Access to Capital and Credit 

For Small Businesses in Appalachia 

April 2007 

Appalachian Regional Commission 

Prepared by:

National Community Reinvestment Coalition 
2

You can view and download this report by visiting www.arc.gov or www.ncrc.org. 

For more information about the report, please contact either Gregory Bischak of the 

Appalachian Regional Commission (202-884-7790, gbischak@arc.gov) or Josh Silver of 

the National Community Reinvestment Coalition (202-464-2708, jsilver@ncrc.org) 

The authors wish to thank the Appalachian Regional Commission for providing the funding 

for the report. 

Appalachian Regional Commission 

1666 Connecticut Avenue, NW, Suite 700 

Washington, DC 20009-1068 

The Appalachian Regional Commission’s mission is to be an advocate for and partner with 

the people of Appalachia to create opportunities for self-sustaining economic development 

and improved quality of life. 

National Community Reinvestment Coalition 

1727 15th St. NW, Suite 900 

Washington, DC 20005 

NCRC’s mission is to increase fair and equal access to credit, capital, and banking services 

and products because discrimination is illegal, unjust, and detrimental to the economic 

growth of underserved communities in the United States and around the world. NCRC 

seeks to support, create, and implement long-term solutions, which include providing tools 

and strategies for building community and individual economic well-being. 

We would like to thank Josh Silver for his role as principal investigator and Milena Kornyl 

for her comprehensive quantitative analysis. We would like to thank our subcontractor, the 

Woodstock Institute and Geoff Smith for their timely and high quality work on this project. 

We also thank the Appalachian Regional Commission for their funding of this report. We 

thank ARC staff, in particular, Greg Bischak for his technical expertise and peer review 

regarding the econometrics, Ray Daffner for his vision in making this project possible, and 

William Grant for his expertise regarding the alternative financial institutions part of the 

report. 

 

© 2007 by the Appalachian Regional Commission and the National Community 

Reinvestment Coalition 

Reproduction of this document is permitted and encouraged, with credit given to the 

Appalachian Regional Commission and the National Community Reinvestment Coalition. 
3

 Table of Contents 

Executive Summary.............................................................................. 4 

Policy Options and Overview of Motivation and Methodology of Study 6 

Socioeconomic Profile of Small Businesses and Lending in Appalachia................. 12 

Mid-Size Banks and Government Backed Lending: Serving Communities and 

Businesses Most in Need of Credit?.............................................................................. 39 

Literature Review................................................................................. 

Regression Analysis of Small Business Lending in Appalachia........................... 

53 

67 

Assessing the Impact of CRA on Community Development Lending for Affordable 

Housing and Small Business in Appalachia.................................................. 91 

Alternative Financial Institutions in Appalachia............................................. 111 

Conclusion........................................................................................ 142 

Bibliography...................................................................................... 163 

Appendices: Appendix Tables 1 to 41......................................................... 165 

 

 
4

Executive Summary 

The Appalachian Regional Commission (ARC) contracted with the National Community 

Reinvestment Coalition (NCRC) to conduct this study as part of ARC’s effort to develop 

Appalachia through increasing access to credit and capital for small businesses. 

Heightened capital flows to small businesses would bolster the economic development of 

the region by creating jobs, diversifying the economy, and further developing an 

entrepreneurial class in Appalachia. This study found that banks have committed 

substantial amounts of community development financing to the region and are responding 

well to the credit needs of Appalachian small businesses in minority communities. The 

study recommends that stakeholders work together to close remaining credit gaps and 

needs in Appalachia. 

Mid-size community banks were particularly responsive to the needs of small businesses in 

lower income and distressed rural communities in Appalachia. These lending institutions 

demonstrate that small business lending is profitable and rewarding for banks. The 

challenge for stakeholders is to encourage all lending institutions to expand upon profitable 

lending opportunities and to further finance an infrastructure for supporting small business 

and economic development. 

The study used a number of databases including the Community Reinvestment Act (CRA) 

data on small business lending, data on bank branching obtained from the Federal Deposit 

Insurance Corporation, data from CRA exams, and data on Community Development 

Financial Institutions (CDFIs). The data also included U.S. Census data on population 

trends and Dun and Bradstreet data on the characteristics of small businesses. Based upon 

the report’s findings, policy options are presented to address financing gaps in nonmetropolitan areas and distressed counties, and among small businesses. 

This policy options focus on three broad areas: 

• Providing support and incentives for the development of bank branches and the 

growth of the community banking sector in non-metropolitan and distressed 

counties; 

• Increasing the capitalization and sustainability of Community Development 

Financial Institutions operating in the region, particularly loan funds and 

development venture capital funds; and 

• Ensuring the continued efficacy and impact of the CRA program and examinations. 

Many of these recommendations can be implemented by ARC working together with 

stakeholders in the Appalachian region. These stakeholders include state agencies, elected 

officials, lending institutions, federal regulatory agencies, the U.S. Department of Treasury, 

financial intermediaries, public finance markets, Federal Home Loan Banks, development 

organizations, and the Federal Reserve Banks.
5

Findings 

The reasons for an optimistic assessment of the ability of the Region to close identified 

capital and credit gaps include a favorable comparison between Appalachia and the nation 

on some indicators of lending. In addition, Appalachia has a lending infrastructure that 

includes about 227 banks and savings and loans with more than $500 billion in assets, and 

a sector of alternative lending institutions featuring over 100 community development 

financial institutions (CDFIs). 

The Community Reinvestment Act (CRA) has had a substantial impact in leveraging 

increases in community development lending and investing in the Appalachian Region. 

This study finds that banks and thrifts headquartered in Appalachia issued about $5.4 

billion in lending and investing for affordable housing, small business development, and 

economic revitalization each CRA exam cycle (about 2.5 years). In addition, the small 

business loan-to-deposit ratio for Appalachia was 35% higher than national levels. And, in 

contrast to most other regions in the country, small business lending was higher in counties 

with greater minority populations in Appalachia. 

 

Some additional positive indicators include: 

• Small and mid-sized banks in Appalachia (with assets less then $1 billion) were 

particularly oriented to the needs of small businesses in distressed and rural areas, 

having a higher market share of loans in economically distressed and rural counties. 

• Small business lending was higher in the Region in counties with higher levels of 

bank branches. 

Within Appalachia, small business lending was less accessible in non-metropolitan 

counties and counties experiencing economic distress. In addition, the smallest businesses 

with revenues under $1 million and businesses in low- and moderate-income communities 

experienced the least access to credit. In order to narrow differences in access to small 

business lending within Appalachia, concerted and persistent stakeholder efforts must be 

undertaken over a multi-year time period. Increasing access to small business lending 

would build the small business sector, create wealth, and stimulate job creation and 

economic development in Appalachia. 

Additional challenges include: 

• Non-metropolitan and distressed counties had considerably smaller shares of bank 

assets, which translated into non-metropolitan and distressed counties receiving less 

community development financing than metropolitan counties. 

• A relatively small amount of community development financing was devoted to 

small business development when compared to housing activities. 

This study also reviewed the role of alternative financial institutions in the Region, 

including Revolving Loan Funds (RLFs), microenterprise lending programs, community 
6

development credit unions and development venture capital funds. Overall, these 

community development financial institutions placed a strong emphasis on business 

lending, but were not financed by banks to the same extent as their national peers. Instead, 

these institutions relied to a much greater degree on capital from government sources. 

Related findings include: 

• Appalachian community development credit unions and venture capital funds were 

more self-sufficient than their national peers, while Appalachian community 

development loan funds and RLFs had lower self-sufficiency rates than the national 

averages. 

• ARC RLFs demonstrated declining deal flow while showing an increase in 

participation in individual loan transactions. 

• No Small Business Administration (SBA) 504 loans were originated to minority- or 

women-owned businesses in Appalachian distressed counties. 

This study updates the report commissioned by ARC in 1998 and conducted by Mt. Auburn 

Associations entitled Capital and Credit Needs in the Appalachian Region. Key findings 

of the Mt. Auburn report included that “insufficient financing appears to have a serious 

impact on the investment decisions of about one in five established companies,” and that 

small firms with less than 10 employees had higher levels of unmet funding needs than 

their larger counterparts. In addition, significant gaps were found in the provision of equity 

capital to growing firms in the Region. 

Policy Options 

Based upon the report’s findings, the following policy options are presented to increase 

access to credit and capital in non-metropolitan areas and distressed counties, and among 

small businesses. A number of these recommendations can be implemented by ARC 

working together with stakeholders in the Appalachian region. These stakeholders include 

state agencies, elected officials, lending institutions, federal regulatory agencies, the U.S. 

Department of Treasury, financial intermediaries, public finance markets, Federal Home 

Loan Banks, community development organizations, and the Federal Reserve Banks.

• Increase Branch presence, particularly in non-metropolitan areas and distressed 

counties – Since lending is higher in counties with higher number of branches, 

building bank branches, particularly in non-metropolitan and distressed counties, 

should be regarded as an important part of an economic development program. 

ARC, state agencies, and lending institutions should investigate New York State’s 

Banking Development District (BDD) Program. Begun in 1998, the BDD program 

offers partial property tax exemptions and encourages local public deposits for 

banks opening branches in geographical areas in need of banking services.1

 

1

 See http://www.banking.state.ny.us/pr980226.htm and http://www.banking.state.ny.us/pr050810.htm. Last 

accessed July 3, 2006. 
7

• Growth of the Community Banking Sector – Mid-size banks with assets between 

$250 million to $1 billion played important roles in small business financing, and 

focused their lending in non-metropolitan and distressed counties. Stakeholders 

should ensure that the mid-size and smaller bank sector remain viable and vibrant. 

Incentives could be developed to support existing mid-sized banks, or encourage 

the formation of new banking institutions in underserved areas. For example, the 

Federal Home Loan Bank System should consider additional advances and other 

incentives to support the small business lending of mid-size banks. Currently, the 

Federal Home Loan Bank of Pittsburgh operates a Banking on Business (BOB) 

program that provides financing for bank loans that would not otherwise be made 

due to insufficient cash flow from the small business. Since its inception, BOB has 

provided $20.5 million in funding, creating and retaining 3,500 jobs.2

 Likewise, the 

Federal Home Loan Bank of Atlanta runs the Economic Development Program that 

helps provide financing to small businesses.3

 

• Increase levels of community development financing for small business 

development – Banks located in Appalachia devoted significantly higher levels of 

community development lending and investing for affordable housing than small 

business development. This finding does not mean that community development 

financing levels for affordable housing should go down so that levels for small 

businesses can go up. Instead, it suggests that banks should be encouraged to 

increase their overall levels of community development financing and devote 

substantial portions of the increases towards small business development. 

• Support alternative financial institutions - Alternative financial institutions such as 

Community Development Financial Institutions (CDFIs) are important for 

increasing access to small business lending. Therefore, policy options include: 

- Expand sources of debt and investment capital for community 

development loan funds and venture capital funds. Appalachian 

Community Development Financial Institutions (CDFIs) and other 

community development financing entities need to expand their funding 

base. Community development loan funds and venture capital funds in the 

Region are heavily reliant on government sources for debt and investment 

capital. ARC can develop relationships with potential investors and 

regulatory agencies to encourage increased investment within Appalachia, 

including partnerships with financial intermediaries, participation in public 

secondary markets, and use of tax credit financings. 

- Appalachian loan funds must increase operational self sufficiency. 

Appalachian loan funds, both RLFs and microenterprise funds, should 

 

2

 See http://www.fhlb-pgh.com/housing-and-community/real-life-stories/banking-on-business.html, last 

accessed December 21, 2006. 

3 http://www.fhlbatl.com/fhlb_content.cfm?lev1=5cis&lev2=bcedp&lev3=2edp, last accessed December 21, 

2006. 
8

increase levels of self sufficiency by reducing operating costs or increasing 

revenues. 

- Increase depth of product offerings by community development lenders. 

To reach the smallest businesses with less than $1 million in revenues, the 

Appalachian community development lenders should increase their 

financing products beyond gap financing. These new products would target 

the smaller businesses that the banks currently have difficulty servicing. 

- Continue to grow capacity of Appalachian development venture capital 

funds. Available literature shows that there remains a significant gap in 

access to equity financing in non-metropolitan markets. ARC’s efforts to 

develop regional equity investment funds are important in bridging this gap 

and increasing regional entrepreneurship levels. 

• Maintain Integrity of CRA Exams and Data – The federal regulatory agencies have 

implemented new CRA exams for mid-size banks. Stakeholders should ensure that 

the integrity of CRA exams is preserved so that mid-size banks maintain and 

increase their levels of community development financing in Appalachia. In 2005, 

federal regulators also deleted the small business loan data reporting requirements 

for mid-size banks. Federal regulators should consider ways to continue to collect 

this data so that future studies can systematically examine the lending patterns of 

mid-size banks. Mid-size banks should continue to be encouraged to voluntarily 

report the data as many chose to do for the 2005 data submissions. While data 

collection imposes costs, the benefits can exceed those costs. The data can 

document positive trends and highlight new opportunities as revealed by this study. 

Moreover, data reporting motivates banks to maintain and increase their lending 

levels to small businesses.

• Encourage Small Business Administration (SBA)-guaranteed lending to MinorityOwned Businesses – The SBA should investigate ways to increase SBA-guaranteed 

lending to minority-owned businesses and in minority counties. It is possible that 

the relatively low levels of SBA-guaranteed loans to minority-owned businesses or 

businesses in minority counties were due to the relatively high levels of 

conventional lending to these businesses. Alternatively, it is possible that there are 

still certain types of credit needs that are not being filled by the conventional 

lending, opening up new opportunities for SBA-guaranteed lending. 

 

• Financial Counseling and Technical Assistance for Small Businesses – The study 

found that lending was higher in counties with higher portions of small businesses 

with the lowest risk credit scores. This suggests that lending will increase to small 

businesses overall if small businesses improved their credit scores. High quality 

financial counseling efforts are therefore important in Appalachia as a means to 

improve the credit scores of small businesses. In addition, technical assistance 

should be provided to improve the knowledge and skill level of small business 

entrepreneurs regarding cash flow, understanding financials, business planning and 
9

taxation issues. ARC, state officials, lending institutions, and community 

organizations should work together to intensify financial counseling directed 

towards small businesses in Appalachia.

• Better Understanding of Lending in Minority Counties in Appalachia – The report’s 

finding about higher levels of lending in counties with higher levels of minorities 

was a surprising and positive finding. Future research should be conducted to more 

fully understand why lending is unusually successful in reaching firms in counties 

with high levels of minorities in Appalachia. Lessons from this research should be 

applied to other regions of the country since the literature overall suggests serious 

barriers in access to small business lending for minority-owned firms.

Overview of the Background, Motivation and Methodology for the Study 

The Appalachian Regional Commission (ARC) contracted with the National Community 

Reinvestment Coalition (NCRC) to conduct this study as part of ARC’s effort to develop 

Appalachia through increasing access to credit and capital for small businesses. ARC is a 

federal-state partnership established in 1965 by the Appalachian Regional Development 

Act to promote economic and social development of the Appalachian Region. The Act, as 

amended in 2002, defines the Region as 410 counties comprising all of West Virginia and 

parts of Alabama, Georgia, Kentucky, Maryland, Mississippi, New York, North Carolina, 

Ohio, Pennsylvania, South Carolina, Tennessee, and Virginia—an area of 200,000 square 

miles and about 22.9 million people. 

For 41 years, the Commission has funded a wide range of programs in the Region, 

including highway corridors; community water and sewer facilities and other physical 

infrastructure; health, education, and human resource development; and economic 

development programs. The rationale for ARC’s Area Development program is to provide 

the basic building blocks that will enable Appalachian communities to create opportunities 

for self-sustaining economic development and improved quality of life. ARC goals 

particularly relevant for this study include increasing job opportunities and per capita 

income in Appalachia to reach parity with the nation, and strengthening the capacity of the 

people of Appalachia to compete in the global economy. 

Small business growth and development is integral to the efforts of ARC to increase 

employment and competitiveness. In Appalachia, primary metals sectors, such as steel, 

have lost over 20,000 jobs since 1994. Many of these losses have resulted from import 

penetration and plant relocations overseas. The Appalachian apparel industry has lost 

110,000 jobs since 1994, and the textile industry has lost 83,000. Over the last decade, one 

out of five jobs lost in textiles nationally occurred in Appalachia, and one out of three jobs 

lost in apparels occurred in Appalachia. 

In the face of large economic forces, ARC has been remarkably successful in channeling 

economic development investments. ARC’s investments have reduced the region's poverty 

rate by one-half, from 31 percent to 13 percent. Likewise, ARC has helped to lessen the 
10

per capita income gap between Appalachia and the rest of the U.S from 22 percent below 

the national average to 18 percent. This study provides critical insights into how and why 

ARC should leverage additional investments for small business development and growth. 

The NCRC study updates the report commissioned by ARC in 1998 and conducted by Mt. 

Auburn Associations entitled Capital and Credit Needs in the Appalachian Region. The 

Mt. Auburn study motivated a follow-up study focusing on bank financing because one of 

the key findings of the Mt. Auburn study was that “Appalachian businesses are heavily 

dependent on the banking industry for financing.” In addition, the Mt. Auburn study 

identified significant credit needs as “insufficient financing appears to have a serious 

impact on the investment decisions of about one in five established companies.” Further, 

the Mt. Auburn study indicated that small firms with less than 10 employees had higher 

levels of unmet funding needs than their larger counterparts. 

The Mt. Auburn study broke important ground through its use of surveys of Appalachian 

small businesses. The study did not benefit, however, from publicly available data on CRA 

small business lending. The CRA data for the year 1996 first became available in summer 

of 1997 when the Mt. Auburn study was well underway. In addition, researchers became 

much more familiar with the strengths and weaknesses of the database over the next several 

years. Thus, this study provides an important update to the Mt. Auburn report by utilizing 

the small business lending data and probing to what extent the unmet credit needs overall 

and for very small businesses still exist in Appalachia. 

Since the Mt. Auburn study, new trends and challenges confront Appalachia. The 

heightened pace of globalization, consolidation in the banking industry, the high cost of 

energy, and rising interest rates pose significant challenges as well as new opportunities for 

business development. Changes in the Community Reinvestment Act (CRA) and federal 

economic development programs likewise present a series of challenges and opportunities. 

For example, the federal New Markets Tax Credit program promises to provide a 

significant amount of resources for development in Appalachia. The program authorizes 

the Department of Treasury to provide tax credits of 39% on up to $15 billion of private 

investments in low-income areas for business development activities and small business 

lending. Nonprofit and private sector entities in Appalachia are just beginning to take 

advantage of this new program. 

NCRC’s study was able to consider the impact on small business lending of a number of 

these large economic changes such as consolidation in the banking industry and the 

growing use of credit scoring in small business lending. However, future studies will be 

needed to further evaluate the impact on access to credit of changes in federal programs 

and banking regulations as well as globalization and other economic structural adjustments. 

Methodology 

This report employed a number of datasets and created datasets for the quantitative 

analysis. For the analysis of small business lending trends, NCRC used the publicly 

available data on CRA small business lending. This data was combined with U.S. Census 
11

data on population demographics and Dun and Bradstreet data on business demographics 

and credit scores. In addition, data was obtained from the Small Business Administration 

(SBA) on SBA lending programs. Branch and deposit data was obtained from the web 

page of the Federal Deposit Insurance Corporation (FDIC). The section of the report 

analyzing community development lending and investing created a database consisting of 

data pulled from CRA exams of banks and thrifts located in Appalachia. Finally, the 

chapter on alternative financial institutions used data collected by public agencies, ARC, 

and trade associations of Community Development Financial Institutions (CDFIs). 

The CRA small business lending data analysis used the year 2003. A longitudinal data 

analysis was not employed because changes in the definitions of loans in the CRA small 

business data had a significant impact on annual loan volumes. In addition, the number of 

lenders required to report the data has changed. It is recommended that ARC commission a 

future study, using the CRA small business data as one of the resources. Such a study 

should carefully assess the influence of changes in the database on similarities and 

differences in lending patterns found in this current study and the future one. A similar 

caveat applies to the CRA exam analysis. The most recent CRA exam was used for each 

lender in this study. A future study can assess if levels of community development 

financing by banks increased or decreased by using the subsequent exams for each lender 

headquartered in Appalachia. 
12

Socioeconomic Profile of Small Businesses and Lending in Appalachia 

This chapter will first describe economic conditions in Appalachia. Appalachian region 

characteristics will also be described in reference to the nation. Population and business 

demographics are discussed, followed by a description of small business lending data. 

After reviewing national data, the chapter explores state level data, scrutinizing the 

differences and similarities among the 13 states in Appalachia. The chapter then describes 

trends on a county and census tract level. Here, the analysis separately considers 

metropolitan (MSA) and non-metropolitan (NonMSA) counties, distressed and nondistressed countries, and low- and moderate- income (LMI) census tracts. 

The data in this chapter describe the number of small non-farm businesses, small business 

(SB) loans originated to various types of small businesses as well as the distribution of 

small businesses by sector, number of employees and legal status. NCRC calculated 

several indicators that assess access to credit by small businesses in Appalachian Region. 

The lending data used in this chapter is publicly reported small business loan data per the 

requirements of the Community Reinvestment Act (CRA) regulations. The lending data is 

for the year 2003. Census data and small business demographic data from Dun and 

Bradstreet were also used. NCRC used CRA Wiz, produced by PCI Services, Inc., to 

analyze the small business data and the demographic data. 

Demographics and Economic Conditions 

Economic Conditions 

The Appalachian region includes 410 counties, comprising all of West Virginia and parts 

of twelve other states. It extends more than 1,000 miles from the southern New York to 

northeast Mississippi, and is home to over 23 million people. Despite recent progress, 

Appalachia still does not enjoy the same economic vitality and living conditions as the rest 

of the country. The region continues to battle economic distress, concentrated areas of high 

poverty, unemployment, low income, poor health, educational disparities, and population 
13

out-migration that are among the worst in the nation. Increased global competition and 

technological change have resulted in job losses and restructuring in many key 

Appalachian industries. Employment losses in non-durable goods and manufacturing and 

resource-based industries have been severe and disproportionately impacted much of the 

region. Some of these declines have been offset by employment growth in service sectors, 

but service sector average wages are often considerably lower than those in the goods 

producing sectors. 

A number of industrial sectors have been hit hard by job loss. Primary metals sectors, such 

as steel, have lost over 20,000 jobs since 1994. Many of these losses have resulted from 

import penetration and plant relocations overseas. The Appalachian apparel industry has 

lost 110,000 jobs since 1994, and the textile industry has lost 83,000. Over the last decade, 

one out of five jobs lost in textiles nationally occurred in Appalachia, and one out of three 

jobs lost in apparels occurred in Appalachia. An estimated one-third of the apparel losses 

and one-half of the textile losses are due to imports or plant relocations to other countries. 

Appalachian coal-mining employment has fallen from 101,500 workers in 1987 to 46,000 

in 2003, largely because of productivity gains. 

Within Appalachia, sub-regions confront unique challenges. Northern Appalachia, with its 

large population base and mature industrial base, must enhance the global competitiveness 

of its existing firms and stimulate new business creation to offset the impact of downsizing. 

Central Appalachia, once dominated by coal and tobacco, is struggling to diversify its 

economy. Southern Appalachia, influenced by its nearby large urban centers, strives to 

link its development to these engines of growth, and to cope with trade-related job 

displacement in labor-intensive manufacturing sectors.4

 

The context of sizable job loss and sub-regional economic development challenges informs 

the analysis of this report. Small business development is a key strategy to diversify into 

new industries. And access to credit and capital is integral to expanding small businesses 

in Appalachia. 

 

4

 Appalachian Regional Commission, FY 2006 Performance Budget Justification, 

http://www.arc.gov/index.do?nodeId=100. 
14

Population by Race 

The great majority of Appalachia’s population is white. In total, the white population 

constituted about 88% of the region’s population, African-Americans were 8.2% and 

Hispanics were only 2% of the total population (see Appendix Table 1 and Figure 1). 

Overall, minorities constituted 12.2% of total population. Predictably, the percent of the 

minority population in metropolitan areas was higher than in rural areas at 14.4% and 

9.25%, respectively. The percent of minorities in distressed and non-distressed counties 

were close to each other at around 12.5%. Finally, there were 371 counties where less than 

20% of population was minority, 41 counties with the percentage of the minority 

population between 20% and 50%, and only 6 counties where minority population 

constituted more than 50% of the total population. 

The percentage of African-Americans and Hispanics in Appalachia was lower than in the 

Nation. African-Americas were 12.1% of the nation’s population while they were 8.2% of 

Appalachia’s population. Hispanics were 12.6% of the nation’s population but just 2% of 

Appalachia’s population. Moreover, the difference between the percent of minorities for 

Appalachia and Nation is higher for MSA areas (around 19 percentage points) when 

compared to NonMSA areas (about 9 percentage points). For the nation, 34% of the 

population in metropolitan areas was minority compared to 14.4% for Appalachian 

metropolitan areas. In addition, 18% of population in non-metropolitan areas in the nation 

National Demographics Population by Race*

Hispanic

13 %

W hit e

69%

Ot her

6 %

A f rican- A merican

12 %

African-American Hispanic White Other

* 2000 Census

Appalachia Demographics Population by Race*

AfricanAmerican

8%

Hispanic

2%

White

88%

Other

2%

African-American Hispanic White Other

* 2000 Census

Figure 1 

Source: Appendix Table 1 – rows Nation Total and Appalachia Total. 
15

was minorities and only 9.25% of non-metropolitan population in Appalachia was 

minorities (see Appendix Table 1). 

Business Demographics 

Comparison of Appalachian and National Business Demographics 

In general, the distribution of businesses by sector and other demographics was similar in 

Appalachia and the nation (see Appendix Table 2 and Figure 2). The largest industry was 

services (36.8% of all the businesses in Appalachia and 37.9% in the U.S. are service small 

businesses). The second largest was retail trade (17.9% in Appalachia and 15.9% in the 

U.S.). In NonMSA areas, the percent of agricultural small businesses was higher in the 

nation than in Appalachia, 9.8% and 5.1%, respectively. For the category of retail trade, 

NonMSA Appalachia had a higher percent of small businesses than rural areas in the 

nation; 19% and 16.6%, respectively. 

When the size of a small business was concerned, about 58.6% of small businesses in 

Appalachia and 58.4% in the nation had 1-4 employees (see Appendix Table 9 and Figure 

Composition of Small Businesses by Sector 

in the Nation

Retail Trade

16%

Services

38%

Other

38%

M anufacturing, 4% Agriculture

4%

Agriculture Manufacturing Retail Trade Services Other

Composition of Small Businesses by Sector 

in Appalachia

Agriculture

4%

Retail Trade

18%

Services

37%

Other

37%

M anufacturing, 4%

Agriculture Manufacturing Retail Trade Services Other

Figure 2 

Source: Appendix Table 2 – rows Nation Total and Appalachia Total. 
16

3). The distribution in larger size categories was also similar when comparing Appalachia 

to the nation. 

Composition of Small Businesses by Firm Size 

in Appalachia and Nation

58.6%

10.2%

5.7% 4.1% 2.7%

18.7%

58.4%

9.5%

5.6% 4.0% 2.6%

20.0%

0.0%

10.0%

20.0%

30.0%

40.0%

50.0%

60.0%

70.0%

80.0%

90.0%

100.0%

1 - 4 Employees 5 - 9 Employees 10 - 19 Employees 20 - 49 Employees 50+ Employees # Employees Not

Known

Percent of Businesses

Appalachia Nation

In addition, a significant amount of small businesses nationwide and in Appalachia lack 

legal status information; 44.9% and 45.1%, respectively. When removing businesses with 

legal status unknown, Appendix Table 4 and Figure 4 show the percent of sole ownerships 

was higher in Appalachia than the nation (49.1% versus 45.8%) and the percent of 

corporations was lower in Appalachia (44.7% versus 48.3%). 

Composition of Small Businesses by Legal Status 

in Appalachia and Nation

49.1%

6.2%

45.8% 44.7%

6.0%

48.3%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Sole Ownership Partnership Corporation

Percent of Businesses

Appalachia Nation

Figure 4 

Figure 3 

Source: Appendix Table 3 – rows Nation Total and Appalachia Total. 

