1. Developing Financial Institution Relations Presented at the Mayor’s Leadership Academy: Real Economic Impact Tour Boston, MA by: Kip Child, Community Affairs Specialist Boston Office, Federal Deposit Insurance Corp. September, 2011

2. CRA is a Two-Way Street Too often nonprofit organizations, including disability support organizations, rely solely on government sources for their funding Most all banks have established a charitable foundation CRA requires maintenance of a Public File

3. Observations from Community Development Roundtables Very few were familiar with the PE Even fewer had ever read one Why don’t banks link PE to their website? No comment letters – to bank or regulator

4. Disabilty Community Served by the VITA Program The Mayor’s EITC/VITA Coalition managed 21 VITA sites for the 2010 tax year. In 2006 12.9% of 6400 tax returns filed were for people with disabilities In 2010, 15.1% of 12000 tax return filed were for people with disabilities

5. People With Disabilities are Covered Under CRA, Fair Housing, ECOA, Fair Lending Help meet the “credit” needs of the communities they are chartered to serve, including those of low and moderate income Within a defined Assessment Area CRA

6. Protected Classes of Discrimination Race Religion Color National Origin Sex (plus 2) Marital Status Exercise of rights under the Consumer Credit Protection Act Age Receipt of Public Assistance Handicap or Disability Handicap or Disability Familial Status Familial Status State Laws State Laws F air H ousing A ct E qual C redit O pportunity A ct and the Under the -

7. Other Fair Lending Issues Disparate Impact Practices that seek to attract a selected group, but inadvertently (or not) prevent others from benefiting from the same program. May be neutral and non- discriminatory, but adversely affects the disabled. Disparate Treatment Treats people differently because of their membership in a protected class. Discriminatory intent does not have to be direct. Circumstantial will suffice Predatory Practices Inadequate or deceptive disclosures Fee packing or padding Loan flipping Unfair and Deceptive Acts and Practices Unfair=injurious, unavoidable, no other benefits Deceptive=misleading, under reasonable interpretation, material (alter decision to purchase or use).

8. Predatory Lending Is - Targeting vulnerable populations, on a consistent basis, that have insufficient education and limited financial options, for products and services that are unnecessary and/or priced substantially higher than any inherent credit risk would warrant.

9. Why Don’t Banks Reach Out More to Those With Disabilities? Cost/Benefit Use of Time Don’t Understand or Appreciate the Need Too many other demands Uncomfortable The Disability Community is easy to serve. It is very receptive to all forms of assistance.

10. HELLO! MY NAME IS _____ Reach out to financial institutions and identify yourself (“the devil you know…”) Suggest, to the institution, ways it might receive CRA credit by assisting your organization Establish some form of account relationship with the institution. Get to know love your banker

11. Activities That Qualify for CRA Credit Renovate Housing – Bath, Doorways, Garage, etc. Rework Van or Car Provide financial education services Match-fund IDA program Assist with bookkeeping Assist with grant writing Grants/Donations