide free or low-cost checking accounts with low opening and balance requirements. |
| Marketing |
Utilize local minority-owned media companies; support counseling programs for loan programs. |
| Branch Distribution |
Open more full-service branches in low-income communities and communities of color; establish a clear procedure requiring community involvement before any branch is closed. |
| Community Investments |
Increase investments in local Community Development Financial Institutions; improve the position of equity investments for Community Development Corporations. |
| Capacity Grants |
Institute substantial grant programs to support capacity of community organizations, including community and housing developers. |
| Vendor Program |
Establish programs focused on purchasing from minority-, disabled-, and women-owned firms; clear accounting by type of owner |
| Rural Program |
Support programs that include self-help housing and other forms of rural assistance. |
| Meetings |
Agree to share specific data prior to semiannual bank meetings. |
| Diversity |
Provide a specific plan for diversifying the bank's top executive levels. |
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