Source: Appendix Table 4 – rows Nation Total and Appalachia Total. 
17

Sectoral Distribution within Appalachia 

Appendix Table 5 represents information on the number of businesses in each sector by 

state. The Appalachian region had a large service industry: the percent of service small 

businesses was 36.8% of the total number of small businesses. The second largest sphere 

was retail trade (17.9%) and third largest was construction at 8.6% of all small businesses. 

There were not many outliers in terms of the sector structure among Appalachian states. In 

other words, each state had approximately the same percent of small businesses in each 

sector. Only in Ohio the percent of agricultural small businesses was much higher than the 

aggregate for the region, 7.9% versus 3.7%. One of the possible explanations could be that 

Ohio Appalachian counties were located in less mountainous areas than the rest of the 

Region. In contrast, since a number of West Virginia counties were mountainous, the 

percent of mining small businesses there was higher than for Appalachia in total, 0.9% 

versus 0.3%. 

The analysis also compared the sectoral distribution of small businesses in MSA and 

NonMSA counties (see Appendix Table 6a). Overall, the percentages were rather close 

except for agricultural and services. In particular, the percent of agricultural small 

businesses was higher in NonMSA than MSA counties (5.1% versus 2.9%) and the percent 

of service sector small businesses was higher for MSA than NonMSA counties (38.1% 

versus 34.7%). The analysis of the sectoral distribution of small businesses in distressed 

and non-distressed counties revealed interesting differences (see Appendix Table 6b). In 

distressed counties, the percent of mining small businesses was higher and percent of 

construction and finance small businesses was lower. Also, the percent of transportation 

and retail small businesses was higher in distressed counties compared to non-distressed 

counties (5.8% versus 3.9% for transportation and 20.2% versus 17.8% for retail trade). 

Distribution of Businesses by Number of Employees 

Appendix Table 7 examines the distribution of small businesses by the number of 

employees. The smallest businesses, with the number of employees from 1 to 4, comprised 
18

the largest portion of all the small businesses in the Appalachian region (more than 58% of 

all small businesses). The second largest category was small businesses with 5 to 9 

employees (10.2%). The larger small businesses with number of employees exceeding 10 

comprised only 12.5% of total number of small businesses. A similar composition of small 

businesses by number of employees was observed in each state.

The composition of small businesses by number of employees in MSAs versus NonMSAs 

and distressed versus non-distressed counties shows that percentages of small businesses by 

size were close in each of these geographical areas (see Appendix Table 8). 

Legal Status of Small Businesses 

Appendix Table 9 illustrates the distribution of small businesses by legal status in each 

state. The data revealed that almost half of all small businesses (45% in Appalachia) did 

not provide information on the legal status of their businesses. To adjust for the large 

number of businesses with legal status unknown, this category was excluded from the 

analysis and the tables. 

Of reporting small businesses, sole ownerships and corporations constituted respectively, 

49.1% and 44.7%, of small businesses in Appalachia. Partnerships comprised only 6.2% of 

all the small businesses. There were some outliers in this distribution on a state level. The 

percent of sole ownerships in Georgia and South Carolina (43.7% and 44.3%, respectively) 

was lower than for Appalachia in total (49.1%). On the other hand, the percent of 

corporations in those states (51.4% for Georgia and 49.9% for South Carolina) was higher 

than the regional total of 44.7%. In addition, the percent of sole ownerships in Ohio 

(55.2%) was higher and the percent of corporations (38.7%) was lower than the 

Appalachian total. 

Comparison of MSA and NonMSA regions shows that percent of sole ownerships in 

NonMSA counties was higher than in MSA counties by almost 7 percentage points (see 

Appendix Table 10a). In addition, the same pattern can be observed when distressed 
19

counties were compared to non-distressed; the portion of sole ownerships was higher in 

distressed counties by 2.7 percentage points (see Appendix Table 10b). This phenomenon 

can be possibly explained by a greater portion of local businesses versus franchises in rural 

and distressed counties. The higher share of sole ownerships in Appalachia as a whole and 

in rural and distressed counties might reflect an entrepreneurship of necessity; that is, 

Appalachian residents may establish small businesses because of the paucity of wage and 

salary jobs. 

Lending Analysis 

This section provides an extensive analysis of small business lending trends in the 

Appalachian region. A descriptive lending analysis becomes richer when keeping in mind 

the demographics of the small businesses. As discussed above, the demographic 

composition of small businesses was similar for the nation and Appalachia. Like the 

nation, the largest percentages of small businesses in Appalachia were in the services and 

retail sectors. Similar to the nation, almost 60 percent of the small businesses in 

Appalachia had just 1 to 4 employees. Unlike the nation, however, a slightly larger portion 

of Appalachian businesses were sole ownerships as opposed to corporations. Overall, the 

data reflected lending to very small businesses with just under half of the small businesses 

in Appalachia in the services and retail sectors. The small business lending data was for 

the year 2003. 

Comparison to the Nation 

Like business demographic indicators, lending indicators overall for Appalachia were close 

to the respective indicators for the nation. Appendix Table 11 and Figure 5 show that 

41.7% of small businesses nationwide received small business loans whereas the figure for 

Appalachia was 41.4% during 2003. For small business (SB) loans to small businesses 

with revenues less than $1 million, the indicators were 25.3% for the nation and 28.4% for 

Appalachia. Almost 41% of Appalachian NonMSA small businesses received SB loans 
20

and 39.5% of national NonMSA small businesses received loans. For MSA areas, these 

indicators were 42.2% for the nation and 41.7% for Appalachia. 

The percentage point difference in the ratio of loans to small businesses between MSA and 

NonMSA areas for the nation was higher (around 3 percentage points) than for Appalachia 

(less than 1 percentage point). For the nation, 42.2% of the businesses in MSAs received 

loans whereas 39.5% of the businesses in NonMSA areas received loans. For Appalachia, 

41.7% of small businesses received loans in MSA areas and 40.9% of small businesses 

received loans in NonMSAs. 

Deposit and branching information is presented in Appendix Table 12. It demonstrates that 

the small business loan-to-deposit ratio was higher for Appalachia (7%) than for the Nation 

(5.2%). The ratio was also higher for Appalachian MSA and NonMSA counties. For 

example, the loan-to-deposit ratio in Appalachian NonMSA counties was 7.2% and was 

5.8% for NonMSA areas in the Nation. 

Branches were more accessible in Appalachian MSAs than national MSAs, but were less 

accessible in Appalachian NonMSAs than national NonMSAs. Access to branches is 

measured by the number of persons per branch. A higher number of persons per branch 

41.4% 41.7%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Appalachia Nation

Percent of Small Businesses Receiving Loans

28.4% 25.3%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Appalachia Nation

Percent of Small Businesses with Less than $1 

million in Revenues Receiving Loans

Figure 5 

Source: Appendix Table 11 – rows Nation Total and Appalachia Total 

and columns # SB Loans/#SB and # SB loans to SB with =<1mln) / #SB (<$1mln). 
21

generally indicate that branches are less accessible since one branch has to serve a larger 

population. The number of persons per branch in total was higher for the Nation (3,244) 

than for Appalachia (2,896). The same pattern could be observed for MSAs. In contrast, 

for NonMSA counties, the number of persons per branch was higher in Appalachia by 

more than 500 people during 2003. 

When examining small business lending per branch, national MSAs were served better than 

Appalachian MSAs but Appalachian NonMSAs were served better than national 

NonMSAs. The number of small business loans per branch was significantly higher for the 

nation as a whole than for Appalachia. The number of loans per branch was 85.6 for the 

nation and 63.6 for Appalachia. For MSA counties, these figures were 98 and 67.8, 

respectively. However, for NonMSA counties the number of SB loans per branch was 

higher for Appalachia (57.5) than for the whole nation (53.2) (see Figure 6). 

Number of Small Business Loans per Branch

98.0

57.5

67.8

53.2

0

20

40

60

80

100

Metro Areas Rural Areas

Appalachia Nation

Appalachia also compared favorably to the nation when considering small business lending 

by minority level of county (see Appendix Table 13). Appalachia contains 371 counties in 

which the minority level is between 0 and 20% of the population; 41 counties contain 20% 

to 50% minorities. Only 6 counties have a minority level above 50% and all of them are 

Figure 6 

Source: Appendix Table 12 – column SB Loans/# branches and rows MSA (Nation and Appalachia) 

and NonMSA (Nation and Appalachia)
22

distressed counties5

. NCRC found that for Appalachia, higher levels of minorities were 

associated with higher loans-to-SB ratios, meaning that in minority counties a higher 

percentage of small businesses received loans. In Appalachian counties with less than 20 

percent minorities, the loan to small business ratio was 39.4 percent while in counties with 

20 to 50 percent minorities, the ratio was substantially higher at 51.4 percent in 2003. In 

counties with more than 50 percent minorities, the ratio was 53.4 percent. Map 1 below 

shows that the loans-to-SB ratio was usually higher in counties with substantial minority 

populations than the regional loans-to-SB ratio. In addition, the difference between the 

ratios for counties with low minority level and high minority levels was also favorable for 

the counties with more minorities when considering loans to small businesses with less 

than $1million in revenues. 

 

5

 For the descriptive analysis part of the report NCRC treated eight cities in Virginia as “county equivalent” 

even though they lost this status. So, the total number of counties is 418. However, this treatment of Virginia 

geographical areas does not influence the report’s findings as verified through sensitivity analysis. 

24

In contrast to Appalachia, national level data revealed little difference between counties in 

these minority groups. In particular, 40.2% of small businesses in high minority counties 

received loans, 42.4% of small businesses received loans in counties with 20% to 50% 

minorities, and 41.8% of small businesses were reached in low minority areas (see 

Figure 7). 

Percent of Small Businesses Receiving Loans 

by Minority Level of County

39.4%

51.4% 53.6%

41.8% 42.4% 40.2%

0%

20%

40%

60%

80%

100%

0-20% Minority in County 20-50% Minority in County >50% Minority in County

Appalachia Nation

Due to the relatively small number of high minority counties, the correlation between 

minority level and the percentage of small businesses that received loans needs further 

investigation. One interesting fact was that of the 47 counties with more than 20% 

minorities, 32 or 68.1% were in Alabama and Mississippi, while only 29 counties or 7.8 % 

of the 371 counties with minority level less than 20% were located in Mississippi and 

Alabama. Mississippi and Alabama could be experiencing faster economic growth than the 

rest of Appalachia. 

In conclusion, even though business demographic and small business lending indicators for 

Appalachia were close to the respective national data, the number of SB loans per branch, 

Figure 7 

Source: Appendix Table 13 – column # SB Loans/#SB and rows 0-20% (Nation and Appalachia), 20-

50% (Nation and Appalachia) and >50% (Nation and Appalachia)
25

SB loan-to-deposit ratio and number of persons per branch were significantly different.6

 In 

terms of the number of branches per people, NonMSA Appalachian counties appeared 

underserved compared to the nation whereas MSA Appalachian areas outperformed 

national MSA areas. However, in terms of SB loans per branch, Appalachian NonMSA 

areas outperformed national NonMSA areas. In addition, SB loan-to-deposit ratios were 

higher in Appalachia than the nation. On some macro indicators of small business lending, 

Appalachia appeared to compare favorably to the nation. But differences in meeting small 

business credit needs emerged within Appalachia (as detailed below). 

State Level Analysis 

Detailed analysis on a state level focuses on branching, deposit and loan information for 

Appalachian counties aggregated by state and examined in various dimensions. 

Appendix Table 14 reveals that 41.4% of small businesses received loans in Appalachia. 

The Appendix Table and Figure 8 also illustrate that in the Appalachian portion of 7 states 

the ratio was higher than the regional total and in Appalachian portion of 6 states the ratio 

was lower than the regional total. In particular, the three states with the lowest ratios were 

Kentucky (32.5%), West Virginia (32.9%), and Pennsylvania (33.7%); and the three states 

with the highest ratios were Mississippi (58.1%), Alabama (56.1%), and Maryland (49%) 

during 2003. 

 

6

 The descriptive analysis in this chapter does not control for per capita differences or other economic and 

demographic differences. The regression analysis below controls for a number of economic and 

demographic characteristics. 
26

Percent of Small Businesses Receiving Loans

32% 33% 34%

38% 38% 40% 41% 44% 45% 47% 48% 49%

56% 58%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

KY

WV

PA

NY

OH

VA

Appalachia

TN

SC

GANC

MD

AL

MS

Examining the ratio of the number of loans to small businesses with less than $1million in 

revenues shows that a few states switched positions (see Appendix Table 14). The three 

states where the ratio was the highest were Mississippi (66.2%), Alabama (40.8%), and 

Georgia (33.9%). The lowest ratios were in Pennsylvania (20.8%), West Virginia (21.4%), 

and Ohio (22.6%). 

Overall, in Appalachia only 28.4% of small businesses with revenues less than $1 million 

received small business loans in 2003. In other words, small businesses with revenues 

under $1 million received fewer loans relative to all small businesses combined (41.4% of 

all small businesses received loans versus 28.4% for small businesses with less than $1 

million in revenues). 

Another ratio worthy of examination is SB loans under $100,000 divided by the number of 

small businesses because loans under $100,000 are typically needed by smaller businesses. 

The patterns for the ratio between the number of SB loans of less than $100,000 and 

number of SBs were similar to the trends for the total number of SB loans. The three states 

with the highest ratios were Mississippi (52.5%), Alabama (49.5%) and Maryland (44.8%). 

Figure 8 

Source: Appendix Table 14 – column # SB Loans/#SB 
27

The lowest ratios were in Kentucky (30%), West Virginia (30.1%) and Pennsylvania 

(31.1%). 

The ratio of SB loans to deposits is yet another measure of lending activity. Georgia, 

Mississippi and Alabama had the highest loan-to-deposit ratios, 11.3%, 10.5% and 9.6%, 

respectively. On the other hand, the lowest ratios were in Kentucky (4.4%), Pennsylvania 

(4.7%) and Virginia (4.8%). 

The number of persons per branch also shows the level of services provided by banks. 

Higher numbers of people per branch reveal a lower supply of branches.7

 The states with 

the highest number of persons per branch (or the lowest supply of branches per capita) 

were Georgia (5,025), Alabama (3,156) and North Carolina (3,096) (see Figure 9). The 

lowest number of people per branch was in Virginia (2,174), Maryland (2,233) and 

Kentucky (2,388). 

Number of Persons Per Branch

0

1,000

2,000

3,000

4,000

5,000

6,000

VA

MD

KY

MS

PA

OH

TN

WV

Appalachia

SC

NY

NC

AL

GA

Persons

Interestingly, Southern States often performed the best on small business lending 

indicators. Midwestern states tended to perform worse that their peers. 

 

7

 This analysis does not explicitly take into account that a lower number of people per branch may be due to 

sparse population or low population density in some counties. Nonetheless, statewide ratios are still 

suggestive of differences in branching across Appalachia. 

Figure 9 

Source: Appendix Table 14 – column Number of persons per branch 
28

States by Metropolitan and Non-Metropolitan Areas 

The MSA/NonMSA analysis presented in Appendix Table 15 shows that lenders served 

businesses better in MSAs than NonMSA counties. For the region in total, the ratios were 

close; 41.7% of the businesses in MSAs received loans and 41% of the businesses in 

NonMSAs received loans. In nine states, however, the ratio of loans per small businesses 

was higher in MSAs than NonMSAs. For example, in Alabama 58.6% of businesses 

received loans in MSA counties and 48.6% of small businesses received loans in NonMSA 

counties. Likewise, 37 percent of the small businesses received loans in MSAs while 31.2 

percent of the businesses received loans in NonMSA counties in Kentucky. In contrast, in 

Georgia, New York and Pennsylvania, the percent of small businesses that received SB 

loans in MSA counties was lower than in NonMSA counties. In Georgia, 50.6% of small 

businesses in NonMSA counties received loans and only 44.7% of small businesses 

received loans in MSAs. Map 2 and Table 1 below display lending trends in MSA and 

NonMSA counties. 

Percent of Small Businesses Receiving Loans in Metro and Rural Areas for Each State 

 

State AL GA KY MD MS NC NY 

 Metro Rural Metro Rural Metro Rural Metro Rural Rural Metro Rural Metro Rural 

All 

Businesses 58.6% 48.6% 44.7% 50.6% 37.0% 31.2% 49.1% 48.8% 55.5% 48.3% 47.0% 38.1% 38.7% 

Businesses 

with <$1 

million 

41.8% 38.0% 27.8% 46.5% 27.3% 22.7% 27.0% 31.5% 55.8% 29.1% 30.8% 20.4% 24.7% 

Table 1 
29

 

State OH PA SC TN VA WV 

 

Metro Rural Metro Rural Metro Rural Metro Rural Metro Rural Metro Rural 

All 

Businesses 39.9% 37.5% 33.2% 35.3% 45.1% 40.3% 45.4% 42.1% 47.8% 38.4% 34.6% 31.5% 

Businesses 

with <$1 

million 21.9% 22.8% 20.1% 22.9% 28.7% 21.5% 33.5% 32.1% 40.5% 26.3% 20.8% 21.8% 

 

State Appalachia 

 

 

Metro Rural 

 

All 

Businesses 41.7% 41.0% 

Businesses 

with <$1 

million 26.9% 30.9% 

Source: Appendix Table 15 columns #SB loans/#SB and #SB loans to SB =< 1 mln/#SB (<1 mln); rows 

MSA and NonMSA for each state. 

The ratio showing the percent of small businesses with less than $1 million in revenues that 

received loans had a larger discrepancy between MSA and NonMSA counties in 

Appalachia than the ratio for all small businesses and all loans. In particular, 26.9% of 

small businesses with less than $1 million in revenues received loans in MSA areas 

whereas 30.9% of such businesses received loans in NonMSA areas during 2003. This was 

a difference of 4 percentage points whereas for all small businesses the difference in MSA 

versus NonMSA counties was less than 1 percentage point. In addition, in the Appalachian 

portion of seven states, businesses with revenues less than $1 million received a higher 

percent of loans in MSA than NonMSA counties. Overall, small businesses with revenues 

less than $1 million had less access to loans than all businesses as measured by the loans 

per small business ratio. Interestingly, however small businesses with revenues less than 

$1 million had greater access to loans if they were located in Appalachian NonMSA 

counties than if they were located in MSAs as revealed by the loans per small business 

ratio. 

31

Distressed and Non-Distressed Counties 

Appendix Table 16 and Table 2 show lending patterns for distressed and non-distressed 

counties.8

 Overall, the percent of small businesses that received SB loans was higher for 

non-distressed counties -- 32.1% of the businesses in distressed counties as opposed to 

41.9% for non-distressed counties. Map 3 below clearly displays the lower loan to small 

business ratios for distressed counties. Similarly, for non-distressed counties 28.5% of 

small businesses with less than $1 million in revenues received loans and 26.7% of these 

businesses received loans in distressed counties. As for the loans of less than $100,000, 

38% of small businesses received these loans in non-distressed counties and 29.9% in 

distressed counties. 

Percent of Small Businesses Receiving Loans in 

Distressed and Non-Distressed Counties 

 

% of Loans 

to Small 

Businesses 

% of Loans 

to Smallest 

Businesses* 

% of Loans less 

than $100,000 

 

Distressed 32.12% 26.71% 29.90% 

 

Non-distressed 41.91% 28.51% 38.01% 

 

* "Smallest Businesses" are businesses with less than $1 million in Revenues, 

Source: Appendix Table 16, columns #SB loans/#SB 

 

8 For FY 2005, the Appalachian Regional Commission defines distressed counties as those counties that have a threeyear average unemployment rate that is at least 1.5 times the U.S. average of 4.8 percent; a per capita market income (less 

transfer payments) that is two-thirds or less of the U.S. average of $26,309; and a poverty rate that is at least 1.5 times the

U.S. average of 12.4 percent; OR they have 2 times the U.S. poverty rate and qualify on the unemployment or income 

indicator. 

The U.S. average and the distressed county level for each indicator are as follows: 

U.S. Average Distressed County 

Three-Year Average Unemployment Rate (2000-2002) 4.8% 7.3% or more 

Per Capita Market Income Less Transfer Payments (2001) $26,309 $17,627 or less 

Poverty Rate (2000) 12.4% 18.6% or more 

Data Sources:

Unemployment data: U.S. Department of Labor, Bureau of Labor Statistics, 2000-2002 

Income data: U.S. Department of Commerce, Bureau of Economic Analysis, 2001 

Poverty data: U.S. Department of Commerce, Bureau of the Census, 2000 

Table 2 

33

Census Tract Level Analysis 

This section presents analysis of small business lending trends on a census tract level. In 

particular, an examination is conducted of lending trends in low- and moderate- income 

(LMI) census tracts in MSA counties compared to NonMSA counties. In addition, lending 

in LMI census tracts located in distressed counties is compared to lending in LMI census 

tracts in non-distressed counties. 

Appendix Table 17 represents lending trends in low- and moderate- income census tracts in 

each state and compares them to lending in all census tracts. Overall, in each state, the 

percent of small businesses that received SB loans was higher in all census tracts combined 

than in LMI census tracts. For the Appalachian region 41.4% of the businesses in all tracts 

received loans but just 35.4% of the businesses in LMI tracts received loans during 2003 

(see Figure 10). The difference in the ratio for all tracts and LMI tracts was 6 percentage 

points. The three states in which the difference in the ratios was the largest between all 

tracts and LMI tracts were Virginia (11.3% percentage points), Ohio (7 percentage points) 

and South Carolina (6.9 percentage points). The smallest difference in the ratio was for 

West Virginia (2.4 percentage points), Maryland (2.9 percentage points) and Alabama (3.2 

percentage points). 

41.40%

35.39%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

All Census Tracts LMI Census Tracts

Percent of Small Businesses Receiving Loans by 

Income Category of Census Tract

35.39%

23.63%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

All Businesses Businesses with Revenues

<$1 million

Percent of Small Businesses Receiving Loans in 

Low- and Moderate- Income Census Tracts

Figure 10 

Source: Appendix Table 17 – row Total Appalachia and columns All Census Tracts (# SB Loans/#SB) 

and LMI Census Tracts (# SB Loans/#SB and number # SB loans to SB with =<1mln / #SB (<$1mln)
34

Small businesses with revenues under $1 million tend to receive the fewest loans as 

reflected by the loans to small business ratio. The ratio of loans to small businesses was 

usually considerably smaller for loans to businesses with less than $1 million in revenues 

than for loans to all small businesses. In particular, for LMI census tracts, 35.4% of all 

small businesses and only 23.6% of small businesses with less than $1 million in revenues 

received loans (see Figure 10). The three states with the largest difference between these 

ratios in LMI census tracts were Maryland (18.8 percentage points), North Carolina (18.4 

percentage points) and South Carolina (14.8 percentage points). The smallest difference 

was observed in Virginia (6.5 percentage points), Mississippi (7.9 percentage points) and 

Kentucky (9.3 percentage points). Interestingly, Mississippi was the only state in which 

the loan to small business ratio in LMI tracts was more favorable for small businesses with 

revenues under $1 million than all small businesses (see Appendix Table 17). 

Another measure of lending is comparing the portion of SB loans in LMI areas against the 

portion of small businesses in LMI census tracts. For each state the portion of small 

businesses in LMI census tracts was higher than percent of SB loans located in these census 

tracts. For the region as a whole 17.7% of all the SB loans were made in LMI census 

tracts, however, the percent of small businesses located in these census tracts was 20.7%. 

In other words, the portion of loans in LMI areas was 3 percentage points less than the 

portion of small businesses in LMI tracts. The three states doing the best on this measure 

were Mississippi, North Carolina and Alabama with 0.8, 0.9, and 1.3 percentage points 

difference, respectively. The largest difference between the portion of small businesses in 

LMI census tracts in a county and portion of small business loans made in LMI areas was 

in Kentucky (5.9 percentage points), Virginia (5.5 percentage points) and Ohio (5.1 

percentage points). In lending to LMI tracts, no sub-region did consistently better or 

worse. In contrast, the Southern region tends to perform better on overall measures of 

small business lending. 
35

Census Tract Data Compared to County Data on Distressed and Metropolitan Status 

Appendix Table 18 represents small business lending ratios in LMI census tracts and all the 

census tracts of Appalachia comparing indicators for distressed and non-distressed counties 

and MSA and NonMSA counties. 

As mentioned above there were more SB loans per small business in non-distressed 

counties than in distressed counties as well as in MSA counties versus NonMSA counties. 

However, the difference between the ratios for MSA and Non-MSA counties was lower 

than the disparity between distressed and non-distressed counties. In contrast, the 

difference between MSAs and NonMSAs in lending to LMI tracts was larger than the 

difference between distressed and non-distressed counties. In MSA counties 36.9% of 

small businesses in LMI census tracts received loans and 41.7% of small businesses located 

in all census tracts combined received loans during 2003. For NonMSAs, 31.8% of 

businesses located in LMI areas received loans and 41% of businesses located in all census 

tracts combined received loans (see Table 3). The difference between LMI census tracts 

and all census tracts combined was higher in NonMSA areas, 8.2 percentage points, than in 

MSA counties, 4.8 percentage points. 

Percent of Small Businesses Receiving Loans in 

Distressed/Non-Distressed and Metro/Rural Counties 

by Income Level of Census Tracts 

 

 All Census 

Tracts 

LMI Census 

Tracts 

 

Distressed Counties 32.12% 26.25% 

Non-Distressed Counties 41.91% 36.53% 

Metro Areas 41.65% 36.88% 

Rural Areas 40.98% 31.77% 

Source: Appendix Table 18, columns All Tracts and LMI Tracts, #Loans/#SB 

For distressed counties, 26.3% of small businesses located in LMI census tracts received 

loans and 32.1% of businesses in all census tracts received loans. For non-distressed 

counties, 36.5% of LMI census tracts businesses received loans whereas 41.9% of all small 

Table 3 
36

businesses received loans (see Table 3). Contrary to MSA and NonMSA counties, the 

difference between lending in LMI census tracts and all census tracts combined in 

distressed counties was closer to the difference between LMI and all tracts in nondistressed counties -- 5.9 and 5.4 percentage points, respectively. 

On another measure of performance - the difference between the portion of businesses 

located in LMI census tracts and the portion of loans made in those tracts – distressed 

counties did not fare as well when compared to non-distressed counties. The difference 

between the percent of businesses located in LMI census tracts and percent of loans in LMI 

tracts was 8.1 percentage points in distressed counties but just 2.5 percentage points in nondistressed counties. In other words, 44 percent of the businesses in distressed counties 

were in LMI tracts, but these businesses received just 36 percent of the loans in distressed 

counties. On the other hand, 19.5 percent of the businesses in non-distressed counties were 

in LMI tracts and they received 17 percent of the small business loans in non-distressed 

counties during 2003. In contrast, the difference between the portion of businesses and the 

portion of loans in LMI tracts was narrower between MSA and NonMSA counties. For 

MSA counties, the difference was 2.7 percentage points whereas the difference for 

NonMSA areas was 3.6 percentage points. 

Overall, it is reasonable to assert that differences in lending were sharper for businesses in 

LMI tracts in distressed counties than for businesses in LMI tracts in non-metropolitan 

counties. When observing the loan to small business ratio, the small businesses in LMI 

tracts in non-metropolitan counties appeared to have less access to loans than the 

businesses in distressed counties. But this observation is made in the context of lower 

levels of lending in distressed counties than non-metropolitan counties, meaning that the 

differences across income level of tract will be less pronounced when comparing lending in 

distressed and non-distressed counties than when comparing lending across metropolitan 

and non-metropolitan counties. Given that lower lending levels probably blunt the 

differences in the small business to loan ratio in distressed counties compared to nondistressed counties, the indicator of the portion of loans compared to the portion of small 

businesses becomes more important. This indicator suggests less access to loans for small 
37

businesses in LMI tracts in distressed counties relative to small businesses in nonmetropolitan counties. 

Conclusions 

This chapter examined population and small business demographic trends on a national 

level and in Appalachia. Within Appalachia, this chapter compared small business 

demographic trends across states. The lending analysis then proceeded in a similar manner 

– national comparisons were first discussed followed by state, county, and then census tract 

analyses. 

While Appalachia comprised fewer minorities than the nation as a whole, small business 

demographics were remarkably similar. The two largest small business sectors in the 

nation and in Appalachia were services and retail. Similarly, almost 60 percent of the small 

businesses in Appalachia and the nation were very small, consisting of 1 to 4 employees. 

