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Nebraska Rural Development Commission More Than Just Money York, Nebraska July 29, 2010. Nebraska Department of Banking & Finance (NDBF) State agency supervising Nebraska state-chartered financial institutions jointly with the FDIC and the Federal Reserve Bank of Kansas City
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Nebraska Rural Development Commission More Than Just Money York, Nebraska July 29, 2010
Nebraska Department of Banking & Finance (NDBF) State agency supervising Nebraska state-chartered financial institutions jointly with the FDIC and the Federal Reserve Bank of Kansas City Office of the Comptroller of the Currency (OCC) Federal agency supervising all nationally-chartered banks in the US
Goals of this Presentation Provide update on Nebraska banking conditions Share information on community development investments that financial institutions may make Note the differences in Community Development Corporation activities allowed for state- and nationally-chartered banks Relate microenterprise development opportunities
How are Nebraska’s banks doing? March 31, 2010 NebraskaUS No. of banks 178 6,772 Annualized %ROA .99 (-.01)* 0.53 (+.44) % Unprofitable 10.67 (-.50) 18.43 (-10.95) % Non-perf. assets 1.54 (+.13) 3.47 (+.11) % Core deposits 67.26 (-6.20) 55.26 (-.82) *change since December 30, 2009
What types of community development? Area revitalization or stabilization Improving affordable housing and small business opportunities Helping attract and grow business and create jobs Equity/debt financing for small business Improving the quality of life by investing in neighborhood projects Strengthening community infrastructure
Guidelines for a Bank CDC State law has allowed banks to invest in CDCs since 1993 The CDC may be a for-profit or a non-profit corporation May be an investment in a multi-bank or multi-holding company CDC May be an investment in a community-based CDC (e.g., low- income housing) Maximum of 15% of Tier 1 capital for any one project The activities of a bank CDC may not expose the bank to unlimited liability
Permissible CDC Investments • OCC: CDCs of nationally chartered banks must fulfill one of the following-- • primarily benefit low-to-moderate income (LMI) persons • or areas • LMI defined as < 80% of the area median income • -Nebraska median income information available at • www.neded.org/files/crd/2010/CDBG/FY10_Census_NE_NonEntitled.xls • benefit areas targeted for redevelopment by a • government entity (city, county or state) • meet the definition of a “qualified investment” under the • Community Reinvestment Act
Permissible CDC Investments NDBF: The investments of CDCs of Nebraska state-chartered banks must be of a predominately civic, community or public nature and not merely private and entrepreneurial. The “wild card” allowed by state law allows a state bank to follow NDBF or OCC guidelines
Other activities of a CDC OCC: At least 51% of the CDC investments of a nationally-chartered bank must meet the aforementioned requirements; up to 49% of the investments of the CDC may be for any other lawful activity NDBF: NDBF defines “predominately” as 70% of the total investments of the CDC; a Nebraska state-chartered bank may invest the other 30% in any other lawful activity
Benefits of a Bank CDC • Double bottom-line investment: • -return on investment • -economic/community development • Potential for increasing the economic capacity of • the bank’s market • Demonstrate commitment to the area the bank • serves
Microenterprise Development Role of the Nebraska Enterprise Fund: Insure access to capital, training and technical assistance East Central Nebraska served through: CDR—statewide www.cdr-nebraska.org REAP—rural Nebraska www.cfra.org/reap EDGE—statewide http://nebraskaedge.unl.edu/ GROW Nebraska—statewide www.grownebraska.org
John MunnDirectorEmail: john.munn@nebraska.govPhone: (402)471-2845Fax: (402)471-3062www.ndbf.ne.orgAddress: Commerce Court, Suite 4001230 ‘O’ StreetLincoln, NE 68508-1402