The legal status of the firms was somewhat but not dramatically different between the 

United States and Appalachia. The portion of sole ownerships was greater in Appalachia 

than the United States by about 3 percentage points and the portion of corporations was 

higher in the United States than Appalachia by about 3 percentage points. Within 

Appalachia, the composition of small businesses was similar across states and counties 

with some notable exceptions. For instance, the percent of agricultural small businesses 

was higher in non-metropolitan areas while the percent of service sector business was 

higher in metropolitan areas in Appalachia. Also, the percent of sole ownerships was 

higher in non-metropolitan areas than metropolitan areas in Appalachia. 

Since the small business demographics appeared relatively similar for the nation compared 

to Appalachia, it is consistent that lending trends were similar in Appalachia and the nation. 

For example, about 41 percent of the businesses in the nation and Appalachia received 

loans in 2003. In addition, Appalachia compared favorably against the nation on some 

lending indicators. Appalachia compared favorably against the nation when considering 

small business loan-to-deposit ratios and small business lending in minority counties. The 
38

nation performed better when considering the number of small loans per branch in all 

counties, but Appalachia outperformed the nation on this indicator in non-metropolitan 

counties. 

Within Appalachia, striking differences emerged in access to credit. When considering the 

ratio of loans to small businesses, loans to deposits and persons per branch, the Appalachia 

parts of southern states tended to have the best performance while the Midwest states 

lagged. 

On a county level, small businesses in non-metropolitan counties and in distressed counties 

had less access to loans when considering loans-to-small business ratios for businesses of 

all sizes and when considering loans to small business ratio for businesses with revenues of 

less than $1 million. In addition, small businesses with revenues of less than $1 million 

had the least access to credit than small businesses of all sizes. Interestingly, however, 

small businesses with revenues of less than $1 million were served better in nonmetropolitan areas than metropolitan areas when examining the loans per small business 

ratio. 

The differences in access to lending were also sharper when comparing distressed and nondistressed counties than when comparing non-metropolitan to metropolitan counties. 

Within counties, businesses in low- and moderate-income tracts experienced the least 

access to loans on a number of indicators. 
39

Mid-Size Banks and Government Backed Lending: Serving 

Communities and Businesses Most in Need of Credit? 

The extensive research literature review in this report suggests that smaller banks specialize 

in making loans to small businesses. To test this proposition, this chapter looked at the 

lending activities of mid-size lenders with revenues between $250 million and $1 billion. 

The sample used in this chapter contained the lending records of 123 mid-size banks and 

thrifts headquartered in Appalachia that had 1,120 branches.9 It would be desirable to 

scrutinize the lending activities of even smaller banks, however, banks with assets of less 

than $250 million do not report small business loans per the requirements of the 

Community Reinvestment Act (CRA) regulations. 

In addition to describing the lending patterns of small banks, this chapter examines the 

lending patterns of loans with government-backing. The Small Business Administration 

(SBA) provided NCRC with data on government-backed lending on a county level for the 

year 2003, which is also the year for the CRA small business lending data analyzed in this 

study. The data presented in this chapter reflects the lending activity of the major SBA 

program, the SBA 7(a) program. The SBA web page describes the 7(a) program as the 

primary business loan program designed to provide access to credit for small businesses 

who “might not be eligible for business loans through normal lending channels.” The 7(a) 

loans can be used for most purposes ranging from working capital, equipment, land and 

building acquisition, and debt refinancing. SBA 7(a) loans have a typical duration of 10 

years for working capital and up to 25 years for fixed assets. Traditional banks and thrifts 

make the 7(a) loans while the SBA issues the loan guarantees.10 

 

9

 NCRC identified the mid-size banks and thrifts headquarted in Appalachia by using the FDIC database 

Statistics on Depository Institutions available via http://www2.fdic.gov/sdi/index.asp. The CRA small 

business lending data of these institutions was then used to tabulate their lending levels by county. 10 See description of the SBA 7(a) program on http://www.sba.gov/financing/sbaloan/snapshot.html. Last 

visited on May 6, 2006. 
40

Mid-Size Banks 

While it may appear that mid-size banks had a small role in the lending market, their 

presence was larger in non-metropolitan counties, distressed counties, and in counties with 

high numbers of minorities. Mid-size banks therefore had an important role in serving the 

hardest to reach small businesses in Appalachia. 

In the Appalachian region, the mid-size banks issued 45,887 of the 530,309 CRA-reported 

small business loans during 2003. The mid-size bank market share of loans was 8.7% (see 

Appendix Table 19 and Figure 11). In other words, mid-size banks issued 8.7% of all loans 

in Appalachia. Mid-size banks exceeded their overall Appalachian market share in the 

Appalachian portion of seven states: Alabama, Georgia, Kentucky, Maryland, Mississippi, 

Tennessee, and Virginia. They had high market shares of 15.2% of the loans in Maryland 

and 22.3% of the loans in Virginia. Their lowest market share was in South Carolina (of 

1.8%). 

Mid-Size Bank Market Share of Loans in Each State

1.8% 2.1% 6.6% 7.3% 7.4% 8.3% 8.7% 10.0% 10.0% 10.0% 11.1% 14.6% 15.2%

22.3%

0%

20%

40%

60%

80%

100%

SC

WV

NY

PA

NC

OH

Appalachia

AL

TN

GA

KY

Percent of Loans Made

MS

MD

VA

 by Mid-Size Banks

The states in which the mid-size bank market share of loans was high were also states in 

which their market share of deposits and branches was also high as displayed in Appendix 

Table 20. For example, in Maryland, the high mid-size bank market share of loans 

appeared to be correlated with a high market share of deposits (37.7%) and branches 

Figure 11 

Source: Appendix Table 19 – column Mid-size Banks' Market Share 
41

(39.7%). A similar relationship between relatively high mid-size bank loan, deposit, and 

branch market share was present in Virginia and Mississippi. As suggested by the 

literature, mid-size banks’ success in Appalachian lending markets hinges on their branches 

and deposit gathering activity. This is evidence of relationship lending featuring direct 

contact with and in-depth knowledge of small businesses utilizing mid-size bank branches.

Mid-size banks had a market niche in serving small businesses in non-metropolitan 

counties. The mid-size bank market share of loans was higher in NonMSA counties versus 

MSA counties. Mid-size banks made 12.3% of loans in NonMSA counties but just 6.5% of 

loans in MSA counties. Map 4 and Figure 12 below show mid-size bank market share in 

MSA and NonMSA counties in Appalachia. The mid-size bank market ratio was higher for 

NonMSA counties than for MSA counties in all Appalachian states but Maryland, South 

Carolina, Virginia, and West Virginia. In Ohio, for example, mid-size banks had a market 

share in NonMSA counties of 13.9% of all loans while their market share in MSA counties 

was just 1.2% of all loans. Likewise, in Alabama the mid-size bank market share was 

16.1% in NonMSA counties but just 8.3% in MSA counties. 

Metro Areas

Rural Areas

6.49% 12.32%

0%

10%

20%

30%

40%

50%

Mid-Size Bank Market Share in Metro and Rural Counties

Percent of Loans Made by Mid-Size Banks

Figure 12 

Source: Appendix Table 21 – column Market Share % and rows Appalachia (MSA) and 

Appalachia (NonMSA)
42

Mid-size banks also reached a higher percentage of small businesses in NonMSA counties 

than MSA counties. Mid-size banks issued loans to 5% of small businesses in NonMSA 

counties and 2.7% of small businesses located in MSA counties during 2003. The pattern 

of serving a higher percentage of small businesses in NonMSA counties held for 8 of the 

13 Appalachian states. For instance, mid-size banks made loans to 7.3% of the small 

businesses in NonMSA counties in Georgia and 3.4% of the small businesses in MSA 

counties in the Peach state. Similarly, mid-size banks issued loans to 4% of the small 

businesses in NonMSA counties in Pennsylvania and 2% of the small businesses in the 

MSA counties in the Keystone state. 

44

Just as with non-metropolitan counties, mid-size banks had a larger presence in the lending 

market in distressed counties than in non-distressed counties (see Appendix Table 22). 

Mid-size banks had a market share of 14.7% of the loans in distressed counties and a 

market share of 8.4% in non-distressed counties (see Map 5 and Figure 13 for a pictorial 

display of mid-size bank market share in distressed and non-distressed counties). 

Interestingly, the mid-size bank median market share in non-distressed counties (4.6%) was 

higher than their median market share (1.8%) in distressed counties. Mid-size bank 

average market share in distressed and non-distressed counties did not differ by that much. 

The discrepancy between overall market share and median market share was probably 

explained by the dispersion of mid-size bank lending. While mid-size banks had a smaller 

median market share of loans in distressed counties than non-distressed counties, mid-size 

banks probably dispersed loans over a greater number of distressed counties than nondistressed counties in absolute terms or relative to other banks, enabling them to have an 

overall market share of loans that was larger in distressed than non-distressed counties. 

Non-Distressed

Counties

Distressed Counties

8.40%

14.67%

0%

10%

20%

30%

40%

50%

Mid-size Bank Market Share 

in Distressed and Non-Distressed Counties

Percent of Loans Made by Mid-size Banks

Likewise, the percent of small businesses receiving loans from mid-size banks in distressed 

areas (4.7%) was higher than the percent of small businesses located in non-distressed 

areas (3.5%). This statistic reinforces the finding that mid-size banks concentrated their 

lending in distressed counties relative to non-distressed counties. 

Figure 13 

Source: Appendix Table 22 – column Mid-size Banks' Market Share, number of loans and rows 

Total- Non-distressed and Total-Distressed

46

Mid-size banks appeared to be particularly active in counties with more than 50% 

minorities (see Appendix Table 23). The market share of loans made by mid-size banks in 

substantially minority counties (minority level >50%) was 28.6% whereas in counties with 

less than 20% minorities, mid-size banks issued less than 10% of all small business loans. 

The mid-size bank median market share of 10.7% in substantially minority counties was 

also much higher than the mid-size bank median market share of 4.2% in counties with less 

than 20% minorities. In contrast, mid-size banks had their lowest overall market share of 

6.7% in counties with between 20% to 50% minorities. 

The analysis in this chapter supports the thesis that mid-size banks were particularly 

responsive to the credit needs of small businesses. Overall mid-size bank market share of 

loans was greater in NonMSA counties than MSA counties, in distressed counties than 

non-distressed counties, and in substantially minority counties than non-minority counties. 

Some of the data were not completely consistent with the thesis that mid-size banks had a 

niche in traditionally underserved markets. For example, median mid-size bank market 

share was lower in distressed than non-distressed counties. But overall mid-size bank 

market share in distressed counties was larger in non-distressed counties, most likely due to 

a greater dispersion of mid-size bank loans in distressed than non-distressed counties. In 

addition, while mid-size bank market share was particularly high in counties with more 

than 50 percent minorities, it was lower in counties with 20 to 50 percent minorities than in 

counties with less than 20 percent minorities. Mid-size banks in Appalachia were more 

successful overall in serving non-metropolitan and/or distressed counties than they were in 

serving counties with a moderate to heavy minority population (between 20 to 50 percent 

minorities).

SBA 7(a) Loan Program 

The SBA loan program had a small presence in the Appalachian and national lending 

market. Overall in Appalachia, the 7(a) program had not succeeded in penetrating the 

minority small business loan market. One possible explanation was that Appalachian 

banks active in the minority community are not heavy users of the 7(a) program. In 
47

contrast to its performance in minority markets, the data suggests that the SBA program 

had succeeded in penetrating non-metropolitan counties. 

Appendix Table 24 shows that the SBA 7(a) program accounted for 4,260 loans in 

Appalachia during 2003, or just 0.8% of all loans in the region. Interestingly, the SBA 

market share of loan dollars was higher than their market share when considering the 

number of loans. The SBA loan program accounted for 2.4% of the loan dollars issued in 

Appalachia during 2003. The higher SBA market share when considering loan dollars was 

probably due to credit card lending driving down the average dollar amount for nongovernment backed loans. 

SBA-guaranteed lending did not appear to have a regional pattern. The SBA market share 

was not concentrated in any particular sub-region in Appalachia during 2003. The highest 

number of SBA-guaranteed loans (2,620 loans) was in Pennsylvania and the lowest was in 

Virginia (28 loans). After Pennsylvania, the next highest totals for SBA-guaranteed 

lending occurred in Georgia (372 loans), West Virginia (207 loans), and New York (200 

loans). The states with the lowest totals besides Virginia were Maryland (35 loans), 

Mississippi (49 loans), and Kentucky (66 loans). 

The SBA program did not quite reach minorities in proportion to their population in 

Appalachia or the nation. While the SBA program did well in serving Asian businesses, it 

had the most difficulty in serving African-Americans in proportion to the AfricanAmerican population. In the Appalachian region, 9.7% of the SBA 7(a) program loans in 

2003 were made to minorities while minorities constituted 12.7% of population. Across 

the country, 27.8% of the SBA-guaranteed loans served minorities, but minorities 

constituted 31% of the population (see Figure 14). 
48

Minorities Share of SBA 7(a) Program Loans 

Compared to Percent of Population 

in Appalachia and Nation

12.71%

30.87%

9.72%

27.79%

0%

5%

10%

15%

20%

25%

30%

35%

40%

45%

50%

Appalachia Nation

% of Population- Minorities % of Loans to Minorities

The SBA program would have served an even lower level of minorities were it not for its 

success in reaching Asian-owned businesses. In Appalachia, Asians were less than 1% of 

the population, and 5.5% of the SBA 7(a) loans were issued to Asians. Likewise, Asians 

across the country enjoyed a greater percentage of SBA-guaranteed loans than their 

percentage of their population. Asians constituted 3.6% of the nation’s population and 

received 13% of the SBA 7(a) loans during 2003. 

The SBA program was not nearly as successful in serving African-Americans as Asians. 

The mismatch between the percent of small business loans and the percent of their 

population was particularly striking in Appalachia and across the country. In Appalachia, 

African-Americans were 8.3% of the population but received 2% of the SBA 7(a) loans 

during 2003. On a national level, African-Americans constituted 12.1% of the population 

but were issued just 5.4% of the SBA 7(a) loans (see Figure 15). The situation was similar 

for Hispanics, but Hispanics did not comprise a large portion of the population in 

Appalachia. Hispanics were 2.2% of the Appalachian population and received just 1.2% of 

Figure 14 

Source: Appendix Table 24 – columns % Minority pop and % of loans, number and rows 

Total for Appalachia and Total for Nation
49

the SBA-guaranteed loans. Across the country, Hispanics were 12.6% of the population 

and were issued just 8.3% of the SBA 7(a) loans. 

African-American Share of SBA 7(a) Program Loans Compared to 

Percent of Population 

in Appalachia and Nation

8.26%

12.10%

2.09%

5.39%

0%

10%

20%

30%

40%

50%

Appalachia Nation

% of Population- African-Americans % of Loans to African-Americ

In the Appalachian portion of states with a considerable minority population, the disparities 

in SBA 7(a)-guaranteed lending to African-Americans were pronounced. For example, 

21.4% of the population in Alabama was African-American but African-American 

businesses received just 4.4% of the SBA 7(a) loans during 2003. Similarly wide 

differences occurred in Mississippi, North Carolina, and South Carolina. In Georgia, the 

SBA 7(a) program exhibited a disparity in reaching Hispanics in proportion to their 

population. Almost 7% of Georgia’s population was Hispanic, but Hispanic-owned 

businesses received 3% of the SBA 7(a) loans. 

The performance of the SBA program in serving women-owned businesses in Appalachia 

matched its performance on a national level. In Appalachia, 20.3% of SBA-guaranteed 

loans in 2003 were made to women owned small businesses, which was very close to the 

nationwide indicator of 21.3%. 

Figure 15 

Source: Appendix Table 24 – columns % Afr-Amer pop and % of loans, number and rows 

Total for Appalachia and Total for Nation
50

Appendix Table 25 illustrates that minority-owned businesses in Appalachia had greater 

access to SBA-guaranteed loans if they were located in MSA counties as opposed to 

NonMSA counties. Almost 29% of the SBA-guaranteed loans were issued to minorities in 

MSA counties but just 7% of the loans were issued to minorities in NonMSA counties in 

Appalachia during 2003. The difference for Asians was large. About 19% of the SBA 7(a) 

loans were issued to Asian-owned businesses in MSA counties and just 3.5% of the loans 

were received by Asian-owned businesses in NonMSA counties during 2003 in 

Appalachia. The difference in the portion for African-American businesses was also 

substantial; African-American businesses received 6.5% of the SBA 7(a) loans in MSA 

counties but just 1.5% in NonMSA counties. 

In contrast to the SBA lending patterns to MSA and NonMSA counties, minority-owned 

businesses had about as much access to 7(a) loans in distressed as in non-distressed 

counties. In non-distressed counties, lenders using the SBA program issued 9.8% of 

guaranteed loans to minority-owned businesses. In distressed counties, lenders using the 

SBA program offered 8.4% of SBA-guaranteed loans to minority-owned businesses in 

Appalachia during 2003. The pattern was quite different across the country; minorities in 

distressed counties received a much higher portion of SBA loans than minority-owned 

businesses in non-distressed counties. This differential access was driven by the much 

higher percentage of Hispanic businesses in distressed counties receiving SBA 7(a) loans 

than Hispanic businesses in non-distressed counties across the country. Appalachia did not 

have a sizeable Hispanic population, and hence did not exhibit this lending pattern to 

Hispanics. 

The SBA program was more successful in penetrating NonMSA counties than minority 

markets during 2003 in Appalachia. In NonMSA counties, the SBA 7(a) program achieved 

a market share of loans of 1% whereas in MSA counties its market share was .34%. Unlike 

the market share differences in MSA and NonMSA counties, the SBA program did not 

have a greater market share in distressed than non-distressed counties. In addition, other 

data indicate that the SBA 7(a) program may not be as successful in distressed counties as 

in non-distressed counties. Lenders using the program made 22.3 loans in distressed 
51

counties per 10,000 businesses and 68.3 loans per 10,000 businesses in non-distressed 

counties (see Table 4). 

SBA 7(a) Loans per 10,000 Businesses, 2003-2004 

 

 Appalachia 

 

Distressed 

Counties 

Nondistressed 

Counties 

All 

all USA 

All Loans 22.33 68.27 66.2 78.83 

Minority owned 

businesses 1.17 7.57 7.28 21.62 

Women owned 4.33 14.44 13.99 17.02 

When considering SBA 7(a) loans per 10,000 businesses on a county level, the data suggest 

that the SBA program was not as successful in guaranteeing lending in Appalachia as it 

was across the country. In Appalachia, lenders using the 7(a) program issued 66.2 loans 

per 10,000 small businesses while they issued 78.9 loans per 10,000 small businesses 

across the country. In addition, lenders using the SBA 7(a) program issued just 7.3 loans to 

minority-owned businesses per 10,000 businesses in Appalachian counties but 21.6 loans to 

minority-owned businesses per 10,000 businesses in counties across the country. For 

women-owned small businesses, the ratios were 14 in Appalachia and 17 across the 

country.11 

Conclusion 

Mid-size banks generally performed according to expectations. Their lending was 

relatively concentrated in non-metropolitan counties and distressed counties in contrast to 

larger banks. They also had a greater market share in substantially minority counties with 

 

11 To generate the data for loans per 10,000 businesses, this report combined 2003 and 2004 SBA 7(a) loan 

data. Above the report used SBA 7(a) loan data for the year 2003 only. 

Table 4 
52

populations that were more than 50% minority but had their smallest market share in 

counties with 20% to 50% minorities. 

The SBA 7(a) program had a higher degree of success in serving small businesses in nonmetropolitan counties than in counties with substantial minority populations. SBA-backed 

lending was not offered in proportion to the minority population in either the nation or 

Appalachia. SBA-guaranteed lending had a higher market presence in non-metropolitan 

counties than metropolitan counties. However, SBA-guaranteed lending served a smaller 

percentage of minority-owned businesses in non-metropolitan than metropolitan counties. 

The SBA program also did not guarantee as many loans per small businesses in Appalachia 

as it did across the country. In sum, it appears that mid-size banks were more consistently 

oriented towards traditionally underserved populations while the performance of the SBA 

7(a) program was mixed in its success of reaching traditionally underserved markets. 
53

Literature Review 

Introduction 

An extensive literature on small business lending has examined the impacts of restructuring 

in the financial industry on banks’ capacities to satisfy credit needs of small businesses. 

This inquiry is important since small businesses represent one of the most vulnerable yet 

critical parts of the national economy. Accordingly, this chapter will explore the lending 

techniques and specializations of small and large banks. As the industry consolidates and 

banks become larger, on average, is the industry as a whole still able to meet the variety of 

credit needs of small businesses? Alternatively, do small businesses now experience less 

access to some types of lending in which smaller banks excelled? The impacts of 

consolidation will also be assessed by a review studies that have explored whether small or 

large banks are more likely to practice discrimination in small business lending. In 

addition, the review discusses lending patterns in rural areas, given the prevalence of rural 

areas in the Appalachian region. Finally, the literature review contributes to the report’s 

regression analysis in the next chapter by providing insights into the variables to use in the 

regression analysis.

Banking consolidation has been at the center of attention for several years due to the large 

number of mergers and acquisitions. In June 2002, the portion of total industry assets held 

by the largest 50 bank holding companies constituted 70 percent whereas in June 1997 this 

figure was 52 percent (Ou, 2005). At the same time number of small banks with the assets 

under $500 million decreased from 8,647 in 1997 to 7,208 in 2002. Hence, researchers 

have given prominent attention to the impacts of bank consolidation in small business 

lending. 

Bank consolidation remains a complex and controversial issue. Some researchers argue 

that it is not efficient for large banks to provide small business loans as these loans are 

associated with relationship financing involving detailed and individualized attention to 

small business borrowers. On the other hand, other research indicates that large banks have 
54

dramatically increased their small business lending as they have adopted credit scoring and 

have achieved economies of scale in small business lending. While large banks have 

undoubtedly increased their small business lending, it is not clear that they have the ability 

to satisfy all credit needs, particularly the needs for larger loans and lines of credit 

associated with the relationship lending of small banks. In fact in recent years, large bank 

credit card lending, which is a type of transactional lending, has increased dramatically. 

Credit card lending has surged to such an extent that average loan amounts ($32,400 in 

2004) made to small businesses with revenues greater than $1 million were actually smaller 

than average loan amounts ($42,600) made to the smallest businesses with revenues under 

$1 million12. The larger small businesses are receiving a greater portion of credit card 

loans than the smallest small businesses. 

The increase in credit card lending and the rise of credit scoring lending by large banks 

begs the question of whether the range of credit needs of the smallest businesses are being 

adequately met. In this era of consolidation, are the smallest businesses receiving an 

adequate supply of larger loans and sufficient access to lines of credit, which are more 

often associated with smaller banks?13 On the other end of the scale, are the smallest 

businesses receiving an adequate supply of credit card lending and small loans; although 

large banks are increasing credit card lending is the credit card lending reaching the 

smallest of the small businesses? 

Relationship and Transactional Lending 

In general, researchers agree on the typologies of lending techniques used by large and 

small banks. They distinguish between financial statement lending, asset-based lending, 

credit scoring, and relationship lending. (Mitchell, 2004). The first three represent 

“transactional” lending as they are based on the “hard” or objective information about a 

 

12 FFIEC. Reports – Findings from Analysis of Nationwide Summary Statistics for 2004 Community 

Reinvestment Act Data Fact Sheet (August 2005). http://www.ffiec.gov/hmcrpr/cra_fs04.htm 

13 Smaller banks have legal limits on the size of their small business loans (Berger, Rosen, Udell, 2001) The 

reference to larger loans made by smaller banks refers to non-credit card loans (credit card loans are usually 

in amounts of $10,000 or less) and/or loans in amounts greater than $100,000. Credit scoring used by large 

banks are usually applied to loans in amounts of $100,000. 
55

borrower. For underwriting purposes, asset-based lending uses information about the 

accounts receivable, inventory, and other forms of collateral. Credit scoring is based on the 

owner’s history of using credit. Financial statement lending is rarely used for small 

business lending as it looks at the audited financial statement of companies that have an 

access to public credit market. In contrast, relationship lending, is based on “soft” 

information about the potential borrower. In other words, banks rely on the subjective 

information about a borrower that they received out of the lasting relationships rather than 

on financial condition of the borrowers. Another indication of relationship lending as 

reported by Cavalluzzo, Cavalluzzo, and Wolken (2001) is that 84 percent of the loans 

received by small businesses came from lending institutions located in the same city. The 

median distance between the firm and the lender was just three miles. 

Allen Berger (1999) defines three conditions that should be met for relationship-based 

finance to occur. First, information other than data from financial statements, collateral 

and other public resources is collected. Second, the information is collected via continuous 

communication between the lender and the small business, the customers of the small 

business, and local community. Third, the information is confidential and can be used only 

for making further lending decisions. 

Relationship lending is mainly associated with small banks whereas transactional lending is 

typically employed by large banks. Berger and Udell (2001) say that banks employing 

relationship lending should delegate more authority to loan officers than those that use 

objective information. Small banks are better equipped to delegate authority than larger 

ones; smaller banks have considerably fewer loan officers, making it easier for smaller 

banks to control, trust, and rely upon the quality of loan officers’ decisions. Relationship 

lending is therefore typically done in lower volumes than transactional lending at large 

banks. Using automated technology such as credit scoring, transactional lending benefits 

from economies of scale. Large transactional lenders serve relatively high number of 

customers, enabling them to lower costs per borrower by spreading fixed costs over a large 

customer base. 
56

Cole, Goldberg, and White provide detailed analysis of differences between relationship, 

“character”, and transactional, “by-the-number,” lending. They found that large banks 

mostly use “by-the-number” approach and small banks use “character” information which 

is based on pre-existing relationships between the bank and a borrower. Using the National 

Survey of Small Business Finances, Cole, et al. classify small banks as those with assets 

under $1 billion and large banks as those with assets above $1 billion. Cole’s regression 

analyses appear to confirm the different lending approaches of small and large banks. For 

example, higher debt-to-asset ratios increase the likelihood that large banks will not 

approve small business loans whereas small banks are not influenced by debt-to-asset 

ratios. Cole et al. hypothesize that small banks possess superior non-financial information 

about their customers and are thus able to make decisions not based purely on the numbers. 

In the same vein, small banks are more likely to approve loans to small business customers 

that have deposits at their banks while large banks are indifferent to deposit relationships. 

It appears that small banks are able to better utilize the experience and information gained 

through the deposit relationship than large banks. 

Impacts of Consolidation

A definitive answer regarding the impacts of consolidation on small business lending will 

probably never be reached. It is quite likely that the economic, institutional, and regulatory 

context in which mergers occur determine their influence on the level of lending in 

communities. Reviewing the literature, Hancook, Peek, and Wilcox (2005) hint at the 

possibilities of different outcomes. In a study in the late 1990’s, for example, Berger found 

that merged banks reduce their small business lending, but that other lenders in the 

community increased their lending in response, often replacing the lost lending of the 

merged banks. Similarly in the late 1990’s, Peek and Rosengren (1998) concluded that the 

small business lending behavior of the merged bank resembled the behavior of the 

acquiring bank instead of the acquired bank. So if the acquiring bank had conducted less 

small business lending, the newly merged bank was likely to reduce its level of small 

business lending. Other studies showed that mergers of smaller banks actually increased 

small business lending while mergers of larger banks had little effect. 
57

While the impacts of bank mergers are likely to be influenced differently by economic and 

market characteristics, Hancock, Peek and Wilcox (2005) identify important institutional 

characteristics that are likely to have more uniform impacts at least for larger banks. 

Hancock, Peek, and Wilcox distinguish between acquisition of banks and merger of bank 

charters. When a bank holding company (BHC) acquires another BHC, the acquiring BHC 

can either absorb the acquired BHC’s banks completely or let the acquired bank(s) continue 

lending as a separate entities. In other words, the acquiring BHC can let the acquired 

bank(s) remain as a separately chartered institutions or it can merge the banks and 

eliminate the charter of the acquired bank(s). To assess the impacts of acquisitions versus 

mergers (of bank charters), the study looked at small business lending patterns of the 50 

largest bank holding companies excluding credit card lenders. The authors used annual 

data for the period of 1997-2002. 

A major finding is that small business lending remains the same after acquisitions not 

involving mergers of charters. However, acquisitions involving mergers of separately 

chartered banks result in declines of small business lending. Researchers used natural log 

of total assets, log of acquired assets, and the Herfindahl-Hirschman Index (HHI) as 

explanatory, independent, variables. The HHI measured concentration of assets within the 

holding company; the higher the HHI, fewer banks within the holding company control 

more of the holding company’s assets. 

Estimated coefficients for the log of change of asset size of banks are negative and 

statistically significant for each model at the 5% level. In addition, estimated coefficients 

of the HHI on gross amount of originations and purchases are statistically significant and 

have negative values. Thus, internal growth of assets and increasing concentration of 

assets through merger of bank charters has a significantly negative impact on small 

business lending. In contrast, external growth through acquisitions does not affect small 

business lending. The estimated coefficients for the log of acquired assets were not 

statistically significant at 5% level. Among the top 50 BHCs in the country, Hancock et al. 

conclude that larger BHCs (in terms of asset size) tend to reduce their small business 
58

lending. In addition, the reduction is more pronounced when acquiring BHCs merge banks 

than when the banks are allowed to operate as separately chartered institutions. 

Frame, Srinivasan, and Woosley (2001) reinforce the conclusion of Hancock et al. by 

finding that the share of small business loans in a bank holding company’s portfolio 

increases with the number of subsidiary banks. Frame et al. hypothesize that a subsidiary 

bank structure is associated with decentralized decision-making in which relationship 

lending is employed. 

Maintaining that large banks increase lines of credit to small businesses, Berger, Rosen, 

and Udell (2001) come to different conclusions than a substantial portion of the literature. 

They find that large banks in markets in which large banks are dominant are more likely to 

increase their line of credit lending to small businesses than smaller banks in markets 

dominated by smaller banks. The one exception to this is line of credit lending in amounts 

less than $100,000; smaller banks are more likely to make these line of credits available to 

small businesses than larger banks. They attribute their findings to different methodology 

from the standard literature. 

The few studies that examine the impacts of mergers on small business lending in low- and 

moderate-income tracts generally find that mergers and acquisitions decrease small 

business lending in these tracts. Reviewing the literature, Immergluck and Smith (2001) 

state that Samolyk and Richardson (2001) find that banks involved in mergers have smaller 

growth rates of lending in low- and moderate-income tracts than banks not involved in 

mergers. From 1996 to 1998, the merging banks’ share of small business loans in low- and 

moderate-income tracts was 13.6 percentage points lower than banks not involved in 

mergers. 

Interestingly and importantly, the Immergluck and Smith (2001) review reports that 

merging banks tend not to decrease their lending in low- and moderate-income census 

tracts in geographical areas covered by their CRA exams; the decrease in lending in lowand moderate-income tracts occurs in areas outside the scope of the CRA exams. 
59

Buttressing the finding of CRA’s impact is a conclusion in the Frame, Srinivasan, and 

Woosley study. This study finds that the share of small business lending in a bank’s 

portfolio increases as the percent of recently acquired assets increase. Frame et al. suggest 

that the positive impact of recently acquired assets is the result of CRA motivating large 

banking institutions to negotiate CRA pledges with community groups to boost their home 

and small business lending. In other work related to home lending, Bostic and Robinson 

have found that banks, in fact, increase their home mortgage lending to low-income and 

minority borrowers in geographical areas covered by banks’ CRA agreements and CRA 

exams. Regulatory enforcement via CRA exams and the merger application process can 

mitigate decreases in lending as a result of mergers and in some cases may actually 

increase lending after mergers. 

Credit Scoring 

As was mentioned above, credit scoring is one of the techniques employed by transactional 

lending. Credit scoring has the potential to mitigate adverse impacts mergers by enabling 

large banks to boost their number of loans. Credit scoring is a process of assigning a score 

to a borrower based on the previous financial behavior of the borrower. A study conducted 

by Frame, Srinivasan and Woosley (2001) explores how credit scoring influences large 

banks’ tendency to engage in small business lending. They use data on 99 large banks 

received through a phone survey. Results showed that 100% of scoring banks used the 

credit scoring system to issue loans under $100,000, and 74% used it for loans under 

$250,000. Only 21% of banks scored larger loans. Regression results demonstrate that 

credit scoring leads to an increase in the portfolio share of small business loans under 

$100,000 by 8.4% or about $4 billion per institution. Frame, Padhi, and Woosley (2001) 

also found that large banks using credit scoring increased their loans in low- and moderateincome tracts to a much greater extent than in higher-income tracts. 

Another study that looked at the role of credit scoring was conducted by Berger, Frame, 

and Miller (2002). They compared “marginal” and “nonmarginal” borrowers. A 

“marginal” borrower is a borrower whose credit approval depends on use of credit scoring; 
60

and a “nonmarginal” borrower is a borrower who will get her credit approved regardless of 

usage of credit scoring. Credit scoring for small business loans under $100,000 lead to an 

increase in credit availability. Interest rates on loans increase as credit scoring is used. 

Berger et al. suggest that interest rates increase because credit scoring has increased the 

number of risky borrowers receiving loans and these borrowers are appropriately charged 

higher prices. However, for larger loans ($100,000 to $250,000) the use of credit scoring 

does not have a significant effect on credit availability. Indeed, only a few banks in the 

sample used credit scoring for loans over $100,000. 

While the research suggests that potential decreases in small business lending as a result of 

consolidation may be compensated by using credit scoring, it seems apparent that credit 

scoring has its limits. At this point, the industry is not employing credit scoring for loans in 

amounts greater than $100,000. As long as this remains the case, credit scoring may not be 

effective for boosting lending of larger dollar amounts when mergers depress lending of 

banks. Moreover, the Berger et al. study shows that credit scoring increases interest rates 

for riskier borrowers, per expectations that riskier borrowers are charged higher prices. 

However, there is likely to be a segment of riskier borrowers for which credit scoring may 

lead to either extremely high interest rates or loan denials (due to insufficient credit history, 

for example). These borrowers depend on relationship lending. If mergers in a particular 

geographical area decrease small bank relationship lending to a great extent, then mergers 

could very well decrease access to credit for the hardest to serve borrowers. 

Branches, Credit Scoring, and Mergers 

Bank branches are generally found to boost small business lending. Frame, Srinivasan, and 

Woosley report that the number of bank branches increases the share of small business 

loans in a bank’s portfolio. They also report that branch networks are associated with 

centralized decision-making networks and increased use of credit scoring by large banks. 

For relationship lending as well, branches are important because they increase customer 

contact. Immergluck and Smith (2001) report that their research in Chicago reveals that 

banks with the highest percentage of their branches in low- and moderate-income (LMI) 
61

census tracts make the highest percentage of their loans in these tracts while banks with the 

lowest percentage of branches in LMI tracts make the lowest percentage of their loans in 

LMI tracts. Squires and O’Connor (1999) came to similar conclusions in Milwaukee. 

Immergluck and Smith review research showing that mergers of banks with branches 

within the same zip code resulted in less per capita growth in branches within lower income 

areas. Mergers of banks with branch presence in the same metropolitan area also result in 

fewer branches in low-income zip codes. By decreasing access to branches in low- and 

moderate-income areas, in-market mergers will lead to less lending in low- and moderateincome areas, given the strong relationship between branches and lending. 

Discrimination 

Researchers distinguish between statistical and prejudicial discrimination. Statistical 

discrimination reflects measurement problems whereas prejudicial involves unjust lending 

practices. The research generally concludes that while prejudicial discrimination may not 

be widespread, it occurs in certain loan markets and to certain borrowers. Mitchell and 

Pearce (2004) using data from 1998 SSBF employ a new approach in that they examine 

possible discrimination in relationship versus transaction lending and by lender type 

(banks and non-bank finance companies). They state that many researchers regard line of 

credit lending as “quintessential” relationship loans since line of credit lending represents a 

sustained commitment on the part of the bank to make periodic loans to borrowers over a 

specified time period. Only banks with close relationships with businesses are likely to 

engage in line of credit lending according to observers. Accordingly, line of credit lending 

is classified in regression equations as “relationship” loans while “one-shot” deals or 

transaction loans are commercial mortgages, motor vehicle loans, equipment loans, and 

capital leases. The authors use data from the 1998 Survey of Small Business Finances 

(SSBF) that is conducted at five year intervals for the Federal Reserve. Mitchell and 

Pearce construct variables that reflect the degree of market concentration (as measured by 

the HHI index) and variables that capture characteristics of the small businesses including 

gender, ethnicity, creditworthiness, history of bankruptcy, and asset levels. 
62

Mitchell and Pearce find that African-American and Hispanic business owners are less 

likely to have bank transaction loans than whites after controlling for market and business 

characteristics, but that there is no statistically significant difference in the likelihood of 

receiving a bank line of credit (relationship lending). Also, minorities are more likely to 

have transaction loans from non-banks. In line with the observation that discrimination is 

not uniform, the authors could not detect discrimination against Asians and females. The 

counter-intuitive finding that minorities are less likely to receive transaction loans suggests 

that smaller banks employing relationship lending may remain an important source of 

lending for minorities. Moreover, the trend for large banks to engage in transaction lending 

may decrease, not increase access to credit for minorities. Cole et al. also found that 

smaller banks are more likely to make loans to African-Americans than large banks with 

assets above $1 billion. 

Cavaluzzo, Cavaluzzo and Wolken (2001) assess the interplay of discrimination and 

market concentration. In the seminal Economics of Discrimination, Gary Becker 

hypothesized that discrimination is more likely in highly concentrated markets lacking 

significant competition. In less competitive markets, firms can get away with 

discrimination while in more competitive markets the discriminating firms are likely to lose 

out in the competitive race against firms more willing to hire or serve minorities. 

Supplementing data from the 1993 National Survey of Small Business Finances with 

creditworthiness data obtained from Dun and Bradstreet, Cavaluzzo, Cavaluzzo and 

Wolken examined the connection between demographic characteristics of small business 

borrowers, market concentration, and the ability to access credit. 

A series of regression analyses revealed that increases in market concentration as measured 

by HHI indices result in African-Americans and females being more likely to experience 

denials of loan applications. Additionally, results show that African-Americans and 

females are more likely to have unmet credit needs (as measured by a fear to apply because 

of possibilities of discrimination or actual rejection) when market concentration increases. 

Finally, a one percentage increase in concentration as measured by an HHI index causes an 

11.40 basis point increase in the price of a line of credit for Hispanic small businesses. 
63

Cavaluzzo, Cavaluzzo, and Wolken test the rigor of their model. They conclude that 

regression results stand up since there is no correlation between market concentration and 

borrowers’ credit scores, meaning that financial institutions do not change their credit 

score policy when market concentration changes. Overall, the report concludes that gender 

and race discrimination cannot be omitted when assessing differences in credit application 

and denial rates. Moreover, their study suggests that consolidation and increasing market 

concentration can exacerbate discriminatory behavior. 

Demand for Small Business Credit 

The literature spends much time scrutinizing the relationships among consolidation, 

discrimination, and lending techniques. The literature on the nature of demand for loans by 

small business is considerably thinner. An indirect means for assessing the demand for 

credit is documenting the types of loans used by businesses of different sizes. 

The SBA report, Financing Patterns of Small Firms: Findings from the 1998 Survey of 

Small Business Finance, provides detail on the types of credit used by type of small 

businesses. The SBA report categorizes traditional loans as line of credits, mortgage, 

vehicle, equipment, and leasing loans. Nontraditional loans include loans from owners of 

the small businesses themselves and credit cards (business and personal). The report 

indicates that around 80% of all the small businesses participating in the survey used loans 

at the end of 1998. In addition, the majority (71%) of small businesses used nontraditional 

credits, and only 55% utilized traditional loans. The single largest source of credit was 

from banks; 38% of the surveyed businesses used banks. In contrast, owners’ loans and 

finance companies’ loans were 14.2% and 13.3% of all loans received by small businesses, 

respectively. The study also shows that the smallest firms (1-4 employees) do not usually 

borrow from commercial banks (only 17% to 31 % of these small firms borrowed from 

banks) whereas 53-77% of larger small firms used credit offered by commercial banks. 
64

In terms of total debt outstanding as of the end of 1998, lines of credit and mortgage loans 

were the two most important types of loans used by small businesses. Mortgage loans, 

lines of credit, owner’s loans, equipment and vehicle loans accounted for 31%, 30%, 8%, 

and 5%, respectively of total debt outstanding. 

Small businesses are not heavy users of loans. Only 15% had more than two loans 

outstanding, 25% had only one loan, and about 47% of small firm had no loans 

outstanding. However, the portion of small businesses using credit jumps with the increase 

of firm size. In addition, smaller firms increasingly use nontraditional types of credit such 

as owners’ loans, personal credit cards, and sometimes home equity lines for business 

purposes. Minority-owned firms are also less likely to use credit than non-minority owned 

firms. 

Bitler, Robb and Wolken (2001) compared the use of credit by small businesses over time 

by comparing the 1998 and 1993 Surveys of Small Business Finance. Over the 1993 and 

1998 surveys, the percent of small businesses using vehicle loans, equipment and “other” 

loans decreased. The portion of small businesses utilizing capital leases remained the same 

while the portion of firms using credit lines and mortgages increased. Credit usage and 

availability depends on the firm’s age; the portion of young firms (less than 5 years old) 

that receive credit lines, loans, or leases is smaller than the percentage of older firms. 

Along the same lines, Haynes, Ou, and Berney, using the 1993 NSSBF data, found that 

large banks are more likely to lend money to larger and older small businesses. 

Reporting on the supply of credit to different categories of businesses most likely understates the needs of small businesses for credit. A significant number of small businesses 

that desire credit do not apply because they fear rejection. Cavaluzzo et al. (2001) found 

that almost half of all small businesses in the 1998 SSBF desired credit but half of these 

firms did not apply because they feared rejection. Of those that feared denial and did not 

apply, black females feared the most (86.3%) and only 45.7% of white males feared denial. 

Because of large-scale fear of rejection, patterns of lending do not necessarily indicate that 

credit needs of various types of small businesses are satisfied. While the SSBF data reveals 
65

that larger, older, and non-minority firms are most likely to use credit, it is quite plausible 

that smaller, younger, and minority firms are not receiving the credit they need because of 

real and perceived obstacles in access to credit. 

Credit Demand in Rural Markets 

Just like assessing overall credit demand, documentation of credit demand in rural areas is 

sparse. The USDA study’s Credit in Rural America examines access for credit in rural 

areas of the U.S. Firstly, the report indicates that data collection is fraught with difficulties. 

In particular, it states that researchers usually must rely on limited survey data that usually 

shows that borrowers in rural areas are satisfied with their credit or obtaining loans is not a 

priority for them. While the report suggests that financial institutions provide necessary 

loans for rural communities, the report documents differences between operations of banks 

in urban and rural areas and emphasizes lack of competition in rural markets. This leads to 

unmet needs for credit in some communities. The study also reveals that while farm 

sectors and housing are well served, credit needs for rural development projects and nonfarm businesses need additional attention. 

The 1998 Mt. Auburn Associates report, Capital and Credit Needs in the Appalachian 

Region, conducted for the Appalachian Research Commission is one of the few attempts to 

comprehensively measure credit needs in a predominantly rural region. Mt. Auburn 

Associates measured and assessed demand for small business credit through a series of 

telephone interviews of 200 small businesses with more than 5 employees located in 

Appalachia. Overall, for the surveyed businesses, the types of financing most frequently 

sought were revolving lines of credit (sought by 36 percent of the applicants), equipment 

loans (32 percent), equipment leases (25 percent), and fixed rate mortgages (25 percent). 

Medium-term working capital and short-term working capital was sought by 18 and 16 

percent of respondents, respectively. The most frequently sought loan size amount was for 

$10,000 to $49,000, generally for equipment loans and leases, working capital loans, and 

revolving credit lines. Larger amounts of $100,000 to $499,000 were generally used for 

commercial mortgages, working capital and revolving credit lines. Mt. Auburn found that 
66

survey respondents from non-metropolitan counties were less likely to seek financing for 

their business than respondents from metropolitan counties. While smaller and larger 

businesses demanded similar types of credit and capital, twice as many smaller firms under 

5 employees (18 percent as opposed to 8 percent) anticipated having difficulties obtaining 

financing over the next two or three years. 

Implications 

Consolidation presents contradictory influences on small business lending. On the one 

hand, larger banks, through the use of credit scoring, have increased lending to small 

businesses. On the other hand, the literature suggests that in certain economic and 

institutional circumstances, consolidation will decrease small business lending, particularly 

when acquiring bank holding companies merge separate bank charters. Banks in 

concentrated markets appear more likely to discriminate, surprisingly in the provision of 

transactional lending. Branch presence is important for reaching low- and moderateincome communities; when mergers result in branch closures in low- and moderate-income 

or minority communities, the result is likely to be less small business lending. 

We will further investigate the impacts of consolidation and the lending patterns of large 

and small banks in Appalachia. The statistical analysis in the next chapter will attempt to 

shed light on how responsive small and large banks are to credit needs of the smallest 

businesses, the influence of bank consolidation and demographic characteristics on small 

business lending, and the role of bank branches on small business lending. 
67

Regression Analysis of Small Business Lending in Appalachia 

Introduction 

Drawing on the insights gathered from the literature review, this chapter will test the 

influence of bank consolidation, credit scoring, the number of branches, the minority 

population share, median household income, metropolitan and distressed county status, and 

small business firm size in three econometric models to analyze lending outcomes for all 

lenders, mid-size banks and SBA lenders. The chapter will assess the impact on lending 

levels of demographic and economic factors such as income levels, the portion of 

minorities on a county level, and the metropolitan/non-metropolitan and distressed/nondistressed status of counties. The chapter will also examine the impact of firm size of the 

small business sector on lending such as the number of businesses with four or fewer 

employees. In addition, NCRC was able to secure data from Dun and Bradstreet on the 

credit scores of small businesses on a county level for Appalachia. The chapter will 

therefore add an examination of the impacts of creditworthiness on the level of lending. 

Finally, the chapter will scrutinize the effect on lending of banking characteristics on a 

county level including the level of concentration and the number of branches.

One of the significant inquiries for the regression analysis is probing the extent to which 

banks of various asset sizes respond to the credit needs of the smallest businesses in 

Appalachia as well as businesses in distressed counties. The literature suggests that smaller 

institutions with assets under $1 billion will be more responsive to the needs of the smallest 

businesses. Accordingly, NCRC will assess the impacts of demographic and economic 

factors on mid-size bank lending. In addition, NCRC has obtained SBA loan data, and 

will determine if SBA lending patterns resemble those of the smaller or larger banks 

making non-government backed loans. The literature is surprisingly silent on patterns of 

SBA lending so an econometric analysis of SBA lending represents value added. 

This chapter has developed models for the three different types of lenders. These three 

models have the following dependent variables: 1) lending by all lenders of all asset sizes 
68

reporting CRA small business loan data, 2) lending by mid-size banks with assets between 

$250 million and $1 billion, and 3) SBA lending. 

For each model, the chapter will describe an expectation or hypothesis of the impacts of 

various demographic, economic and structural variables. For example, it will describe the 

expected impact of the metropolitan or non-metropolitan status of a county on the level of 

lending. In some cases, additional descriptive analysis will further illustrate the 

expectations of how the variable will impact lending. In other cases, references will be 

made back to previous chapters in describing the expectations of the variable’s impact. 

After describing the expectations for each of the variables, NCRC will review the actual 

impact of each variable and explain whether the actual impact matched our expectations. 

NCRC tested for collinearity and heteroskedasticity; the models were free from these 

problems. The data for our regressions were on a county level. A number of researchers 

use national surveys sponsored by the Federal Reserve that contain data on a firm level. 

Researchers are also starting to use the CRA small business loan data on a county or census 

tract level. NCRC’s models were based on county level data due to the availability of 

concentration indices on a county level, credit score data on a county level, and because 

counties were relatively small in terms of population in many cases in Appalachia. 

Data for the year of 2003 was used for this study. NCRC opted against longitudinal 

analysis because the CRA small business data has experienced definitional changes (for 

example, reporting of renewals changed) over the years. The Appalachian region was in a 

weak recovery in 2003, which must be kept in mind when examining the results of the data 

analysis. 

Below is a description of the variables used in each model, the expectations of the 

variables’ impacts per the literature review and descriptive data analysis, and results of the 

regressions. For each model, we developed two versions: a core model that contained 

demographic, economic and banking variables and a full model that included business 

demographic variables. In developing the models, NCRC had also tested introducing one 
69

business demographic variable at a time to the core model in order to determine if the 

impacts of the variables were consistent in different models. Overall, the variables were 

consistent in their impacts. The intermediate models between the core and full model are 

not presented here in the interests of space. The full models discussed in this report did not 

violate the classical assumptions of regression analysis. 

Finally, some of the variables had up to five categories such as the credit score variable 

which was expressed as quintiles of risk. Some of the full models below did not have all 

the categories for variables such as the credit score variable. The discarded categories were 

not significant and caused collinearity. 

Following is a list of variables in the regression analysis. 

Explanatory Variables 

Core Model 

% Black Percent of Black population Percent 

%Hispanic Percent of Hispanic population Percent 

MedianHH income Median Household Income Number 

MSA/NonMSA Metro or Non-metro county status Dummy (1 – MSA, 0 – 

NonMSA) 

Distressed/Nondistressed 

Personal Inc Grwth 

Distressed or Non-distressed county status 

Personal Income Growth 

Dummy (1- Distressed, 0 – 

Non-distressed) 

Percent 

HHI, ICB + Thrift @50% 

county level 

HHI index Number 

Number of Branches Number of all lenders’ branches Number 

Number of Branches (mid 

banks) 

Number of mid-size banks’ branches Number 

Size (number of 

Employees) 

 

Size_1 Percent of SB with 1 – 4 Employees Dummy14* 

Size_2 Percent of SB with 5 – 9 Employees Dummy* 

Size_3 Percent of SB with 10 -19 Employees Dummy* 

Size_4 Percent of SB with 20 – 49 Employees Dummy* 

Size_5 Percent of SB with 50 + Employees Dummy* 

Credit Score 

 

 

*

 “1” is assigned to a county where percent of small businesses in a particular category is above median for 

Appalachia; “0” is assigned to a county where percent of small businesses in a particular category is below 

Appalachian median 
70

CS1 Low risk small businesses in terms of credit score Dummy* 

CS2 Moderate risk small businesses in terms of credit 

score. 

Dummy* 

CS3 Medium risk small businesses in terms of credit 

score. 

Dummy* 

CS4 High risk small businesses in terms of credit score. Dummy* 

CS5 Very high risk small businesses in terms of credit 

score. 

Dummy* 

Dependent Variables 

All lenders 

Log#SBL Logarithm of the number of Small Business Loans 

made by all lenders 

Number 

Mid-size banks 

LogMid-sizebankloans Logarithm of the number of small business loans 

made by mid-size banks 

Number 

SBA 7a Program 

7a prg loans Number of loans made through the SBA 7a Program Number 

Model 1 – All Lenders (see Appendix Table 31) 

Metropolitan Statistical Area/Non-Metropolitan Statistical Area (MSA/NonMSA) 

Expectation: The numbers of lenders and small businesses are greater in metropolitan 

areas; supportive infrastructure such as counseling agencies, law firms, appraisal firms, and 

other entities needed for lending are in greater supply in metropolitan areas. All else equal, 

the number of small business loans should be greater in metropolitan areas. In addition, the 

descriptive analysis above also suggested that the loans-to-small business ratio was greater 

in MSA than NonMSA counties in the Appalachian portion of nine states. 

Results: In the core model, the MSA/Non MSA variable was significant with more lending 

occurring in MSAs. However, in the full model with credit score and size of business 

variables, the MSA/NonMSA variable was insignificant. Expectations were partially 

matched in the core model but not in the full model. Perhaps other factors such as small 

business demographic variables rather than the metropolitan status of the county have a 

stronger influence on lending levels. 
71

Distressed/Non-Distressed Counties 

Expectation: NCRC’s descriptive analysis suggests that lending levels are lower in 

distressed counties. Distressed counties have higher levels of poverty and unemployment, 

and overall economic conditions that are less conducive to small business lending. 

Results: The results are consistent with the expectations. In each model this variable was 

significant and had a negative sign. 

 

Minority Level in County (Percent Black and Percent Hispanic Variables) 

Expectation: The literature suggests that discrimination against minority owned businesses 

is a serious possibility that cannot be dismissed. In Appalachia, however, the descriptive 

analysis above suggested that lending was higher as the minority level in a county was 

greater. It is possible that a regional characteristic could be increasing lending to minorityowned businesses and/or counties with a substantial minority population in Appalachia. In 

contrast, minority-owned businesses in other parts of the country do not fare as well in 

access to credit as discussed in the analysis above. 

Results: Results contradicted the findings in the literature but were consistent with the 

descriptive analysis above. In particular, in the core and full models minority variables 

were statistically significant and had positive signs, which indicated that lending was 

higher as the minority population in a county was higher. This can have the following 

explanation: in Southern Appalachia, the highest growth areas are the counties north of 

Atlanta, Georgia where there has also been the highest growth in the Hispanic population, 

so there should be a positive and direct association with the number of business loans, 

although this could be an indirect effect induced by the regional growth trend. However, 

an income growth variable was introduced in the model (see below), suggesting that the 

level of Hispanics in a county is having a positive and independent impact in small 

business lending levels in Appalachia. 
72

Deal-flow considerations may explain the increase in lending associated in predominantly 

African-American counties. Lending to African-American businesses may be higher in 

substantially African-American counties because the high concentration of AfricanAmerican businesses in those counties increases the likelihood that African-American 

businesses will receive loans. Again, African-American small business owners’ experience 

in Appalachia is likely to be different than their experience in other parts of the country. 

A report of the Minority Business Development Agency15 found that minority-owned 

businesses grew dramatically, at 35%, between 1997 and 2002 whereas the total number of 

firms grew only 10%. In particular, African-American-owned firms grew 45% and 

Hispanic-owned firms at 31%. It is possible that the percent of the African-American and 

Hispanic population is a proxy for the minority-owned businesses. If this is the case, the 

relationship between number of small business loans in a county and minority population is 

expected to be positive. 

Median Household Income 

Expectation: NCRC’s descriptive analysis revealed that lending was lower in low- and 

moderate-income census tracts. We therefore expect that lending will be higher as the 

median household income of a county is greater. 

Results: Consistent with the expectations. Each model showed that the median household 

income variable was significant and had a positive sign indicating that lending levels were 

higher in counties with higher median income levels. 

Level of Concentration (HHI Index) 

Expectation: NCRC obtained from the Federal Reserve Board data on the level of 

concentration in each county in Appalachia. The Herfindahl-Hirschman (HHI) index 

 

15 The State of Minority Business Enterprises: A Preliminary Overview of the 2002 Survey of Business 

Owners, Minority Business Development Agency of the U.S. Department of Commerce, September, 2005. 
73

measures the level of concentration. The literature contains a lengthy discussion on the 

impacts of consolidation; it appears that markets dominated by larger firms are likely to 

experience drop-offs in lending. The descriptive analysis in Appendix Table 26 appears to 

support this hypothesis. In Appalachian counties with below median HHI, the median 

number of small business loans was 1,120. In counties with above median, HHI, the 

median number of loans was 287 (see Appendix Table 26). 

Results: The results were consistent with the expectations. The HHI index variable was 

statistically significant in each model and had a negative sign which indicated that higher 

levels of bank concentration in a county led to lower levels of small business lending. 

 

Branches 

Expectation: Existing studies suggest that banks make more small business loans as they 

increase their number of branches in a community. NCRC’s descriptive analysis was 

consistent with previous studies. The median number of branches in Appalachian counties 

was 11 according to Appendix Table 27. In counties with above median number of 

branches, the median number of loans by all banks was 1,287. In counties with below 

median number of branches, the median number of loans was 235. 

Results: Consistent with the expectations. The number of branches variable was significant 

in each model and had a positive sign suggesting that banks had higher levels of lending to 

small businesses when they had more branches in the area. 

Income Growth

Expectation: This variable measures the change in personal income on a county level. 

First, all incomes of persons residing in a county are summed. Second, the income growth 

variable is derived by computing the percentage increase or decrease between the aggregate 

personal income level in 2003 and the income level of 1998. As income levels increase, it 

is expected that lending levels would also increase. 
74

Results: The results were partially consistent with the expectations. Aggregate income 

growth was associated in a statistically significant manner with higher levels of small 

business lending in the core model. The sign was positive in the full model but the 

coefficient was not statistically significant. NCRC had also anticipated that the income 

growth variable would have made the minority variables insignificant because counties 

experiencing fast income growth tended to be Appalachian counties with high minority 

levels. However, introducing the income growth variable did not impact the significance of 

the minority variable. 

Size - Number of Employees in Small Business 

Expectation: The literature reports that the smallest businesses (those with 1 to 4 

employees) were the least likely to borrow. NCRC’s initial hypothesis was that the 

regression analysis would show that lending levels were lower in counties with above 

median percentage of these businesses. The descriptive data analysis in Appendix Table 28 

appeared to provide support for our hypothesis. In counties with below median 

percentages (60 percent) of small firms with 1 to 4 employees, banks made a median of 717 

loans; in counties with above median percentages, banks made 473 loans. 

In the next two categories of employment size (5 to 9 employees and 10 to 19 employees), 

all banks had a greater median number of loans in counties with above median percent of 

firms in these employment sizes. For instance, in counties with an above median percent of 

firms with 10 to 19 employees, banks issued a median of 817 loans while in counties with a 

below median percent of firms in this category, banks made a median of 465 loans. 

Lending patterns were mirror opposites for the next two categories of firm size (20 to 49 

employees and 50 and above). The median number of total loans was considerable higher 

by about 100 loans in counties with below median percent of firms with 20 to 49 

employees than in counties with above median percent of these firms. In contrast, the 

median number of loans from all banks was about 400 loans greater in counties with above 
75

median percent of firms with greater than 50 employees than in counties with below 

median percent of these firms. Banks appeared to make much greater numbers of small 

business loans in counties with above median percent of firms with greater than 50 

employees but fewer loans in counties with above median percent of firms with 20 to 49 

employees. Not too much should be read into this yet, because the median percentages of 

these firms per county were relatively small (3.95% for firms with 20 to 49 employees and 

2.44% for firms with greater than 50 employees). But further research may find that 

something is going on – perhaps the largest firms are supporting their smaller business 

counterparts with subcontracts to a greater extent in counties with above median number of 

these firms. The subcontracting could then stimulate more loan demand. 

Overall, the descriptive data analysis suggests that less lending occurs when there was 

above median percentages of the smallest firms (1 to 4 employees) than when there was an 

above median percentage of the largest firms. 

Results: In the full model, the variable for businesses with 10-19 employees was significant 

in determining small business lending volumes. In particular, lenders had higher levels of 

lending as the number of these businesses was greater in a county. This was somewhat 

consistent with our hypothesis and descriptive data analysis. While all lenders did not have 

lower levels of lending in counties with a high number of the smallest businesses per our 

hypothesis, lenders made more loans when the small businesses of larger employee sizes 

were present in greater numbers. In particular, the regression analysis was consistent with 

the descriptive data analysis, which suggested that banks would have higher lending levels 

in counties with above median numbers of firms with 10 to 19 employees. 

Credit Score 

Expectation: The literature suggests that credit scoring has allowed larger, transaction 

based lenders to make more loans to small businesses. In contrast, smaller lenders tend not 

use credit scores, meaning that their lending levels are unaffected by credit scores. A 

number of studies report that smaller lenders employ the relationship model in which 
76

underwriting decisions are more qualitative in nature and depend on the lender’s 

knowledge of the character and reputation of local small businesses. NCRC obtained Dun 

and Bradstreet (D&B) credit score data to test these propositions. 

D&B’s commercial code credit score predicts the likelihood that a company will pay its 

bills in a severely delinquent manner (90 days past due), or obtain legal relief from 

creditors, or cease operations over the next year without paying all outstanding loan 

amounts. The score ranges from 101 to 670, with 101 representing the highest risk of 

serious delinquency and 670 representing the lowest risk. The credit score data can also be 

expressed as quintiles of risk, with 1 representing the lowest risk and 5 representing the 

highest risk of serious delinquency. On a county level, the D&B data reveals how many 

businesses are in each quintile of risk. D&B uses a sample from its database of 16 million 

small businesses to develop credit scores based upon demographic characteristics of the 

small businesses, public records, payment performance, and financial ratios (such as 

liquidity and efficiency ratios).16 

Appendix Table 29 shows the largest portion of small businesses in Appalachia was in the 

credit score category of low risk scores. Moreover, the differences among the distribution 

of businesses in categories of credit scores were not as large as would be expected. The 

table shows that 26% of all Appalachian small businesses had the low risk credit scores, 

17.2% had moderate risk, 13.7% had medium risk, 23.6% had high risk, and 18.7% had 

very high risk scores. 

Considering categories of counties, the largest differences occurred among the distribution 

of businesses with low risk and very high risk credit scores. The portion of businesses with 

low risk credit scores in non-distressed counties was about 3 percentage points greater than 

the portion of businesses with low risk credit scores in distressed counties. Likewise, the 

portion of businesses with low risk credit scores was about 5 percentage points greater in 

MSA counties than NonMSA counties. On the other end of the scale, the portion of 

 

16 D&B Risk Management Solutions, Understanding the D&B Commercial Credit Score, Copyright 2002, 

D&B, Inc. 
77

businesses with very high risk scores was about 2.5 percentage points greater in NonMSA 

counties than MSA counties. The difference between the portion of businesses with very 

high risk scores in non-distressed and distressed counties was just under 1 percentage point. 

In sum, only the difference in the distribution of businesses with low risk scores between 

MSA and NonMSA counties was particularly striking. The difference in the distribution of 

very high risk scores was not large among the categories of counties. Thus, it is plausible 

that credit score distribution and the metropolitan/non-metropolitan or distressed/nondistressed status of counties were not correlated or interacting with each other. 

The data suggests that banks, including larger ones, were using credit scoring and had 

lower small business lending levels in counties with higher portions of higher risk scores 

(high risk is represented as low scores in D&B’s scoring system, see above). According to 

Appendix Table 30, in counties with above median portions of low risk scores, the median 

loan level was 877 loans. In contrast, the median loan level was 382 loans in counties with 

below median portion of low risk scores. Starting with the second lowest risk category 

(moderate risk) and continuing through the other quintiles of risk, the median lending 

levels were larger in below median portions of the risk category and were smaller in above 

median portions of the risk category. For example, in counties with below median portions 

of moderate risk scores, the median number of loans was 734. In counties with above 

median portions of moderate risk scores, the median number of loans was 440. 

It is therefore to be expected that lending would be higher in counties populated by small 

businesses with low risk credit scores and would be lower in counties populated by 

businesses with high and very high risk credit scores. 

Results: The full model showed that only the low risk category was significant and had the 

expected sign. Banks had higher lending levels in counties with high numbers of the 

lowest risk businesses. Interestingly, banks did not have statistically significant lower 

levels of lending in counties with above median portions of higher risk scores. Despite the 

insignificance, the signs were in the expected direction; that is, lending would be lower if 
78

the variables had been significant. The results suggest that banks were most sensitive to 

higher portions of low risk businesses, with significantly higher levels of lending in 

counties with above median portions of these businesses. This was consistent with 

expectations. The lack of significant impacts of the other credit score quintiles did not 

necessarily refute the initial expectations. The initial expectations would be refuted 

completely only if lending was higher as greater portions of higher risk businesses were 

present. 

Model 2 – Mid-Size Banks (see Appendix Table 32) 

Metropolitan Statistical Area/Non-Metropolitan Statistical Area (MSA/NonMSA) 

Expectation: The descriptive data analysis above showed that mid-size banks made a 

greater number of their loans in NonMSA counties and had a higher market share of loans 

in NonMSA counties than MSA counties. However, the median number of mid-size bank 

loans was greater in MSA than NonMSA counties. Mid-size banks probably dispersed 

more of their loans over a greater number of NonMSA counties than other banks. But on a 

per county basis, it is to be expected that mid-size banks would be making fewer loans in 

NonMSA counties than MSA counties. 

Results: The results show that the MSA/NonMSA variable was not significant in either the 

core or the full model. Just as with all banks, it appears that MSA/NonMSA status did not 

have a statistically significant impact on lending. This finding was somewhat contrary to 

initial expectations, but suggests that in and of itself, MSA/NonMSA status did not exert a 

large influence on lending for mid-size or other banks. 

Distressed/Non-Distressed Counties 

Expectation: Mid-size banks had a higher market share of loans in distressed than nondistressed counties. But just like other banks, mid-size banks had a lower median number 

of loans in distressed than non-distressed counties. Perhaps, mid-size banks did not lower 
79

their lending to the same extent as other banks in distressed counties, thereby accounting 

for their larger market share in distressed counties. Nevertheless, the lower median number 

of loans in distressed counties suggests that mid-size bank lending would be lower in 

distressed counties. 

Results: In the core model, the distressed/non-distressed variable was significant and 

negative. This was consistent with initial observations, meaning that lending was lower in 

distressed counties. In the full model, however, the distressed/non-distressed variable 

became insignificant. In contrast, the distressed/non-distressed variable was significant and 

negative for all lenders in the full model. Two effects may be occurring here that cancel 

each other out. On the one hand, mid-size banks may indeed have a niche in distressed 

counties, which would boost their market share of loans in distressed counties. On the other 

hand, distressed economic conditions in distressed counties may lower lending levels of 

banks in general. 

Minority Level in County (Percent Black and Percent Hispanic Variables) 

Expectation: The literature reports that smaller and mid-size banks with assets below $1 

billion are more likely to make loans to minority-owned businesses. It is possible that this 

could also apply to counties with high levels of minorities, suggesting that the minority 

level of a county may be a positive and statistically significant variable. However, the 

descriptive data analysis suggested that mid-size bank market share of loans was actually 

the lowest in counties with 20% to 50% minorities although mid-size banks had a higher 

median number of loans in counties with 20% to 50% minorities than in counties with less 

than 20% minorities. Although the descriptive data was mixed, the initial expectations 

were that mid-size banks would have lending patterns similar to other banks; that is, 

lending levels would be higher in counties with more minorities. 

Results: The impact of the percent African-American and Hispanic variables were 

consistent with expectations in the full model and core model. Race variables were 
80

significant and had positive signs; this implied that mid-size bank lending was higher in 

counties with higher levels of minority population. 

Median Household Income 

Expectation: The expectation for this variable was the same as for all lenders; namely 

lending would be higher as median household income was greater in a county. 

Results: The core model was consistent with expectations but with a coefficient that was 

very small. The full model was not consistent with expectations because the variable was 

statistically insignificant. 

Concentration 

Expectation: Some theories suggest that smaller banks perceive opportunities in more 

concentrated markets as customers become dissatisfied with services offered by 

oligopolies. These theories suggest that lending by mid-size banks would be higher in 

concentrated markets. The descriptive data, however, in Appendix Table 26 reveals that 

mid-size banks made a median number of 8 loans in counties with above median levels of 

HHI and 66 loans in counties with below median levels of HHI. The median mid-size bank 

market share of loans was also lower in counties with above median levels of HHI and 

higher in counties with below median levels of HHI. Overall, the descriptive data analysis 

suggests that mid-size banks would make less loans in Appalachian counties with higher 

concentration levels. 

Results: The level of concentration was associated with lower mid-size bank lending in the 

core model, and was consistent with initial expectations. In contrast, the level of 

concentration was insignificant in the full model. It did not appear that mid-size banks 

were seizing competitive opportunities by offering more loans in concentrated markets, 

however, higher levels of concentration were not associated with less mid-size bank 

lending as it was for other lenders. 
81

Income Growth Variable 

Expectation: Just as with other lenders, it was expected that mid-size banks would increase 

their lending as income growth surged over time in a county. 

Results: The income growth variable was positive and statistically significant in the core 

model but became statistically insignificant in the full model. 

Number of Branches of Mid-Size Banks 

Expectation: Mid-size banks appeared to thrive in counties with above median number of 

mid-size bank branches. Their market share of loans was 2.1 percent and 5.3 percent in 

counties with below median number of branches and in counties with above median 

number of branches, respectively, as displayed in Appendix Table 27.17 The median 

number of loans was 6 loans in counties with below median number of branches and 95 

loans in counties with above median number of branches. We thus expected lending to be 

higher in counties with greater number of mid-size bank branches. 

Results: The results were consistent with the expectations. Mid-size bank lending was 

higher as the number of mid-size bank branches was greater in a county in both the core 

and full models. 

Number of Employees in Small Business 

Expectation: The literature dwells on the “relationship” lending of mid-sized banks which 

is geared to serving the smallest businesses. We expected to see greater numbers of loans 

by mid-size banks in counties with greater numbers of firms with 1 to 4 employees and 5 to 

9 employees. The descriptive analysis suggests that mid-size banks may have a market 

 

17 NCRC used the FDIC database, Summary of Deposits, to identify branches located in Appalachian 

counties and to identify branches of mid-size banks headquartered in Appalachia. See 

http://www2.fdic.gov/sod/index.asp for this database. 
82

niche with the firms with 5 to 9 employees. Their median market share of loans was one 

percentage point higher in counties with above median percent of firms with 5 to 9 

employees than in counties with below median percent of these firms (see Appendix Table 

28). Moreover, the median number of loans in counties with below median number of 

firms with 5 to 9 employees was 13. In contrast, the median number of loans in counties 

with above median number of firms with 5 to 9 employees was 37. 

Results: The results were not consistent with the descriptive statistics. None of the size 

categories of businesses, including the number of businesses with 5 to 9 employees, had a 

statistically significant impact on lending. The sign on the coefficient for the 5 to 9 

employee variable was in the expected direction (positive) while the signs for the other size 

categories were negative. 

Credit Score 

Expectation: The literature, as discussed above, finds that credit scoring is not a statistically 

significant factor in mid-size bank lending and underwriting. Mid-size banks often employ 

relationship lending in which first-hand knowledge of local small businesses replace the 

quantitative analysis and/or credit scoring as the means for making loans to small 

businesses. In contrast, larger banks engage in transactional lending that mostly rely upon 

credit scoring and other quantitative techniques for underwriting and issuing loans 

(Mitchell, 2004 and Berger and Udell, 2001). 

The descriptive analysis reveals that mid-size banks’ lending patterns were similar to other 

banks when considering credit score. As shown in Appendix Table 30, mid-size banks had 

a higher median number of loans (37) in counties with above median levels of businesses 

with low risk credit scores, but they had lower median number of loans (13) in counties 

with below median number of low risk scores. The patterns were reversed for mid-size 

banks in the other risk categories; that is the number of loans was lower with above median 

number of businesses in the higher risk categories. Notwithstanding the descriptive data 
83

analysis, we are going to rely on the extensive literature and expect the credit scoring 

variables to be statistically insignificant. 

Results: The results were consistent with the expectations. The credit score variable was 

not statistically significant. Mid-size banks’ lending levels were not affected by the 

distribution of credit scores on a county level in Appalachia. Mid-size banks appeared to 

be applying the relationship model of lending. 

Model 3 – SBA Loans (see Appendix Table 33) 

Overall, the expectations for SBA lending were similar to mid-size bank lending because of 

the possibility that the “relationship” model of lending was employed to a large extent in 

SBA lending. This section will report on the results for each variable. 

Metropolitan Statistical Area/Non-Metropolitan Statistical Area (MSA/NonMSA) 

Expectation: The descriptive data analysis revealed that the SBA 7(a) program had a 

higher market share of loans in NonMSA than MSA counties. Accordingly, the initial 

expectation was that SBA 7(a) loans would be higher in NonMSA counties. 

Results: In the core model and full models, the variable capturing metropolitan/nonmetropolitan status of a county was negative and statistically significant, meaning that SBA 

7(a)-guaranteed lending actually was lower in metropolitan counties. This finding was 

different from all banks and mid-size banks. It suggests a focus of SBA 7(a)-guaranteed 

lending in Appalachian non-metropolitan areas that was distinct and significant from a 

policy perspective. 

Distressed/Non-Distressed Counties 

Expectation: The descriptive data analysis found that the SBA 7(a) program’s market share 

of loans did not differ that much in distressed or non-distressed counties. Therefore, it 
84

would be expected that the distressed/non-distressed status of the county would not have 

much of an impact on SBA 7(a)-guaranteed lending. As stated above, the SBA 7(a) 

program focuses on small businesses who “might not be eligible for business loans through 

normal lending channels.” A program goal of this nature could include targeting 

economically distressed areas for small business loans, but the SBA 7(a) program 

description on the SBA website does not include information on whether geographical 

targets have been established for the program. 

Results: This variable was not significant in any of the models, whereas it was significant 

and negative for all lenders. The result for SBA-guaranteed lending was the same as for 

mid-size banks, meaning that mid-size bank lending and SBA-guaranteed lending may not 

be negatively influenced by distressed counties in contrast to lending conducted by all 

banks. 

Minority Level in County (Percent Black and Percent Hispanic Variables) 

Expectation: The descriptive analysis above documented that SBA 7(a)-guaranteed 

lending did not reach minority-owned businesses in proportion to the minority population 

either nationally or in Appalachia. Accordingly, it was expected that larger portions of the 

African-American or Hispanic population would result in lower levels of SBA 7(a)-

guaranteed lending. 

Results: In the core and full models, the variable capturing the portion of the AfricanAmerican population was negative and statistically significant. The Hispanic population 

variable was negative in sign but not statistically significant in the models. The findings 

for the African-American and Hispanic variables contrasted with all lenders and mid-size 

banks; for all lenders and mid-size lenders, loan volumes were higher in counties with 

greater numbers of minorities. 
85

Median Household Income 

Expectation: The SBA program intends to target small businesses who would not otherwise 

receive loans. Given this orientation, the initial expectation would be that SBA-guaranteed 

lending was less likely than non-government backed lenders to be higher in counties with 

higher median income levels. 

Results: The results were consistent with the expectations. The median household income 

variable was insignificant in the core and full models. Income levels in a county did not 

influence SBA-guaranteed lending. 

Concentration 

Expectation: The descriptive statistics in Appendix Table 26 reveal that the number of 

median SBA loans was lower in counties with above median HHI and was higher in 

counties with below median HHI. It was therefore expected that SBA-guaranteed lending 

would be lower in counties with higher levels of banking industry concentration. 

Results: Partially contrary to expectations, the core model showed that SBA-guaranteed 

lending was higher when the concentration level was higher. In the full model, the 

concentration variable was not statistically significant. Overall, this was a positive finding 

in that SBA-guaranteed lending may not be as sensitive as non-guaranteed lending to 

higher levels of concentration on a county level. In contrast to SBA-guaranteed lending, 

the full model for all lenders revealed lower levels of lending as HHI was higher on a 

county level. 

Income Growth

Expectations: Counties experiencing higher levels of personal income growth also probably 

experienced higher levels of small business formation and growth. It would be expected 

that SBA-guaranteed lending would be higher in counties experiencing faster rates of 
86

income growth. This could even include poorer counties, as long as the income growth 

was fast in these counties. 

Results: Contrary to expectations, the income growth variable did not have a statistically 

significant impact on SBA 7(a)-guaranteed lending. 

Branches 

Expectation: The descriptive data analysis in Appendix Table 27 reveals that median and 

average levels of SBA-guaranteed lending were higher in counties with above median 

number of branches and lower in counties with below median number of branches. Thus, 

the expectation was that SBA-guaranteed lending would be higher in counties with greater 

number of branches. 

Result: In the core and full models, the number of SBA-guaranteed loans was higher in 

counties with greater number of branches. This finding was consistent with the 

expectations. 

Number of Employees in Small Business 

Expectation: The descriptive data analysis in Appendix Table 28 does not provide good 

clues regarding expectations of SBA-guaranteed lending to businesses of various sizes. In 

all the business size categories (except for firms with more than 50 employees), the SBA 

7(a) program guaranteed a greater average number of loans in counties with below median 

number of firms in the particular size category than loans in counties with above median 

number of firms. Based on the purpose of the 7(a) program, it would be expected that 

SBA-guaranteed lending would be higher in counties with greater number of smaller 

businesses. 

Results: In the full model, the variable for small businesses with 5-9 employees was 

significant and negative in sign. The variable for small businesses with 1 to 4 employees 
87

was statistically insignificant as was the variable for small business with 10 to 19 

employees. SBA-guaranteed lending was not lower in counties with higher numbers of the 

smallest businesses (1 to 4 employees), but was lower in counties with greater portions of 

businesses with 5 to 9 employees. Perhaps, SBA-guaranteed lending was more focused 

than all lenders on the smallest firms with 1 to 4 employees since: 1) the 1 to 4 employee 

variable was the only variable in the 7(a) model that was not negative in sign, and (2) the 

only statistically significant variable for the all lender model was the variable for firms with 

10 to 19 employees. 

Credit Score 

Expectation: The intent of the SBA 7(a) program would suggest that SBA-guaranteed 

lending would be higher in counties with greater portions of moderate risk and high risk 

small businesses. The descriptive data analysis in Appendix Table 30, however, suggests 

that the 7(a) program guaranteed more loans in counties with higher numbers of lower risk 

business and fewer loans in counties with higher risk businesses. Since the intent of the 

program was not consistent with the data analysis, the initial expectation will split the 

difference between the program’s purpose and the descriptive data. The initial expectation 

was that credit score distributions would not significantly impact the level of SBAguaranteed lending on a county level. 

Results: The full model showed SBA 7(a)-guaranteed lending was higher in counties with 

greater numbers of businesses in all credit risk quintiles except the moderate risk quintile. 

In other words, SBA-guaranteed lending basically remained unaffected by differences in 

the distribution of credit scores in counties. Since SBA-guaranteed lending was not lower 

in counties with the highest portion of medium or high risk businesses, the SBA program 

appeared to be serving its purpose in Appalachia by serving (and not avoiding) higher risk 

businesses. 
88

Discarded Variables 

This report discarded a few of the variables on business characteristics from the equations 

due to collinearity problems. It is nevertheless worthwhile to briefly discuss these 

variables as initial expectations were that they would influence the levels of lending in 

Appalachia. 

Sector of Small Business 

Expectation: The sector of small businesses appeared to be an important control variable 

for regressions. For example, the median percentage of services businesses in a county was 

34.8 percent and the median percentage of retail businesses was 18.9 percent. The median 

number of loans in counties with above median percentages of services businesses was 470 

loans higher than in counties with below median percentages of services firms (see 

Appendix Table 34). In contrast, the median number of loans was reversed in the case of 

retail firms, with a much higher median of loans in counties with below median 

percentages of retail firms. 

Results: In the great majority of the equations, the sector variable was insignificant and 

created collinearity problems. Two versions of the variable were tried. In the first version, 

demographic data on the number of small businesses in each sector were employed. In the 

second version, data from Economic Research Service from the United States Department 

of Agriculture that characterizes county-wide dependence on a given sector was employed. 

Ownership of Small Business 

Expectation: Dun and Bradstreet’s description of their credit scores states that corporations 

are considered less risky than sole ownerships. Thus, an initial hypothesis was that small 

business lending was less in counties with below median percentages of corporations and 

above median percentages of sole ownership firms. The descriptive data suggested this 

was the case. The median percentage of sole ownerships in a county was 30.6 percent. All 
89

banks made 842 loans in counties with below median percentages of sole ownerships, and 

434 loans in counties with above median percentages of sole ownerships (see Appendix 

Table 35). In contrast, lending was higher when the number of corporations in a county 

was greater. 

Results: Variables that measured sole ownerships and corporations as a percent of small 

businesses created collinearity problems. This was solved by introducing a composite 

ownership variable which was a ratio of the sum of sole ownerships and partnerships 

divided by the percent of corporations in a county. However, this variable was not 

significant, motivating us to delete it from the equations. 

Conclusion 

The regression analysis produced significant findings of factors accounting for lending 

levels. One of these significant findings was that higher numbers of bank branches result 

in more small business loans for banks of all sizes and for SBA 7(a)-guaranteed lending. 

Furthermore, lower lending levels occurred in distressed counties than non-distressed 

counties. Sensible policies would be to encourage bank branch building in Appalachia and 

to pursue economic development in distressed counties. When counties move from 

distressed to non-distressed status, more small business lending would occur. 

An important finding was that counties with higher levels of minorities had higher levels of 

small business loans in Appalachia. In contrast, counties with higher levels of bank 

consolidation and concentration had lower levels of lending. In addition, counties with the 

highest numbers of businesses with low risk credit scores had higher levels of loans. 

As predicted by the literature, mid-size banks exhibited lending patterns that reflected 

relationship lending. The level of mid-size bank lending on a county level was unaffected 

by the distribution of credit scores. In addition, the distribution of small businesses by 

employee size did not impact mid-size bank lending unlike lending by all banks which was 

higher in counties with a higher portion of businesses with 10 to 19 employees. Also, levels 
90

of concentration did not impact mid-size bank lending whereas lending by all lenders was 

lower in counties with higher levels of concentration. 

The SBA 7(a) program also exhibited distinct lending patterns. It was the only type of 

lending that was lower in MSA counties relative to NonMSA counties in Appalachia. This 

suggested a non-metropolitan focus by the SBA program in Appalachia. A worrisome 

finding, however, was that the SBA program was the only type of lending that was not 

higher in counties with greater portions of African-Americans and Hispanics. 
91

Assessing the Impact of CRA on Community Development Lending for 

Affordable Housing and Small Business in Appalachia 

Introduction 

The Community Reinvestment Act (CRA) of 1977 imposes upon banks and thrifts an 

affirmative and continuing obligation to meet the credit needs of communities in which 

they are chartered, including low- and moderate-income communities. Four federal 

financial supervisory agencies enforce CRA and conduct periodic CRA exams about once 

every two or three years for banks with assets above $250 million. CRA exams assess the 

level of loans, investments, and services banks with assets above $250 million provide to 

low- and moderate-income communities.18 Banks receive CRA ratings for their overall 

performance as well as their performance in each state and multi-state metropolitan 

statistical area (MSA) in which they have branches. Banks and thrifts have strong 

incentives to increase their levels of lending, investing, and services to low- and moderateincome communities. Low CRA ratings can result in negative publicity and/or delay bank 

applications for federal agency approval to merge with another institution or open 

additional bank branches. 

This chapter will assess the impacts CRA has had on increasing certain types of lending 

and investing for affordable housing and small business by banks located in Appalachian 

counties. The chapter will use CRA exams of banks headquartered in Appalachia during 

the time period of 2001 through 2004 to document levels of financing for affordable 

housing and small business development. So far the report has been devoted to examining 

access to lending for individual small businesses. In this chapter, the report scrutinizes the 

level of community development financing. Community development lending and 

investing provides the financing that builds the infrastructure and support systems of small 

 

18 As of September 2005, the CRA exam structure was different for mid-size banks with assets between $250 

million and $1 billion and for large banks with assets above $1 billion. The exams for these two types of 

banks, however, had the same test structure (separate lending, investment, and services tests) during the time 

period examined by this report. Below, the chapter describes the test structure in more detail. This chapter 

looked at the most recent CRA exams of banks headquartered in Appalachia; the great majority of exams 

were conducted during 2001 through 2004. Only about 1 percent of the exams were conducted during 2005. 
92

businesses. For example, community development financing would support the 

development of small business incubators and Rural Business Investment Corporations 

(RBICs). This chapter therefore rounds out the analysis of serving the credit and capital 

needs of small businesses. The chapter supplements the previous analysis of lending to 

individual small businesses with an analysis of financing the necessary infrastructure and 

support systems of small business development. 

CRA exams for banks with assets greater than $250 million include sections that assess a 

bank’s level of community development lending and investments. Community 

development lending and investing include financing for low- and moderate-income rental 

and homeowner units as well as for small business incubators and equity vehicles for small 

businesses. The purpose of comparing levels of financing affordable housing and small 

business is to provide the Appalachian Regional Commission with a new and unique 

database of bank financing for these important needs. 

This exercise also seeks to reveal the levels at which banks finance affordable housing and 

small business and whether a relatively small amount of financing for one of these 

activities suggests that more bank financing is required. The chapter will also assess if 

CRA has influenced banks to increase their level of bank branching in Appalachian 

counties. Finally, the CRA regulations have recently changed. The chapter will contain a 

brief description of the new CRA regulations for mid-size banks with assets between $250 

million to $1 billion and offer insights into whether the new regulations and exams will 

impact the level of community development lending and investing. 

Description of Sample Size of Banks and Thrifts 

NCRC selected banks in Appalachia that had greater than $250 million in assets as of yearend 2004, as listed by databases available on the Federal Financial Institutions Examination 

Council (http://www.ffiec.gov) web page. Banks and thrifts with assets above $250 million 

in assets have more comprehensive CRA exams that scrutinize their lending, investment, 

and service activities. In particular, NCRC was interested in the community development 
93

lending and investment activities of these banks. At the end of 2004, 227 banks and thrifts 

located in Appalachian counties had assets of more than $250 million. NCRC was able to 

find the CRA exams for 220 of these institutions. In the seven remaining cases, the CRA 

exams could not be tracked down due to a number of possibilities including changes in 

charter types, the age of the institution (new or de novo banks may not have been examined 

yet), or mergers and acquisitions making it difficult to track name changes to the 

institutions. 

At the time of their most recent CRA exam, 78 of the 220 banks had less than $250 million 

in assets and were examined by regulators using the “small bank” CRA exam. The small 

bank CRA exam focuses on lending activities. The remaining 142 banks were examined 

using the “large bank” examination that encompasses lending, investments, and services. 

The banks with assets less than $250 million at the time of their CRA exam were still 

included in the NCRC database and analysis.19 Specifically, these banks were included in 

the examination of bank branching patterns, but were not included in the part of the 

analysis that considered the levels of community development lending and investing. 

Four federal supervisory agencies conduct CRA exams. The Federal Deposit Insurance 

Corporation (FDIC) and the Federal Reserve Board (FRB) conduct CRA exams for 

institutions charted by state governments. The Office of the Comptroller of the Currency 

(OCC) and Office of Thrift Supervision (OTS) perform CRA exams for institutions charted 

by the federal government. 

 

19 NCRC thought it was important to capture the banks that had assets over $250 million at year end 2004, but 

had assets less than that amount in their most recent CRA exam. The next CRA exams of these institutions 

will be more comprehensive. In addition, their branching patterns could still be assessed. Finally, the small 

bank CRA exam provides “bonus” points if small banks engage in community development lending and 

investing. We wanted to see how often small banks in Appalachia took advantage of the bonus point option 

and engaged in community development and lending. 
94

The regulatory agency break down for banks in the sample is as follows: 

 All Banks Small Banks Large Banks 

FDIC 51.8% 57.7% 48.6% 

FRB 15.0% 9.0% 18.3% 

OCC 25.5% 25.6% 24.4% 

OTS 7.7% 7.7% 7.7% 

Sample Size 220 78 142 

The majority of banks and thrifts in our sample were state-chartered institutions as the 

FDIC and FRB examined 51.8 percent and 15 percent of the institutions, respectively. The 

OCC examined a quarter of the banks. Only 7.7 percent of the lenders were federally 

chartered thrifts that were examined by the OTS. 

The great majority of CRA exams in the NCRC sample were relatively recent. More than 

90 percent of the CRA exams for the large bank sample were from 2002, 2003, and 2004 

(23.2%, 36.6% and 31.7%, respectively). CRA Exams from 2001 and earlier made up 7% 

of the sample, and exams from 2005 accounted for 1.4%. 

Bank Location by State, Metropolitan Area and County 

Appalachian counties in Pennsylvania accounted for 42 institutions in the sample or almost 

30 percent of the sample. Appalachian counties in Alabama had 20 banks or 14 percent of 

the lenders in the sample and Appalachian counties in Tennessee had 10 institutions or 7 

percent of the lenders in the sample. 

Of the sample of large banks, the break-down by state is as follows: 

Count Percentage 

AL 20 14.1% 

GA 14 9.9% 

KY 5 3.5% 

MD 4 2.8% 

MS 6 4.2% 

NC 8 5.6% 

NY 8 5.6% 

OH 9 6.3% 
95

PA 42 29.6% 

SC 2 1.4% 

TN 10 7.0% 

VA 7 4.9% 

WV 7 4.9% 

Total 142 100% 

Slightly more than half of the banks and thrifts with assets above $250 million as of year 

end 2004 were located in metropolitan statistical areas (MSAs) in Appalachia. One 

hundred seventeen banks were located in MSAs and 103 banks were located in nonmetropolitan counties in Appalachia (see Appendix Table 36a). The asset sizes of the 

banks located in MSAs were considerably larger; banks located in the MSAs had combined 

assets of $420.6 billion versus $73.3 billion for assets of banks located in non-metropolitan 

counties (see Appendix Table 36c). Only 11 banks with combined assets of $4.3 billion 

were headquarted in distressed counties in Appalachia. 

Banks headquartered in Appalachia represent a significant financial resource for 

responding to credit and capital needs of small businesses, but planning needs to be 

undertaken to leverage increased amounts of bank financing delivered equitably throughout 

the region. The imbalance of considerably more bank assets in MSAs is not surprising, but 

can perhaps be mitigated by CRA assessment area procedures. It is unlikely, for example, 

that the 117 banks located in metropolitan areas have declared only metropolitan areas as 

their official CRA assessment areas in which they undergo CRA exams. Many of these 

banks may also have non-metropolitan areas designated as assessment areas. ARC officials 

and local economic development officials may want to undertake a targeted review of CRA 

exams of MSA-located banks to ensure that non-metropolitan counties are included as 

assessment areas, especially counties designated as distressed counties. 

The other phenomena regarding asset sizes that is important for planning purposes is the 

relatively “small” size of banks located in Appalachia. The average asset value of banks 

and thrifts in the NCRC sample located in Appalachian counties as of year end 2004 was 

$2.2 billion but the median asset size was $364 million (see Appendix Table 36a and 

Appendix Table 36b). In other words, a large number of banks and thrift fell into the asset 

category of $250 million to $1 billion, an asset category considered to be “intermediate” 
96

small banks by the federal financial supervisory agencies. Intermediate small banks may 

have more difficulties undertaking large-scale community development financing projects 

such as significant Low-Income Housing Tax Credit deals or high volumes of equity 

investments in small businesses. These banks, however, may be receptive to a consortia 

approach or investing in CDFIs or Revolving Loan Funds to benefit a specific area within 

Appalachia in cases in which large scale financing is needed. 

The Level of Community Development Investment and Lending for Affordable 

Housing and Small Business 

Banks and thrifts in NCRC’s sample (located in Appalachian counties and with assets of 

more than $250 million as of year end 2004) made about $3.53 billion and $1.9 billion in 

community development lending and investing, respectively, during a time period of 

approximately once every 2.5 years (which was the average time period evaluated by CRA 

exams in the sample) (see Appendix Table 37c).20 In other words, lenders in the NCRC 

sample made about $5.43 billion in community development lending and investing every 

2.5 years.21 This figure of more than $5 billion represents a significant financial resource 

for economic development in Appalachia. It is all the more impressive when considering it 

does not include dollar totals of loans to individual small businesses and homeowners. 

Instead, the $5 billion reflects the amount available for community development projects 

such as large scale housing developments or small business incubators that benefit 

neighborhoods or even entire rural counties in Appalachia. 

Banks located in metropolitan areas made considerably higher levels of total community 

development loans and investments than banks located in non-metropolitan areas in 

Appalachia. Banks located in metropolitan areas issued a total of $3.27 billion in 

 

20 The average time period for which CRA data on lending and investments was considered on the exams in 

the NCRC sample was 30.8 months. This average number of months for large bank CRA exams was 32.7 

months, and the average for small banks was 26.8 months. The median values were 32 and 24 months, 

respectively. The prior period investments have been subtracted from the total community development 

lending and investment totals. 

21 This total does not include outstanding investments and loans from previous time periods not made during 

the most recent CRA exam cycle. The total prior period investments include $16 million for community 

development lending and $215 million in community development investing. 
97

community development loans on their most recent CRA exams while banks located in 

non-metropolitan areas made a total of $264 million in community development loans (see 

Appendix Table 37c and Figure 16). Likewise, banks located in metropolitan areas made a 

total of $1.7 billion in community development investments and banks in non-metropolitan 

counties issued $206 million in community development investments. This does not 

necessarily translate into much fewer community development loans and investments for 

non-metropolitan areas since banks located in metropolitan areas most likely have included 

non-metropolitan counties as part of their assessment areas or geographical areas 

scrutinized on their CRA exams. But even after taking into account the non-MSA 

assessment areas of MSA headquartered banks, non-MSA areas most likely receive 

considerably less bank community development lending and investing. 

It is also likely the case that the total community development investment and lending 

disparities among banks headquartered in metropolitan and non-metropolitan areas are 

being driven by a few very large banks. The median community development lending and 

investment figures still showed that banks headquartered in metropolitan areas issued 

higher levels of community development financing but the differences narrowed 

considerably. Banks located in metropolitan areas issued a median community 

Community Development Lending 

in Metro and Rural Areas

Metro Areas, 

$3,269,832,196

Rural Areas, 

$264,387,608

Community Development Investment

 in Metro and Rural Areas

Metro Areas, 

$1,696,854,929

Rural Areas, 

$205,892,899

Figure 16 

Source: Appendix Table 37 c. Total Values – row CD Lending and CD Investment 

and columns Rural Areas and Metro Areas
98

development lending level of $1.811 million as opposed to the $1.585 million made by 

banks located in non-metropolitan counties (see Appendix Table 37b). Banks 

headquartered in metropolitan areas issued a median level of $1.461 in investments while 

banks in rural counties made a median level of $848,000 in investments. 

NCRC attempted to break down the total community development lending and investing 

figures into sub-totals for housing and small business development. This endeavor was 

more successful for community development investing as opposed to lending. CRA exams 

vary in the level of specific detail they provide on community development financing. 

Some exams provide much detail on every community development project financed by 

banks while others reveal only total amounts of community development lending or 

investing. For whatever reason, the level of detail was greater for community development 

investments than lending (perhaps because investments were considered under a separate 

test for banks with assets greater than $250 million while community development lending 

was considered as part of a lending test). The total amount of community development 

lending for all banks in the NCRC sample was $3.53 billion with $3.1 billion that could not 

be classified as supporting housing or small businesses (see Appendix Table 37c). In 

contrast, most of the investment dollars could be classified as either supporting affordable 

housing or small businesses. The total amount of community development investment was 

$1.9 billion with $707 million that could not be classified as supporting affordable housing 

or small businesses. 

Considering the amount of community development lending and investments that could be 

classified suggests that the level of bank community development financing supporting 

affordable housing is higher than that for small businesses. In total, all banks and thrifts in 

NCRC’s sample made $297 million in community development loans that financed 

affordable housing versus $117 million in community development loans for small 

businesses in Appalachia (see Appendix Table 37c and Figure 17). 
99

Similarly, banks and thrifts in NCRC’s sample issued $807 million in investments for 

affordable housing as opposed to $174 million in investments for small businesses in 

Appalachia during the time period of the most recent CRA exams for the banks and thrifts 

in NCRC’s sample. Examining average or median community development loan and 

investment levels per bank for affordable housing and small businesses yielded similar 

disparities in favor of affordable housing. This analysis is not intended to suggest that 

community development financing levels for affordable housing should go down so that 

levels for small businesses can go up. Instead, it suggests that banks could be encouraged 

to increase their overall levels of community development financing and small business 

development. 

Examples of Small Business Financing 

Some examples of innovative community development financing illustrate that CRA has 

motivated important financing for small business development and expansion in 

Appalachia. For instance, Union State Bank in Alabama with $257 million in assets made 

a construction loan of $1,800,100 for a childcare facility in a moderate income area. The 

day care provided its services to all citizens in the area; however, it offered a discounted 

rate to low- income individuals. The CRA exam for United Bank in Parkersburg, West 

Virginia stated that this bank maintained a $2.2 million equity investment in a small 

Community Development Loans by Purpose:

 Housing and Small Business

Housing, 

$297,397,431

Small 

Business, 

$117,271,479

Community Development Investments by Purpose: 

Housing and Small Business

Housing, 

$807,413,830

Small Business, 

$174,107,733

Figure 17 

Source: Appendix Table 37 c. Total Values – rows CD Lending (Housing and Small Business) and 

CD Investment (Housing and Small Business) and column All Banks 
100

business investment company (SBIC). The SBIC focused on businesses located throughout 

West Virginia. Finally, S&T Bank, a Pennsylvania-based bank with $2.2 billion in assets, 

invested almost $300,000 in a federal preservation tax credit project, according to its CRA 

exam. The project involved an investment in a commercial office building in a moderateincome census tract. 

Relationships Among CRA Ratings, Community Development Investment and 

Lending Levels 

NCRC’s sample revealed that banks with higher ratings or grades on their investment and 

lending tests had higher levels of community development investments and lending. While 

this finding would appear to be intuitive, it is nevertheless important since it indicates that 

if banks are encouraged to perform well on their CRA exams, then the level of community 

development financing will increase in Appalachia. Banks can receive one of five ratings 

on their lending or investment tests: Outstanding, High Satisfactory, Low Satisfactory, 

Needs to Improve, and Substantial Noncompliance. 

Substantial differences in investment levels were present for Appalachian banks with 

various ratings on their investment test. The median community development investment 

level for the 20 banks with Outstanding ratings was $17.3 million and was $2 million for 

the 41 banks with a High Satisfactory ratings on their Investment Test (see Appendix Table 

38b and Figure 18). Median investment levels drop precipitously for banks with lower 

ratings. The 62 banks with Low Satisfactory ratings had median investment levels of 

$858,388 and the 18 banks with Needs-to-Improve ratings had median investment levels of 

just $84,994. 
101

Median Community Development Investments by CRA Rating

$84,995

$858,388

$2,003,915

$17,250,000

$0

$2,000,000

$4,000,000

$6,000,000

$8,000,000

$10,000,000

$12,000,000

$14,000,000

$16,000,000

$18,000,000

$20,000,000

Needs to Improve Low Satisfactory High Satisfactory Outstanding

Banks with various ratings also had significantly different ratios of community 

development investment to assets. Banks with Outstanding ratings on the Investment Test 

had average ratios of community development to assets of .84% (see Appendix Table 38a). 

In other words, the average dollar amount of community development investments was less 

than 1 percent of bank assets or .84% of bank assets. Banks with High Satisfactory ratings 

had ratios of community development investment to assets of .56%. Banks with the lowest 

ratings had much lower ratios. 

The differences among the mean community development investments to assets ratio were 

statistically significant for a number of the ratings categories. The difference between 

.56% for banks with High Satisfactory ratings and .22% for banks with Low Satisfactory 

ratings was statistically significant (see Appendix Table 38a). The difference between 

.22% for banks with Low Satisfactory ratings and .07% for banks with Needs-to-Improve 

ratings was also statistically significant. Interestingly, only the differences between banks 

with Outstanding and High Satisfactory ratings were not statistically significant. 

Figure 18 

Source: Appendix Table 38 b. Median Values – row CD Investment 
102

A sensible objective is to motivate as many Appalachian headquartered banks as possible 

to strive for a High Satisfactory or Outstanding ratings on their investment tests since banks 

with these ratings were making statistically significant higher dollar number of investments 

in Appalachia than banks with lower ratings. Many banks desire higher ratings on CRA 

exams to enhance their public reputation and demonstrate solid CRA performance to the 

public and their regulatory agencies.22 If stakeholders (nonprofit organizations, public 

agencies, CDFIs, and others) present enticing opportunities, partnerships, and/or programs 

for increasing levels of investments, a number of banks will seize these opportunities as a 

means of bolstering their CRA ratings and increasing their level of profitable community 

development investments. 

The community development lending levels were also substantially different for banks with 

various ratings on the lending test. Banks with Outstanding ratings on the lending test had 

a median community development lending level of $2.6 million (see Appendix Table 39b). 

Just going down one notch in the ratings to High Satisfactory resulted in considerably less 

community development lending. Banks with High Satisfactory ratings on the lending test 

had a median community development lending level of $1.8 million, about $700,000 less 

than banks with Outstanding ratings. The difference was even more dramatic between 

banks with High Satisfactory and Low Satisfactory ratings. The median community 

development lending dollar amount of banks with Low Satisfactory ratings was $654,300, 

about one quarter the amount of banks with High Satisfactory ratings (see Appendix Table 

39b and Figure 19). 

 

22 The federal regulatory agencies consider CRA performance and ratings when banks submit applications to 

merge and open branches. Solid CRA performance, consistent CRA performance on all the component tests, 

and high ratings increase the chances of expeditious approval of bank applications. 
103

Median Community Development Lending by CRA Rating

$654,300

$1,826,682

$2,588,500

$0

$500,000

$1,000,000

$1,500,000

$2,000,000

$2,500,000

$3,000,000

Low Satisfactory High Satisfactory Outstanding

The community development lending to asset ratios were substantially different for banks 

with various ratings on the lending test but they were not statistically significant. The 

community development lending to asset ratios were .96%, .54% and .33% for banks with 

Outstanding, High Satisfactory, and Low Satisfactory ratings on the lending test, 

respectively (see Appendix Table 39a). One possible reason for the lack of statistical 

significance is that the lending test includes a number of other components besides 

community development lending. In contrast, the investment test is solely focused on 

community development investing. Despite the lack of statistical significance, the absolute 

dollar amounts and ratios for community development lending differed greatly among 

banks with various ratings on the lending test. Again, the objective should be to motivate 

banks to achieve High Satisfactory and Outstanding ratings on the lending test in order to 

maximize the amount of community development lending in Appalachia. 

Lastly, small bank CRA exams did not provide much of an impetus for banks to engage in 

community development lending and investing. As stated above, small banks with assets 

under $250 million can receive bonus points for community development financing. Only 

two small banks out of 78 small banks in the sample had information on community 

Figure 19 

Source: Appendix Table 39 b. Median Values – row CD Lending 
104

development investments included on their CRA exam. Seven small banks in the sample 

had information on community development lending included on their CRA exam. 

The Level of Bank Branches in Appalachia 

CRA exams include an analysis of bank branching patterns as a component of the CRA 

service test. The service test includes the number and percent of branches by income level 

of census tract. The branching data in this chapter differed from the branching data 

presented in other chapters in that the data here were from CRA exams whereas the 

branching data in the other chapters were from the FDIC web page.23 The objective in this 

section of the chapter was to describe branching patterns in detail for banks of various asset 

sizes and to assess if CRA service test ratings reflected differences in branch penetration in 

low- and moderate-income areas. Since branches had a significantly positive impact on the 

level of lending as discussed in the regression chapter, it is important to see if CRA exams 

are motivating banks to place more branches in low- and moderate-income areas. 

The CRA exam data suggested overall differences in branching by category of counties and 

confirmed the analysis above that showed a relative shortfall of branches in NonMSA 

counties. The CRA exam sample included 7,662 branches; 7,244 branches were owned by 

large banks while small banks controlled 418 branches (see Appendix Table 36c). Almost 

1,500 branches were located in low- and moderate-income census tracts. Banks 

headquarted in MSAs had 5,956 branches while banks located in NonMSAs had just 1,706 

branches.24 Interestingly, the median number of branches was 10 branches located in both 

MSA and NonMSA counties. The reason for the disparities was the larger banks with 

higher average assets in MSA areas. The average number of branches in the two county 

categories was quite different: 54 for MSA counties and 17 for NonMSA counties. 

 

23 The previous data on branching from the FDIC was from http://www2.fdic.gov/sod/index.asp and 

http://www2.fdic.gov/sdi/index.asp. 24 The differences in distressed and non-distressed counties are not discussed because a small sample, just 8 

banks, were headquarted in distressed counties. The CRA exam data for branching in distressed counties is 

contained in the tables. 
105

Banks with Low Satisfactory ratings on the service test did not place branches in 

proportion to the portion of census tracts that were low- and moderate-income (LMI) in 

Appalachian counties. Overall, the banks with different ratings did not differ that much in 

the average percent of branches they placed in LMI census tracts. Banks with Outstanding 

ratings on the service test located 19.4 percent of their branches in LMI tracts while the 

branch distribution in LMI tracts was 19.2 percent and 16.7 percent, respectively, for banks 

with High Satisfactory and Low Satisfactory ratings, respectively (see Appendix Table 

40a). 

The variations in performance became apparent when calculating the difference in the 

percent of branches in LMI tracts and the percent of tracts that were LMI. For banks with 

Low Satisfactory ratings, the portion of branches in LMI tracts was 5.9 percentage points 

less than the portion of tracts that were LMI (see Appendix Table 40a). In contrast, for 

banks with Outstanding and High Satisfactory ratings, there was no difference in the 

percentages of branches in LMI tracts and the percentages of tracts that were LMI. 

Interestingly, the differences on this measure for banks with High Satisfactory and Low 

Satisfactory were not statistically significant. Just as was found on the lending test, the 

differences in performance on this measure may not be statistically significant because the 

service test includes a number of components. However, the differences appear to be 

substantial, and point to the desirability of motivating banks to score well on the service 

test. 

The Future in CRA Performance 

The federal banking agencies recently changed the CRA exam format for mid-size banks 

with assets between $250 to $1 billion in assets (the change occurred after the time period 

in this study).25 Instead of a separate lending, investment and service test, the new mid-size 

 

25 The federal banking agencies changed the CRA regulation in August of 2005 and then adopted new 

Questions and Answers on the CRA regulation in March of 2006. See the Federal Register, Vol. 70, No. 147, 

August 2, 2005, pp.44256-44270, and the Federal Register on Friday, March 10, 2006 Volume 71, No. 47, 

page 12424. The Office of Thrift Supervision (OTS) made different changes to its CRA regulation over 

several months starting in the summer of 2004. This report does not discuss the OTS changes because of the 
106

bank exam will include a lending test and a community development test. The community 

development test will assess community development lending, investments and services. 

The new exam format raises a series of questions including whether the tests will be as 

rigorous and whether levels of community development lending and investing will increase 

or decrease in Appalachia. 

The new exam for mid-size banks is highly significant for Appalachia. The great majority 

of banks located in Appalachia were mid-size banks in NCRC’s sample. Mid-size banks 

with assets between $250 million to $1 billion totaled 136 banks in Appalachia while banks 

with assets above $1 billion dollars totaled just 40 banks. Small banks with assets less than 

$250 million were 44 of the Appalachian banks. Since the great majority of Appalachian 

banks now have new CRA exams, it is important that the exams remain rigorous. 

Because NCRC found substantial differences in community development lending and 

investment levels and branching levels for banks and thrifts with different ratings, it 

appears that the current three tests of the large bank exam are effective in identifying 

quantitative differences in performance and awarding banks ratings that reflect these 

differences. Nationally and especially in Appalachia, the regulatory agencies must ensure 

that the new mid-size bank exam format is as effective as the previous large bank exam in 

motivating and rewarding mid-size banks and thrifts to offer community development 

loans, investments, and services. 

A vital element of migrating to the new exams is to establish expectations that banks must 

be expected to maintain and improve upon their overall level of community development 

(CD) investing and lending. Federal agencies should make clear, for example, that banks 

will receive lower ratings if they dramatically decrease their combined levels of CD 

lending and investing in the first round of the new CRA exams. The preamble to the new 

CRA regulations for mid-size banks included a quote stating that the federal banking 

agencies “do not intend to suggest that a bank may simply ignore one or more categories of 

 small number of federally chartered thrifts in Appalachia and because there is a possibility that the OTS may 

be changing its CRA regulations again. 
107

community development or arbitrarily decrease the level of such activities.” This 

guideline, reinforced recently in the Interagency Question and Answer document, must be 

implemented in a manner that ensures that community development lending and investing 

do not decrease, especially in a region like Appalachia that depends on mid-size banks. 

The new community development test for mid-size banks does not have an explicit 

criterion for bank branching. It is not clear, for example, if the new exams will carefully 

scrutinize the number and percent of bank branches in LMI census tracts. Since substantial 

differences of bank branching in LMI tracts exist for banks with different CRA ratings, it is 

critically important that the new tests also have rigorous measuring mechanisms for 

assessing bank branching in LMI communities. The new Question and Answer document 

states that “the presence of branches located in low- and moderate-income geographies will 

help to demonstrate the availability of banking services to low- and moderate-income 

individuals.”26 This is the closet that the regulatory agencies will come for a specific 

branching criterion on the new mid-size bank exam. It is an improvement over earlier 

language. Hopefully, it will be interpreted to mean that mid-size banks will still be 

assessed by the number and percent of branches in low- and moderate-income areas. 

The report found that banks located in metropolitan areas had much higher levels of 

community development financing than banks located in non-metropolitan areas. The 

regulatory agencies also amended the CRA regulations to provide CRA points for 

community development financing in rural middle-income census tracts located in 

distressed and underserved counties. It is possible that community development financing 

may increase in non-metropolitan and distressed counties as a result of these newly eligible 

census tracts. 

Community development financing directed to middle-income tracts in distressed rural 

counties may indeed be beneficial but must be considered in the overall economic context 

of the rural community. On the one hand, a county may be quite distressed economically 

and have high poverty rates, meaning that a middle-income tract still has low absolute 

 

26 Federal Register citation, March 2006 on the Interagency Question and Answers, op. cit. 
108

income levels. In rural areas, CRA defines income levels based on a statewide median 

income for rural counties. This means that middle-income as defined as 80 to 120% of area 

median income could still be low in absolute terms. In cases in which middle-income 

represents low absolute income levels, community development directed to middle-income 

census tracts benefits these particular tracts and could have beneficial effects in 

surrounding low- and moderate-income tracts. 

On the other hand, a middle-income tract in a distressed county could have a reasonably 

high absolute income level in a state in which the median income level of rural counties is 

also relatively high. Or the middle-income tract itself could simply have a high median 

income level, regardless of the rural statewide median income level. In these instances, 

community development financing in the middle-income tract in a distressed county would 

still count on CRA exams. However, CRA examiners should also ensure that a bank is 

financing community development activities in low- and moderate-income census tracts as 

well. The recently revised Interagency Question and Answer document on CRA indicates 

that addressing credit needs in distressed rural counties includes financing projects in lowand moderate-income areas. This Question and Answer was added to prevent the 

possibilities of a disproportionate amount of community development financing flowing to 

middle-income census tracts, particularly those that have relatively high absolute income 

levels. 

Finally, the sample revealed that the largest share of community development lending and 

investments went towards meeting affordable housing goals. Affordable housing 

community development investments are often in the form of mortgage-backed securities 

(MBS), which while a qualified investment, are neither innovative nor complex. In 

addition, examiners should ensure that banks are not churning MBS investments. In other 

words, one bank will buy a MBS right before their CRA exam, and then sell the securities 

to another bank that is preparing for its CRA exam. Investing in MBS serves a community 

development need only if churning is prohibited. Also, the new community test should 

reward mid-size banks for pursuing a diversified portfolio of community development 
109

investments and loans, including affordable housing, small business and economic 

development, and other initiatives to support low- and moderate-income areas. 

Conclusion 

This chapter reviewed CRA exams of banks headquartered in Appalachia in order to 

quantify banks’ level of community development lending, investing, and branching. The 

chapter focused on community development lending and investing that supports small 

business development. 

The chapter detailed bank headquarter location and asset distribution in Appalachia. 

Almost 30 percent of the Appalachian banks were located in Pennsylvania with the next 

highest portion (14 percent in Alabama). While the numbers of banks located in MSAs and 

NonMSAs were similar, banks located in MSAs had combined assets of $420.6 billion 

versus $73.3 billion for banks in NonMSA counties (see Appendix Table 36c). Of the 

more than $5 billion in community development lending and investing that occurs during 

the CRA exam cycle, the great majority of it was financed by banks located in MSAs. This 

does not mean that NonMSA counties are starved of community development financing 

since banks located in MSA counties likely have CRA assessment areas extending into 

NonMSA counties. However, the disparities in community development lending and 

investment by metropolitan status of county are possibly significant. Further study should 

investigate if banks headquartered in MSAs have assessment areas extending into 

NonMSA counties and if the banks located in MSAs offer significant amounts of 

community development financing in NonMSAs. 

The chapter found an imbalance in the amount of community development lending and 

investments devoted to affordable housing and small business development. For example, 

the chapter documented about $807 million in affordable housing investments as opposed 

to $174 million in small business investments (see Appendix Table 37c). Banks located in 

Appalachia should be encouraged to increase their overall level of community development 

financing and devote a significant portion of that increase to small business development. 
110

Lastly, the chapter revealed that banks with different CRA exam ratings actually did have 

substantial differences in their levels of community development investments, loans and 

branches. This has important policy implications in the context of the new CRA exam for 

mid-size banks, which constituted a majority of the banks located in Appalachia. The 

chapter concluded with observations of how to ensure that the new CRA exams for midsize banks were as rigorous as the old exams. 
111

Alternative Financial Institutions in Appalachia 

Previous chapters have discussed trends in the financial services industry that affect access 

to capital for small business development in Appalachia, particularly in distressed and 

underserved markets. As the financial services industry modernizes and becomes 

increasingly consolidated, there are concerns that access to capital may be threatened in 

lower-income markets where small business borrowers often have marginal credit or 

limited business histories. Improvements in technology allow for much more streamlined, 

cost-effective underwriting, and consolidation leads to increasingly centralized decisionmaking. As decision making becomes more standardized and less relationship oriented, 

businesses owners without strong credit or capital, particularly those in disinvested or 

underserved markets, may have difficulty accessing necessary capital for starting or 

growing their businesses. In recent decades, a diverse network of non-bank financial 

institutions has grown and attempted to fill such gaps in access to credit. 

This chapter examines the presence of regional development finance institutions and other 

intermediary business development lenders in Appalachia. Such intermediaries are often 

loan funds which are typically operated by a mix of public, private, non-profit, or for-profit 

organizations and receive capital from sources such as mainstream financial institutions; 

federal, state, and local government agencies; and foundations. This section uses a variety 

of data sources to analyze the presence of different types of such institutions in the region, 

focusing on community development financial institutions (CDFIs), government-backed 

revolving loan funds (RLFs), development venture capital funds, and SBA lending 

intermediaries.27 

 

27 In the following chapter we make a distinction between community development financial institutions (CDFIs) and revolving loan

funds (RLFs). In broad terms, we consider a CDFI an institution whose primary mission is providing community development finance 

and technical assistance to underserved and distressed markets. RLFs also provide loans and technical assistance to businesses in 

underserved markets, but, frequently, RLFs are a small part of a larger quasi-government organization whose mission is to promote 

regional economic development. As such their primary mission is not providing community development finance. The analysis in this 

chapter uses data from the CDFI industry and from ARC on their RLF lending pool. While there is a modest degree of overlap between 

institutions in the two data sets, we feel that differences in organizational mission and available data warrant two distinct sections. 
112

Community Development Financial Institutions (CDFIs)

The current Community Development Financial Institution (CDFI) industry emerged over 

decades as public and private sector players responded to the difficulties that many 

distressed markets, such as minority, lower-income, and rural communities, experienced in 

accessing mainstream financial services. CDFIs are niche financial institutions whose 

mission is to provide targeted financial services such as retail bank accounts, affordable 

housing finance, and small business capital to disinvested areas. In addition to such 

products, CDFIs also place a strong emphasis on building the capacity of the markets they 

serve through providing high levels of hands on financial literacy training, housing 

counseling, and entrepreneurial technical assistance. 

The CDFI industry is made up of a diverse set of institutions that to varying degrees 

provide a mix of financial products and services and capacity building to distressed 

communities. The four basic types of CDFIs are community development banks, credit 

unions, loan funds, and development venture capital funds. 

Community development banks and credit unions are regulated financial institutions with 

the ability to take deposits and offer loan products. Community development banks are 

for-profit entities whose focus is to provide targeted lending and investment geared towards 

the redevelopment of distressed communities. The main source of capital for community 

development banks is deposits received from individuals and institutions and government 

grants and investments. Community development credit unions (CDCUs) are non-profit 

cooperatives that provide affordable financial services to individuals without traditional 

bank accounts and help these individuals develop assets. CDCUs specialize in providing 

low-cost deposit accounts in communities not served by mainstream financial institutions 

and often extend credit at more flexible terms. CDCUs are primarily capitalized by 

member deposits, but also receive capital investments from other sources such as 

mainstream financial institutions. CDCUs offer consumer loans, vehicle loans, mortgages, 

and small business loans to distressed markets and often lead the way in product 
113

innovation. CDCUs were the among the first institutions to offer low-cost, short term 

consumer loan products to compete with high cost payday lending operations. 

Community development loan funds are not depository institutions, but are non-profit 

organizations that leverage investments by outside sources such as banks, foundations, 

corporations, and government agencies to provide lending for small business development, 

housing, microenterprise, or community facilities in distressed markets. Community 

development venture capital funds are for-profit entities who also leverage investments 

from outside sources to provide equity investments or equity-like loans for business 

development in distressed communities. 

In its early years, the growing CDFI industry was primarily capitalized with government or 

foundation resources, but changes in government policy and the financial services industry 

have led to shifts in the sources of financial support for CDFIs. Mainstream financial 

institution participation was limited and typically involved investing in loan pools for 

affordable housing development and mortgage lending. The Community Reinvestment Act 

(CRA) changed the nature of financial industry support of the CDFIs. CRA was passed in 

1977 to promote lending and investment by depository financial institutions in low- and 

moderate-income markets. In its early years, however, CRA’s effectiveness was limited 

largely by weak regulatory enforcement. Substantial changes to the CRA regulation in 

1995 altered the way banks were monitored for their community reinvestment 

performance. As related to CDFIs, the updated CRA regulation added specific components 

that examined banks for their levels of community development lending and investments 

and grants. This change served as incentive for banks and thrifts to provide low-cost loans 

and investments to CDFIs who were able to leverage these resources to finance activities 

that mainstream institutions found too risky to finance directly. CRA has often been 

credited with spurring the rapid growth of the CDFI industry in the 1990s which saw the 

establishment of the more new CDFIs than any other decade.28 

 

28 The CDFI Data Project. 2005. Providing Capital, Building Communities, Creating Impact. 
114

The federal government also established the CDFI Fund in 1994 under the Department of 

Treasury. It provides financial grants and technical assistance awards to CDFIs and 

implements the Bank Enterprise Award (BEA) program which rewards banks and thrifts 

who are active in supporting the CDFI industry. The CDFI Fund also implements the New 

Markets Tax Credit Program which provides tax credit allocations for community 

development entities to use in attracting investment in lower-income communities. 

The CDFI industry has faced significant challenges recently. Sources of funding have been 

a particular concern. Government funding for CDFIs from sources such as the CDFI Fund 

and the SBA have been consistently threatened in recent federal budgets. Foundation 

support, a traditionally strong source of funding for the CDFI industry, has waned in recent 

years. Additionally, as mentioned in previous chapters, the Community Reinvestment Act 

has been weakened. Changes implemented by federal banking regulators put less emphasis 

on the importance of critical community development loans and investments for many midsized banks. The increasingly complex and global financial services industry now requires 

that CDFIs increase their level of sophistication in accessing capital markets and financing 

projects. In many markets, CDFIs now compete with the community development 

corporations of major banks for the best projects.29 There has also been a growing 

emphasis from funders to document impact created by their investment. 

CDFIs in Appalachia 

The Appalachian region has a diverse set of development finance intermediaries. The 

following section takes a closer look at the CDFI industry in Appalachia. 

An analysis of the membership lists of the major trade associations that represent different 

types of CDFIs gives a sense of the nature of the CDFI industry in Appalachia.30 Table 5 

 

29 Moy, Kirsten and Alan Okagaki. July 2001. “Changing Capital Markets and Their Implications for Community Development 

Finance.” Capital Xchange. Brookings Institution. Washington D.C. 30 The major CDFI trade associations surveyed were Association for Enterprise Opportunity, Community Development Venture Capital 

Alliance, National Federation of Community Development Credit Unions, National Community Capital Association, National 

Community Investment Fund, and the CDFI Fund. This list is not comprehensive of all development finance intermediaries. There are 

many small revolving loan funds or loan funds that are for-profit or government or quasi-government agencies who are not members of 

these associations. These institutions will be discussed in subsequent sections of this chapter. 
115

shows CDFIs located in the region by state31 and type of CDFI. There are over 100 CDFIs 

active in the region. Appalachian Pennsylvania has 29 CDFIs while West Virginia has 14 

and Alabama has 11. At the other end of the spectrum, Appalachian South Carolina has no 

CDFIs and Georgia, Maryland, and Mississippi each have one. Of note, there are no 

community development banks in the region, although there are 26 community 

development credit unions. Appalachian Alabama has a high concentration of CDCUs 

where seven of the area’s 11 CDFIs are CDCUs. The most prevalent type of CDFI in 

Appalachia are loan funds with a total of 71. Pennsylvania has the most loan funds with 

21. Kentucky and Tennessee each have high concentrations of loan funds where nine of 

ten and eight of ten CDFIs respectively are loan funds. Finally, in Appalachia there are 10 

institutions set up specifically for community development venture capital investment. 

Table 5. Appalachian CDFIs by State and Type32

Credit Loan Venture

State Total CD Banks Unions Funds Funds

Alabama 11 0 7 4 0

Georgia 1 0 0 1 0

Kentucky 10 0 1 9 0

Maryland 1 0 0 0 1

Mississippi 1 0 0 1 0

New York 10 0 3 5 2

North Carolina 9 0 1 6 2

Ohio 5 0 1 3 1

Pennsylvania 29 0 7 21 1

South Carolina 0 0 0 0 0

Tennessee 10 0 2 8 0

Virginia 6 0 1 4 1

West Virginia 14 0 3 9 2

Total 107 0 26 71 10

Community development loan funds offer a diverse array of products and services. Loan 

funds broadly serve four sectors: microenterprise, small business development, housing, 

and community facilities. Microenterprise lenders target very small firms, typically those 

with fewer than five employees, for loans of less than $35,000. These lenders often target 

minority, women-owned, and start-up businesses and provide high levels of technical 

 

31The region represented is only that part of each state within the Appalachian Regional Commission boundaries. 32 CDFIs were taken from the association membership lists or known sources of funding. Credit Unions were members of the National

Federation of Community Development Credit Unions (NFCDCU) . Microlenders were members of the Association of Enterprise 

Opportunity (AEO) or were a registered SBA microlending intermediary. Loan funds were members of National Community Capital 

Association (NCCA). Venture capital funds were members of the Community Development Venture Capital Alliance (CDVCA) or 

received venture capital funding from the Appalachian Regional Commission. 
116

assistance. Other loan funds target larger or more established businesses in distressed 

markets and provide a mix of loan and equity products with the primary goal of creating or 

retaining regional jobs. In addition to standard debt products, these loan funds many also 

operate venture capital funds that provide equity investment to rapidly growing small or 

mid-sized businesses in distressed communities. Funds that target housing can provide a 

variety of financing to developers of affordable housing or mortgages to lower-income 

households for homeownership, home improvement, or refinancing out of troubled loans. 

Loan funds who specialize in community facilities make funding available for child care 

centers, clinics, or other types of community service organizations. Analysis of results 

from the CDFI Data Project Survey show that 58 percent of loan funds participating in the 

survey served multiple sectors.33 

The 71 community development loan funds in Appalachia have a strong emphasis on 

business lending. Table 6 categorizes the services offered by Appalachian loan funds as 

microlending, small business, housing, community facilities. A category has also been 

added for loan funds who offer equity-like venture capital financing for business 

development in addition to an array of other products.34 Over 70 percent of Appalachian 

loan funds offer some type of microfinance product, while 35 percent of loan funds make 

larger small business loans. Just under 27 percent of Appalachian loan funds provide 

housing finance, while only two loan funds specifically state they do lending for 

community services such as daycare and health facilities. Within the region, four loan 

funds operate venture capital investment firms as well as offering an array of other small 

business lending services. These four loan funds are in addition to the ten stand-alone 

development venture capital firms identified above in Table 5. 

 

33 CDFI Data Project. Providing Capital, Building Communities, Creating Impact 34 Information on services offered is based on a January 2006 analysis by the authors’ of trade association and loan fund web sites. 
117

Table 6. Services Offered by Appalachian Loan Funds 

Total

Loan Micro Small Community Venture

State Funds Business Business Housing Services Capital

Alabama 4 3 1 0 0 0

Georgia 1 1 0 0 0 0

Kentucky 9 3 6 2 0 2

Maryland 0 0 0 0 0 0

Mississippi 1 1 0 0 0 0

New York 5 5 2 4 1 0

North Carolia 6 4 3 2 0 0

Ohio 3 3 1 0 0 1

Pennsylvania 21 16 6 8 0 0

South Carolina 0 0 0 0 0 0

Tennessee 8 5 3 1 0 1

Virginia 4 3 2 2 1 0

West Virginia 9 6 1 0 0 0

Total 71 50 25 19 2 4

Activities Financed

Analysis of Appalachian CDFIs

In order to gain a more complete understanding of CDFI activity in Appalachia, we created 

a special dataset that combines data from two national surveys of CDFIs. The major 

dataset used was from the CDFI Data Project (CDP). The CDP is an annual survey 

conducted by CDFI industry trade associations35 that collects data on the activities, 

financial condition, and performance of CDFIs across the country. Where possible we 

enhanced this dataset with information from the CDFI Fund’s Community Investment 

Impact System (CIIS) survey. This survey collects institution- and transaction-level data 

from CDFIs who receive awards or New Markets Tax Credit allocations from the CDFI 

Fund. 

Our combined dataset covers FY 2003 and contains information from nearly 468 of the 

nation’s roughly 1,000 CDFIs.36 The dataset contains information on 47 CDFIs located in 

Appalachia. Table 7 breaks out the types of CDFIs represented in the sample and 

compares Appalachia to the nation. Appalachia has a slightly higher percent of total CDFIs 

that are either loan funds or venture capital funds than the national aggregate. Just under 

43 percent of Appalachian CDFIs in the sample are loan funds compared to just over 34 

percent for the national aggregate, and six percent of Appalachian CDFIs are venture funds 

 

35 Participating associations include Aspen Institute, Community Development Venture Capital Alliance, National Federation of 

Community Development Credit Unions, National Community Capital Association, and National Community Investment Fund. 36 The CDP contains data on 459 CDFIs, 38 of which are in the Appalachian region. Where possible, we added data on nine 

Appalachian CDFIs from the CIIS survey that were not included in the CDP. 
118

compared to just under 5 percent nationally. Appalachia has a smaller share of CDFIs that 

are credit unions than the nation. Just under 57 percent of national CDFI sample are credit 

unions compared to 51 percent for Appalachia. There are no community development 

banks in Appalachia. 

Table 7. Types of CDFIs Represented in Combined Dataset, FY 2003 

Appalachia National

CDCUs 51.1% 56.6%

CD Banks 0.0% 4.3%

CD Loan Funds 42.6% 34.4%

CD Venture Funds 6.4% 4.7%

Total CDFIs 47 468

The Appalachian CDFI industry is less mature than the national industry. Although 

Appalachia is home to many well established and influential community development 

finance intermediaries such as Kentucky Highlands Investment Corporation, the regional 

industry has developed much more recently than the national industry. Figure 20 shows 

that just under half of all CDFIs in Appalachia were established after 1990 compared to just 

under 38 percent for national CDFIs. Community development loan funds and venture 

capital funds have experienced tremendous growth since 1990. Just under 60 percent of 

national loan funds have been established since 1990 compared to nearly 73 percent of 

Appalachian loan funds. Nationally, over 90 percent of community development venture 

capital funds were established post 1990. Of the two Appalachian venture capital funds in 

data set, one was established after 1990. 
119

Figure 20. Percent of CDFIs established after 1990 

40.0%

21.2%

59.9%

90.5%

37.8%

0.0%

37.5%

72.7%

50.0% 48.6%

0.0%

10.0%

20.0%

30.0%

40.0%

50.0%

60.0%

70.0%

80.0%

90.0%

100.0%

Banks CU Loan Funds Venture Total

National CDFIs Appalachia CDFIs

Appalachian CDFIs serve predominantly rural markets. Table 8 shows that in FY 

2003 the activity of national CDFIs was fairly evenly distributed between major urban, 

minor urban, and rural markets while Appalachian CDFI clients were predominantly 

located in rural markets. On average, just under 50 percent of Appalachian CDFI clients 

were in rural areas compared to just under 34 percent for national CDFIs. Conversely, an 

average of less than 20 percent of Appalachian CDFI clients were from major urban areas37

compared to nearly 38 percent for national CDFIs. On average, 31 percent of Appalachian 

CDFI clients were in minor urban areas. This reflects the rural character of the region and 

is consistent with the CDFI mission of targeting underserved markets. Research has 

consistently shown that rural business owners have difficulty accessing capital due to 

limited supply and a lack of experience accessing capital markets.38 

 

37 The CDP defines a “major urban” area as a metropolitan area with a population over 1 million. In Appalachia, the two 

“major urban” areas are Pittsburgh and Birmingham. “Minor urban” areas are those metropolitan areas with less than 1 million in 

population. Rural areas are all non-metro areas. 

38 Markley, Deborah and Don Macke. March 2002. “Capital for Rural Entrepreneurs” Center for Rural Entrepreneurship. Monograph

7. 
120

Table 8. Average Percent of Clients Located in Different Geography Types, FY2003 

Appalachia National

Major Urban 19.4% 37.9%

Minor Urban 31.4% 28.4%

Rural 49.3% 33.7%

Total CDFIs Reporting 25 273

Appalachian CDFIs are active lenders. When controlling for asset class, Appalachian 

CDFIs had similar portfolio characteristics when compared to national CDFIs. Table 9 

classifies CDFIs into four asset size categories and compares Appalachian CDFIs to 

similarly sized national institutions.39 In three of the four asset classes, Appalachian 

CDFIs, on average, closed fewer loans in FY2003 than their national counterparts, but also 

made larger average loans and on average had a larger portfolios of outstanding loans. For 

example, the three Appalachian CDFIs with assets between $10 and $30 million closed an 

average of 259 loans in FY2003 compared to an average of 367 loans closed by national 

CDFIs of similar size. However, the average dollar amount of the loans closed in FY2003 

by Appalachian CDFIs of this size was slightly larger than national CDFIs at $5.2 million 

compared to $5.1 million. Additionally, Appalachian CDFIs with assets between $10 and 

$30 million had average portfolios of outstanding loans of $13.6 million compared to $9.9 

million for similarly sized national CDFIs. This indicates that while Appalachian CDFIs 

may have smaller annual deal flow than similarly sized national counterparts, they are still 

active lenders who participate in larger projects or take a more substantial stake in projects. 

Table 9. Average CDFI Portfolio Characteristics by Asset Category, FY2003 

Averages ARC National ARC National ARC National ARC National

Loans Closed 56 62 228 215 259 367 975 1,632

$$ Loans Closed $272,527 $162,776 $1,344,519 $1,396,601 5,208,393 $5,101,214 17,878,528 14,595,684

Assets $574,901 $521,895 $4,181,312 $4,266,619 20,551,788 $16,668,958 51,766,384 46,239,734

Portfolio Outstanding $324,708 $222,969 $2,464,277 $2,528,346 13,625,475 $9,894,197 36,245,748 26,761,531

CDFIs 14 120 16 195 3 60 3 36

<$1M $1M-$10M $10M-$30M $30M-$70M

Appalachian CDFIs placed a heavy emphasis on lending for business development. 

Tables 10 and 11 examine the types of CDFI financing outstanding in terms of loans and 

 

39 We limited out asset categories to institution below $70 million because the largest Appalachian CDFI is at $64 in assets. 
121

dollars in FY 2003. Appalachian CDFIs placed a stronger emphasis on business financing 

than national CDFIs.40 Four percent of Appalachian CDFIs’ financings outstanding were 

for business development in 2003 compared to three percent for national CDFIs. However, 

over 32 percent of dollars loaned went to business development compared to only 18 

percent for national CDFIs, a difference of nearly 14 percentage points. This indicates that 

Appalachian CDFIs made larger loans or investments in business development than their 

national counterparts. In 2003, the percent of loans and dollars outstanding for 

microenterprise lending in Appalachian and national CDFIs were similar. However, for 

both CDFI groups, microfinancing accounted for a small share of the total outstanding 

loans pools. 

Table 10. Breakout of Direct Financing Outstanding (Number of Loans), FY2003 

Difference

Between App.

Appalachia National and Nation

For Businesses # 4.0% 3.0% 1.0%

For Housing # 17.1% 12.0% 5.2%

For Microenterprise # 3.1% 3.3% -0.2%

For Other # 5.9% 6.0% 0.0%

For Personal Development # 69.6% 75.1% -5.5%

For Community Facilities # 0.2% 0.7% -0.5%

Total Financing Outstanding # 13,877 282,164 NA

Total CDFIs Reporting 34 294 NA

Table 11. Breakout of Direct Financing Outstanding (Dollars Loaned), FY 2003 

Difference

Between App.

Appalachia National and Nation

For Businesses $ 32.2% 18.4% 13.8%

For Housing $ 40.3% 45.1% -4.8%

For Microenterprise $ 1.9% 1.4% 0.5%

For Other $ 4.4% 3.1% 1.3%

For Personal Develompent $ 20.1% 23.3% -3.2%

For Community Facilities $ 1.1% 8.7% -7.6%

Total Financing Outstanding $ $200,618,712 $4,862,012,489 NA

Total CDFIs Reporting 34 294 NA

 

40 Business financing represents debt and equity financing to small or mid-sized businesses. Loans to micro businesses are considered 

separately. 
122

Appalachian CDFIs’ emphasized lending to larger businesses and assist more jobs per 

loan.41 In FY 2003, less than 39 percent of businesses financed by Appalachian CDFIs 

were microbusinesses compared to over 77 percent for national CDFIs (Table 12). 

Therefore over 61 percent of the businesses financed by Appalachian CDFIs were larger 

enterprises. By focusing on financing larger businesses, Appalachian CDFIs reported 

being able to create or retain over 3,300 jobs in the region in FY 2003. This averages to 

over 11 jobs assisted per business financed. By comparison, national CDFIs, report 

assisting 2.8 jobs per business financed. Jobs assisted are not necessarily new jobs created, 

but rather a combination of jobs created and jobs retained over a given period. 

Table 12. Types of Businesses Financed and Job Outputs, FY2003 

Appalachia National

Total Businesses Financed 292 8,366

Micro Businesses Financed 113 6,477

Share Micro 38.7% 77.4%

Total Jobs Assisted 3,315 23,022

Jobs Assisted per Business Financed 11.35 2.75

CDFIs Reporting 21 168

Appalachian CDFIs were heavily reliant on the government funding for debt or 

investment capital. As mentioned previously, CDFIs receive debt or investment capital 

from a variety of sources such as depository and non-depository financial institutions; 

federal, state, and local governments; and foundations. CDFIs are typically heavily 

dependent on external sources of lending capital. Table 13 breaks out sources of capital by 

type of CDFI in FY 2003. Individual deposits comprised the majority of debt capital for 

both Appalachian and national credit unions. 

 

41 The CDFI Data Project defines a microbusiness as firm with five or fewer employees or one receiving a loan for $35,000 or less. A 

larger business as one that has greater than five employees or one that received financing greater than $35,000 for the purpose of 

expansion, working capital, equipment purchase/rental, or commercial real estate development or improvement. 
123

Table 13. Sources of CDFI Debt Capital by CDFI Type, FY 200342

App. National Ratio App. National Ratio App. National Ratio

Banks Thrifts and Credit Unions $ 2.4% 2.4% 1.01 37.0% 46.7% 0.79 12.5% 26.0% 0.48

Corporations $ 0.5% 1.1% 0.43 0.3% 1.7% 0.15 0.0% 2.2% 0.00

Government $ 1.1% 0.7% 1.53 43.9% 13.8% 3.17 46.8% 23.4% 2.00

Foundations $ 0.9% 0.4% 2.38 6.7% 14.7% 0.46 27.7% 43.4% 0.64

Individuals $ 82.7% 88.9% 0.93 1.7% 2.9% 0.59 0.0% 0.0% NA

National Intermediaries $ 1.7% 0.6% 2.96 2.7% 2.9% 0.92 6.6% 2.0% 3.37

Non-Depository Financial Institutions $ 0.1% 0.1% 1.26 0.0% 6.6% 0.00 6.2% 2.9% 2.17

Other $ 8.9% 4.6% 1.93 3.5% 5.5% 0.64 0.2% 0.1% 3.37

Religious Institutions $ 1.7% 1.2% 1.35 4.2% 5.2% 0.81 0.0% 0.0% NA

Total CDFIs Reporting 13 116 NA 19 157 NA 2 19 NA

CDCUs CDLFs CDVCs

Appalachian community development loan funds and venture capital funds both received 

the largest share of debt or investment capital from government sources. Appalachian loan 

funds received over three times as much of their debt capital from government sources as 

their national counterparts while Appalachian venture capital funds received twice as much 

funding from government sources as national venture funds. Forty four percent of 

Appalachian loan fund debt capital came from federal, state, or local government sources 

while nearly 47 percent of venture capital fund capitalization was from government 

sources. Nationally, loan funds received less than 14 percent of debt capital from 

government sources while venture funds received just over 23 percent of investment capital 

from the government. 

Appalachian loan funds had a smaller share of debt capital from all non-government 

sources than their national counterparts. Nationally, community development loan funds 

received a larger share of lending capital from depository financial institutions, 

foundations, and non-depository financial institutions than Appalachian loan funds. In 

particular, only 37 percent of debt capital for Appalachian loan funds came from banks and 

thrifts as opposed to 47 percent for national loan funds. Appalachian development venture 

capital funds received a larger share of investment capital from national intermediaries and 

non-depository financial institutions than national funds. National peer development 

venture capital funds, however, received much more investment capital from depository 

financial institutions and foundations than Appalachian funds. 

 

42 One outlier loan fund was removed when calculating sources of debt capital. This loan fund received a disproportionately large

amount of capital from non-depository financial institutions. 
124

Appalachian loan funds should diversify their sources of debt capital. As mentioned 

previously, funding for CDFIs has consistently been threatened in recent federal budgets. 

Government sources along with regulated financial institutions accounted for 81 percent of 

Appalachian community loan fund lending capital. These same sources accounted for 

roughly than 60 percent national community development loan fund lending capital. This 

heavy dependence on government and financial institution resources may make 

Appalachian loan funds more vulnerable to changes in government funding cycles or bank 

investment in community development than their national counterparts. As mentioned 

previously, however, Appalachian loan funds received limited funding from foundations 

and no debt capital from non-depository financial institutions, while these are second and 

fourth largest sources of capital for national community development loan funds. 

Appalachian CDCUs and CDVCs have higher levels of self-sufficiency than national 

peers. Given the scarcity of funding sources and the intense competition for available 

capital, one of the key concerns of the CDFI industry today is improving self sufficiency. 

One way to measure self sufficiency is to look at the percent of an institution’s expenses 

that can be covered by earned revenue (i.e. revenue generated through lines of business and 

not grants or investments). A ratio of earned revenue to total expenses of 1.0 or greater 

indicates that an institution could support itself on earned revenue alone. Figure 21 

compares the self-sufficiency of Appalachian and national CDFIs by type in FY 2003. The 

average self sufficiency ratio of Appalachian CDFIs was .56 compared to .77 of the 

national aggregate. However, this aggregate number masks the fact that Appalachian credit 

unions and venture capital funds had higher self-sufficiency ratios than their national 

counterparts. In FY 2003, Appalachian community development credit unions had a self 

sufficiency ratio of .88 and Appalachian community development venture capital funds had 

a self sufficiency ratio of .68. Both of these numbers were well above national averages of 

.62 and .44 for credit unions and venture capital funds respectively. 
125

Figure 21. Self Sufficiency Ratios by CDFI Type, FY2003 

0.62

0.65

0.44

0.77

0.88

0.35

0.68

0.56

0

0.1

0.2

0.3

0.4

0.5

0.6

0.7

0.8

0.9

1

Credit Unions Loan Funds Venture Funds All CDFIs

National CDFIs Appalachian CDFIs

Appalachian community development loan funds lagged national numbers in the 

ability to support themselves through earned revenue. Unlike community development 

credit unions and venture capital funds, Appalachian community development loan funds 

had a low levels of self sufficiency. Figure 21 shows that regional community 

development loan funds had a self-sufficiency ratio of .35 indicating that only 35 percent of 

total expenses could be covered by earned revenue. This number is well below that of 

national loan funds. This low level of self-sufficiency paired with the heavy reliance that 

Appalachian loan funds have on government sources for debt capital, should raise some 

concerns about the long term viability of Appalachian community development loan funds. 

Revolving Loan Funds

Revolving loan funds (RLFs) are pools of capital provided by the public and private sectors 

for the purpose promoting economic development in distressed and underserved markets. 

RLFs are among the oldest types of development finance intermediary. Federal 

government agencies began funding revolving loan pools in the mid-1960s in response to 
126

losses in jobs, tax revenue, and private investment in many urban and rural markets.43 

RLFs are typically capitalized by grants from federal, state, and local governments. Loans 

are made to business owners in distressed markets, usually at interest rates below the 

market rate. As the loan principal and interest are paid back to the RLF, funds are available 

to be re-loaned. Borrowers who receive RLF loans are often able to leverage these loans to 

access additional capital from private market sources. One of the main social impact goals 

of RLFs is job creation and retention. 

The Appalachian region is rich in RLFs. An analysis of loan funds receiving federal grants 

show that over 190 exist in the region. The three main federal agencies who fund revolving 

loan funds targeted towards economic development are the US Department of Agriculture 

(USDA), the Economic Development Administration (EDA) and the Appalachian Regional 

Commission (ARC). Through its Intermediary Relending Program (IRP), Business 

Enterprise Grant Program, Economic Development Grant Programs the USDA has 

provided grants to 146 RLFs in Appalachia. The EDA has provided grants to 59 RLFs in 

Appalachia through its revolving loan fund program. Since 1977, the Appalachian 

Regional Commission has provided grants to 38 RLFs in the region. ARC loan funds will 

be discussed in more detail below. Map 6 illustrates the number of loan funds who 

received grants from the USDA, EDA, and ARC by state in Appalachia. In addition to 

federally funded RLFs, there are numerous revolving loan funds capitalized through state 

and local funds not included in this analysis.

 

43 National Council on Urban Economic Development. October 1995. Revolving Loan Funds: Recycling 

Capital for Business Development. Washington D.C. 

128

ARC revolving loan funds have been active lenders in the region since inception. ARC 

made the first grant in its revolving loan fund program in 1977. Since that date, the 38 

ARC capitalized loan funds have made 1,570 loans for over $104 million. Only one loan 

fund that has received an ARC grant has failed to make a loan. The median loan fund 

received its first ARC grant in 1993. ARC loan funds have made a median of 25.5 total 

loans and loaned a median of nearly $1.8 million. As of the first quarter of 2006, the 

median loan fund had 10 loans outstanding and a median of just over $607,000 in loans 

outstanding. On average, ARC loan funds had over $845,000 in loans outstanding and 

over $200,000 in funds available to lend for an average loan pool size of just over $1 

million. The pool of ARC grantees had, on average, 19.3 percent of their funds available to 

lend. In aggregate, ARC loan funds have written off 3.8 percent of dollars loaned. The 

highest percent of loans written off was 12.6 percent. Eleven of the 38 ARC loan funds 

had zero write-offs. These write off numbers are comparable to industry averages for rural 

loan funds. A survey of rural EDA RLFs indicates a 5.5 percent of loans were written off 

with 28 percent of loan funds surveyed having no write offs. 44

The average deal flow of ARC revolving loan funds has declined since 2000, but their 

level of participation in deals has increased. Figure 22 tracks average number of loans 

by ARC RLFs over a seven year period starting in 2000. It shows that the average number 

of loans originated by ARC-funded RLFs has declined since 2000 when an average of over 

four loans were originated per fund. This number declined to a low of 2.6 loans per fund in 

2005. In 2006, ARC RLFs made an average of 3.4 loans per fund.45 This level of annual 

deal flow somewhat lags industry benchmarks. A 2002 analysis of rural EDA revolving 

loan funds found average deal flow of 6.1 loans per year.46 However one important 

distinction to consider when examining the deal flow of ARC-funded RLFs is that they are 

gap lenders that provide the portion of debt in a project financing package that a bank will 

not. It is very rare that an ARC-funded RLF would make a loan without a bank also 

providing project financing with the bank almost always acting as the primary lender. 

 

44 National Association of Economic Development Organizations Research Foundation. March 2003. Organizations that Manage Loan 

Funds Create Rural Jobs Efficiently. Washington D.C 45 RLF lending data for 2006 is annualized using data through April 2006. 46 National Association of Economic Development Organizations Research Foundation. March 2003. Organizations that Manage Loan 

Funds Create Rural Jobs Efficiently. Washington D.C. 
129

Because of this distinction, ARC-funded RLF lending almost always tracks trends in bank 

lending. 

Figure 22. Change in Average Annual Lending Activity by ARC-funded RLFs, 

2000-2006 

4.14

2.77

3.17

2.63 2.67 2.59

3.44

0.00

0.50

1.00

1.50

2.00

2.50

3.00

3.50

4.00

4.50

2000 2001 2002 2003 2004 2005 *2006

Loans per RLF

Despite a decline in deal flow for ARC RLFs, these funds have increased their average 

level of participation in deals particularly relative to other government RLFs. Figure 

23 charts the sources of financing for projects were ARC RLFs participated between 2000 

and 2006. On average loans by ARC RLFs gained an increasing share of total outside 

project financing47 between 2000 and 2006. In 2000, loans from ARC RLFs made up an 

average of 14.4 percent of outside project financing. These levels have generally tracked 

upward and peaked in 2006 where on average loans by ARC RLFs accounted for 22 

percent of outside project financing.48 In fact, bank debt and ARC RLF participation were 

the top two sources of outside project financing in 2006 and have followed the same 

general upward trend over the 2000 to 2006 time period. This growing level of project 

participation by ARC RLFs is in contrast to declining levels of participation by RLFs 

 

47 “Outside project financing” includes all sources of project financing except for borrower equity. 

48 RLF loan data for 2006 based on lending through April 2006. 
130

funded by other government agencies. In 2000 loans by RLFs funded by other government 

agencies were the second largest source of outside project financing making up nearly 38 

percent of total outside project funds. These numbers declined through 2006 when loans 

by other federally funded RLFs made up 13.5 percent of total outside project financing. 

This indicates that despite declining deal flow, ARC RLFs have been able to play an 

increasingly significant role in projects where they choose to be active. 

Figure 23. Change in Percent Contribution to Total Outside Project Funding by Financing 

Type, 2000-2006 

22.0%

37.8%

13.5%

47.5%

53.7%

62.6%

8.5%

1.9%

14.4% 14.6% 13.4% 19.7% 17.0%

16.9%

23.1% 23.9% 24.2% 22.2%

26.3%

51.5%

54.0%

50.2% 49.7%

0.3% 4.7% 10.2% 6.7% 9.5%

0.0%

10.0%

20.0%

30.0%

40.0%

50.0%

60.0%

70.0%

2000 2001 2002 2003 2004 2005 *2006

ARC RLF Other Gov RLF Bank Debt Other Debt and Non-Debt

The lending of 38 ARC capitalized revolving loan funds have created or retained a 

substantial number of jobs in the region.49 A fundamental goal of RLF lending is the 

creation or retention of local employment. Between 2002 and the first quarter of 2006, 

loans from ARC capitalized revolving loan funds helped create over 3,600 jobs and retain 

over 8,300 jobs in the region. The number of jobs created increased from 920 to 968 and 

the number of jobs retained increased from 1,365 to 2,761. All but one of the 38 ARC loan 

 

49 “Jobs created” represent new jobs that did not exist at a firm prior to receiving financing. “Jobs retained” represent jobs that existed 

prior to financing and remained after financing. There is a debate about the use of “jobs retained” statistics to measure the impact of 

RLF lending. Some feel that it is difficult to directly tie the retention of existing jobs to RLF financing and that these numbers are used 

to inflate the impact of RLF lending. Others feel that it is important to measure the number of jobs influenced by RLF loans whether or 

not the loan was directly responsible for the retention of a specific job. 
131

funds reported influencing at least one job. On average, ARC RLFs influenced an average 

of 315 jobs during this period. The median number of RLF jobs influenced was 263. The 

number of RLF jobs influenced ranged from 4 to 1,452. 

Figure 24 charts the change in jobs created and retained per loan by ARC RLFs between 

2002 and first quarter 2006. In 2002, ARC RLFs influenced 26.1 jobs per loan and loaned 

$3,254 per job. In 2005, ARC RLFs influenced 48.4 jobs per loan and loaned $1,797 per 

job influenced. Between 2002 and 2005, the number of jobs retained per loan increased 

from 15.7 to 35.9 jobs retained per loan. Over this same period, the number of jobs created 

per loan increased from 10.6 to 12.6. The efficiency of ARC RLFs at influencing local 

employment is on par with or exceeded other government funded RLF pools. An analysis 

of rural EDA RLFs conducted by the National Association of Development Organizations 

(NADO) showed that they on average created or saved 16 jobs per loan with 20 percent of 

rural RLFs creating or saving more than 30 jobs per loan. The same analysis showed that 

each job created or retained cost the loan fund $4,502.50 The increased ability of ARC loan 

funds to affect job retention and creation may be tied to the growing level of participation 

ARC RLFs are taking in projects they finance. 

 

50 National Association of Economic Development Organizations Research Foundation. March 2003. Organizations that Manage Loan 

Funds Create Rural Jobs Efficiently. Washington D.C.
132

Figure 24. Jobs created and retained per loan, 2002-2006 YTD

15.7 18.1

31.1

35.9

29.7

10.6

11.2

10.9

12.6

6.1

0.0

10.0

20.0

30.0

40.0

50.0

60.0

2002 2003 2004 2005 2006*

Jobs Retained per Loan Jobs Created per Loan

On a state by state basis, loan funds in Pennsylvania impacted the most regional jobs, 

but Kentucky and West Virginia funds created and retained jobs at the highest rate. 

Table 14 breaks out the state-by-state impact of ARC RLFs. Pennsylvania loan funds 

impacted 567 jobs per fund between 2002 and 2006 1Q. However, loan funds in 

Kentucky were the most efficient at impacting jobs by influencing nearly 110 jobs per loan 

and costing roughly $700 per job over this period. West Virginia funds were also efficient, 

influencing nearly 50 jobs per loan and costing less than $1,300 per job. On average, ARC 

loan funds created nearly 315 jobs per fund and influenced 32 jobs per loan at a cost of 

under $2,700 per job. 
133

Table 14. Jobs Impacted by ARC RLF Lending by State, 2002-2006 1Q 

Jobs Impacted Jobs Impacted Dollars Loaned

ARC Per RLF Per RLF Loan Per Job Impacted

State RLFs 2002-2006 1Q 2002-2006 1Q 2002-2006 1Q

Alabama 3 67.3 22.4 $2,129

Georgia 1 151.5 25.3 $7,789

Kentucky 3 401.7 109.5 $704

Maryland 1 172.0 21.5 $3,756

Mississippi 4 216.3 18.4 $4,473

North Carolina 1 37.0 12.3 $10,270

New York 5 230.8 25.1 $3,049

Ohio 4 107.8 13.1 $5,102

Pennsylvania 8 567.4 44.5 $1,854

South Carolina 3 506.3 20.8 $5,448

West Virginia 5 336.2 49.4 $1,277

ARC Total 38 314.6 32.1 $2,669

Community Development Venture Capital Funds 

A significant and growing subset of the CDFI industry are community development 

venture capital funds (CDVCs). These institutions specialize in providing equity or equitylike investments to businesses in distressed or underserved communities. Such equity 

products differ from the more traditional loan products offered by banks and many 

community development loan funds and are a significant driver of business growth. An 

expanding business needs significant capital to grow, but may not have a regular cash flow 

that would allow the firm to repay a substantial monthly debt service. Venture capital 

firms provide such businesses with a direct infusion of cash in exchange for a share of 

ownership. Such investments provide firms with the necessary capital to grow as well as 

the increased participation and expertise of the venture capital firm who are typically 

specialists in a given industry. CDVCs differ from traditional venture capital firms in their 

focus on financing businesses in distressed communities. 

Access to traditional venture capital has been limited by industry type and firm location. 

Venture capital firms typically focus on financing a small number of high growth industries 

often in high technology sectors. More traditional sectors of the economy such as 

manufacturing are slower growth industries and rarely benefit from venture capital 
134

financing. Additionally, venture capital financing is highly geographically concentrated. 

States with high concentrations of technology firms are regions that have benefited most 

from venture financing. A report from the Community Development Venture Capital 

Alliance (CDVCA) shows that between 1991 and 2000, over 65 percent of all venture 

capital financing went to five states (California, Massachusetts, New York, Texas, and 

Colorado) with well established technology sectors.51 In additional to high levels of 

concentration in a few states, traditional venture capital financing also has a very strong 

urban focus. A rule of thumb is that venture capital firms rarely invest in companies more 

than a two hour drive away giving a distinct disadvantage to more geographically dispersed 

non-metropolitan firms. The same report by CDCVA shows that of all firms receiving 

investment from traditional venture capital firms in 2001, over 98 percent were in 

metropolitan counties while less than two percent were in semi-rural counties and none 

were in rural areas. 

 

In Appalachia, the dearth of available equity capital was identified in a report produced by 

Mt. Auburn Associates for the Appalachian Regional Commission (ARC). The report 

identified gaps in capital needs for regional entrepreneurs. While a small subset of firms in 

the region sought some type of equity or risk capital, these firms had substantial difficulty 

in obtaining it.52 Limited access to equity capital can affect the ability of the region to 

develop, attract, or retain small- or mid-sized firms in high growth industries. The report 

recommended that ARC invest in socially oriented venture funds. 

In response to this recommendation, ARC began an entrepreneurship initiative that focused 

on promoting the growth of CDVCs in the Appalachian region. To this end, ARC initiated 

a partnership building effort through a series of conferences focused on access to equity 

capital in rural markets that brought together foundations, financial institutions, and 

economic development organizations. ARC also worked with the Community 

Development Venture Capital Alliance to enhance the capacities of area CDVC 

 

51 Schmidt, Brian. May 2003. “Assessing the Availability of Traditional Venture Capital in the U.S.: A 

Preliminary Analysis.” Community Development Venture Capital Alliance: New York, NY. 52 Mt. Auburn Associates. February 1998. Capital and Credit Needs in the Appalachia Region. Appalachian 

Regional Commission: Washington, DC. 
135

management teams. Additionally, as of October 2004, ARC had granted $4.4 million to 13 

CDVCs (11 active funds) in seven states in the region. These funds have a total 

capitalization of $96 million and have invested $13.6 million in 59 regional businesses. 

These investments have created over 1,000 jobs in the region.53 

The previous analysis of CDFIs in Appalachia identified some key issues in CDVC sources 

of capitalization and levels of self-sufficiency. Appalachian CDVCs received twice as 

much funding from government sources as national CDVCs, while national CDVCs were 

more heavily capitalized by depository financial institutions and foundations than 

Appalachian funds (see Appendix Table 9). This indicates there may be opportunity for 

Appalachian CDVCs to diversify into these sources of investment capital. Additionally, 

the above analysis showed that Appalachian CDVCs had a higher level of self-sufficiency 

that their national counterparts. Appalachian CDVCs had a .68 self sufficiency ratio 

compared to .44 for national CDVCs. This means that Appalachian CDVCs could support 

68 percent of their operating expenses through earned revenue. While this is not the 

optimal level of 1.0 or greater, it shows that Appalachian CDVCs perform at a high level 

relative to national peers. 

SBA Loan Programs 

The U.S. Small Business Administration administers a number of programs to help 

businesses in underserved markets access necessary capital. The SBA’s 7(a) program has 

been discussed previously. This section takes a closer look at two programs that require 

the presence of an intermediary: the SBA Microloan Program and the 504/CDC Loan 

Program. 

The SBA Microloan program makes funds available to non-profit community-based 

intermediaries for the purpose of making very small loans (under $35,000) to businesses. 

These loans are intended to go to very small firms and target business owners who 

traditionally have difficulty accessing capital such as start-up businesses and minority- and 

 

53 Source: Internal ARC data on Development Venture Capital Funds in Appalachia. 
136

women-owned firms. The SBA disperses funds to community based, non-profit lending 

intermediaries. These intermediaries make all credit decisions and have some discretion 

over loan terms. In recent federal budgets, funding for the SBA Microloan program has 

been eliminated only to be later returned. The future of the program remains uncertain.54 

SBA microlending intermediaries are effective at serving distressed counties, but have 

difficulty reaching minority-owned businesses. Table 15 shows the number of 

microloans per 10,000 businesses and per 10,000 microbusiness (fewer than 5 employees) 

in 2003-2004. The analysis shows that in Appalachia distressed counties have high levels 

of SBA-guaranteed microlending compared to non-distressed counties. Distressed counties 

received 10.1 microloans per 10,000 microbusinesses compared to 5.6 per microloans per 

10,000 microbusinesses in non-distressed counties. Overall, Appalachia had high levels of 

SBA-guaranteed microlending. The region had 6.1 loans per 10,000 microbusinesses 

compared to 4.6 per 10,000 microbusinesses nationally. In distressed counties, start-up 

businesses and those that are majority women owned received loans at levels comparable 

to the rest of the region and nation. Minority-owned businesses, however, seem to have 

more limited access to microfinance, particularly in distressed counties. Only 8.3 percent 

of microloans in distressed counties went to minority-owned businesses compared to 21.3 

percent in the region and 50 percent for the nation. Map 7 shows microlending in the 

region and plots the locations of intermediaries serving Appalachia. The highest levels of 

microlending appear in parts of central Appalachia, particularly in parts of Virginia, 

Kentucky, and North Carolina. New York also has high levels of microlending. 

Businesses in the southern part of Appalachia would appear to have more limited access to 

SBA-guaranteed microfinance with many parts of the region having zero microloans. 

 

54 Bernard, Tara Siegel. April 25, 2006. “Microloans are Again a Point of Budget Dispute.” American 

Banker. 
137

Table 15. SBA Micro Lending Activity in Appalachia, 2003-2004 

Distressed Non-Distressed

Counties Counties All USA

Loans per 10,000 

Micro Business (1-4 employees) 10.1 6.0 6.1 4.6

All Businesses 6.0 3.5 3.6 2.7

Percent loans made to:

Start-ups 36.1% 43.8% 43.2% 43.5%

Minority-Owned Business 8.3% 22.4% 21.3% 50.0%

Majority Woman-Owned Business 41.7% 38.8% 39.0% 44.9%

Appalachia

The SBA 504 loan program provides long term financing for large fixed costs such as a 

land acquisition, construction, infrastructure improvements or large equipment. Loans 

through the 504 program are structured to require a private lender to be senior lien holder 

and to finance up to 50 percent of a project. A Certified Development Company (CDC) 

serves as junior lien holder for up to 40 percent of the project cost. The CDC loan is 

guaranteed 100 percent by the SBA. The business is required to produce at least 10 percent 

of project costs. Generally, businesses are required to create or retain at least one job per 

$50,000 guaranteed by the SBA Use of the 504 loan program varies widely regionally. In 

many regions of the country the product is not well known. Smaller community banks 

have constraints on the size of loans they can make. The loan fees are high, and some 

lenders feel that the SBA paperwork and approval process slows down deals.55 

 

55 Office of the Controller of the Currency. February 2006. “SBA 504 Loan Program: Small Businesses’ Window to Wall Street” 

Community Development Insights. Washington D.C. 

139

There were few SBA 504 loans to distressed counties and minority and women-owned 

businesses received no 504 loans in 2003-2004. Table 16 shows that 504-guaranteed 

lending levels in Appalachia lags national averages except in lending to majority womenowned businesses. Within Appalachia, lending in distressed counties substantially lags that 

in non-distressed counties. Distressed counties received 1.2 504 loans per 10,000 business 

compared to 4.1 for the region. Although minority- and majority-women owned businesses 

in non-distressed Appalachian counties had access to 504-guaranteed lending on par with 

or well above national averages, similar businesses in distressed counties received no 504 

loans. Map 8 illustrates levels of 504 lending in the region. Unlike microlending, southern 

Appalachia has high levels of 504 lending, particularly in Alabama, Georgia, and South 

Carolina with the lowest levels of 504 lending seen in Virginia, West Virginia, and 

Kentucky. 

Table 16. SBA 504 Lending Activity in Appalachia, 2003-2004 

Distressed Non-Distressed

Counties Counties All USA

504 Loans per 10,000 Businesses 1.17 4.27 4.13 8.14

Percent of Loans to:

Minority-Owned Business 0.0% 21.4% 21.1% 21.9%

Majority Woman-Owned Business 0.0% 35.1% 34.6% 16.9%

Appalachia

141

Conclusion 

CDFIs

The community development financial institution industry in Appalachia is less mature 

than the national industry. Appalachian CDFIs largely target rural markets for their 

lending. Appalachian CDFIs lend at levels on par with national counterparts of similar 

size, but have a much stronger emphasis on lending for small and mid-sized businesses 

development. Financing larger businesses with greater than five employees has allowed 

Appalachian CDFIs to impact substantially more jobs than national CDFIs. Appalachian 

community development loan funds and venture capital funds have a strong reliance on 

capital from government sources. Appalachian loan funds also have low levels of selfsufficiency, particularly when compared to national counterparts. 

RLFs

Although revolving loan funds who received grant money from the Appalachian Regional 

Commission have smaller deal flow than some national indicators, they report being able to 

influence a substantial number of jobs in the region. The efficiency at which ARC RLFs 

influence jobs has increased over time, surpassing industry numbers in jobs created per 

loan and the dollars loaned per job influenced. 

SBA Intermediaries

SBA microlending intermediaries are effective at lending in Appalachian distressed 

counties, but substantially lag in terms of lending to minority-owned businesses in 

distressed counties. SBA 504 lending in Appalachia substantially lags national averages. 

Of particular concern is the fact the zero 504 loans were made to minority- or womenowned firms in Appalachian distressed counties. 
142

Conclusion 

The Appalachian Regional Commission (ARC) contracted with the National Community 

Reinvestment Coalition (NCRC) to conduct this study as part of ARC’s effort to develop 

Appalachia through increasing access to credit and capital for small businesses. 

Heightened capital flows to small businesses would bolster the economic development of 

the region by creating jobs, diversifying the economy, and further developing an 

entrepreneurial class in Appalachia. This study found that banks have committed 

substantial amounts of community development financing to the region and are responding 

well to the credit needs of Appalachian small businesses in minority communities. The 

study recommends that stakeholders work together to close remaining credit gaps and 

needs in Appalachia. 

Mid-size community banks were particularly responsive to the needs of small businesses in 

lower income and distressed rural communities in Appalachia. These lending institutions 

demonstrate that small business lending is profitable and rewarding for banks. The 

challenge for stakeholders is to encourage all lending institutions to expand upon profitable 

lending opportunities and to further finance an infrastructure for supporting small business 

and economic development. 

This study is cautiously optimistic that stakeholders can work together to close remaining 

credit gaps. The reasons for optimism include a favorable comparison between Appalachia 

and the nation on some indicators of lending. In addition, Appalachia has a lending 

infrastructure that includes about 227 banks and savings and loans with more than $500 

billion in assets, and a sector of alternative lending institutions featuring over 100 

community development financial institutions (CDFIs) and 190 revolving loan funds 

(RLFs). 

The Community Reinvestment Act (CRA) has had a substantial impact in leveraging 

increases in community development lending and investing in the Appalachian Region. 

This study finds that banks and thrifts headquartered in Appalachia issued about $5.4 
143

billion in lending and investing for affordable housing, small business development, and 

economic revitalization each CRA exam cycle (about 2.5 years). In addition, small 

business lending exhibited a positively unique and puzzling trend in Appalachia. In 

contrast to most other regions in the country, small business lending was higher where the 

minority population was higher on a county level in Appalachia. 

Despite signs of progress, differences in small business lending within Appalachia must be 

overcome by concerted and persistent efforts undertaken over a multi-year time period. 

Within Appalachia, small business lending is less accessible in non-metropolitan counties 

and counties experiencing economic distress. In addition, the smallest businesses with 

revenues under $1 million and businesses in low- and moderate-income communities 

experience the least access to credit. A series of policy initiatives are needed for 

overcoming the unequal access to credit including a program of branch building in 

underserved and non-metropolitan counties, the preservation of a community banking 

sector of mid-size banks, an intensified focus of Small Business Administration (SBA)-

guaranteed lending in counties with high levels of minorities, and the vigorous application 

of the Community Reinvestment Act (CRA) to address the need for small business 

development in non-metropolitan and distressed counties. 

The NCRC study updates the report commissioned by ARC in 1998 and conducted by Mt. 

Auburn Associations entitled Capital and Credit Needs in the Appalachian Region. The 

Mt. Auburn study motivated a follow-up study focusing on bank financing because one of 

the key findings of the Mt. Auburn study was that “Appalachian businesses are heavily 

dependent on the banking industry for financing.” In addition, the Mt. Auburn study 

identified significant credit needs as “insufficient financing appears to have a serious 

impact on the investment decisions of about one in five established companies.” Further, 

the Mt. Auburn study indicated that small firms with less than 10 employees had higher 

levels of unmet funding needs than their larger counterparts. 

The Mt. Auburn study broke important ground through its use of surveys of Appalachian 

small businesses. The study did not benefit, however, from publicly available data on CRA 

small business lending. The CRA data for the year 1996 first became available in summer 
144

of 1997 when the Mt. Auburn study was well underway. In addition, researchers became 

much more familiar with the strengths and weaknesses of the database over the next several 

years. Thus, this study provides an important update to the Mt. Auburn report by utilizing 

the small business lending data and probing to what extent the unmet credit needs overall 

and for very small businesses still exist in Appalachia. 

Since the Mt. Auburn study, new trends and challenges confront Appalachia. The 

heightened pace of globalization, consolidation in the banking industry, the high cost of 

energy, and rising interest rates pose significant challenges as well as new opportunities for 

business development. Changes in the Community Reinvestment Act (CRA) and federal 

economic development programs likewise present a series of challenges and opportunities. 

For example, the federal New Markets Tax Credit program promises to provide a 

significant amount of resources for development in Appalachia. The program authorizes 

the Department of Treasury to provide tax credits of 39% on up to $15 billion of private 

investments in low-income areas for business development activities and small business 

lending. Nonprofit and private sector entities in Appalachia are just beginning to take 

advantage of this new program. 

NCRC’s study was able to consider the impact on small business lending of a number of 

these large economic changes such as consolidation in the banking industry and the 

growing use of credit scoring in small business lending. However, future studies will be 

needed to further evaluate the impact on access to credit of changes in federal programs 

and banking regulations as well as globalization and other economic structural adjustments. 

Methodology and Findings 

This report employed a number of datasets and created datasets for the quantitative 

analysis. For the analysis of small business lending trends, NCRC used the publicly 

available data on CRA small business lending. This data was combined with U.S. Census 

data on population demographics and Dun and Bradstreet data on business demographics 

and credit scores. In addition, data was obtained from the Small Business Administration 

(SBA) on SBA lending programs. Branch and deposit data was obtained from the web 
145

page of the Federal Deposit Insurance Corporation (FDIC). The section of the report 

analyzing community development lending and investing created a database consisting of 

data pulled from CRA exams of banks and thrifts located in Appalachia. Finally, the 

chapter on alternative financial institutions used data collected by public agencies, ARC, 

and trade associations of Community Development Financial Institutions (CDFIs). 

The CRA small business lending data analysis used the year 2003. A longitudinal data 

analysis was not employed because changes in the definitions of loans in the CRA small 

business data had a significant impact on annual loan volumes. In addition, the number of 

lenders required to report the data has changed. It is recommended that ARC commission a 

future study, using the CRA small business data as one of the resources. Such a study 

should carefully assess the influence of changes in the database on similarities and 

differences in lending patterns found in this current study and the future one. A similar 

caveat applies to the CRA exam analysis. The most recent CRA exam was used for each 

lender in this study. A future study can assess if levels of community development 

financing by banks increased or decreased by using the subsequent exams for each lender 

headquartered in Appalachia. 

The major findings in this report include: 

Appalachia Compared to the Nation 

Small business demographics in the nation and in Appalachia were remarkably similar. 

The two largest small business sectors in the nation and in Appalachia were services and 

retail. Similarly, almost 60 percent of the small businesses in Appalachia and the nation 

were very small, consisting of 1 to 4 employees. 

 Appalachia compares favorably against the nation on some lending indicators. Appalachia 

compares favorably against the nation when considering small business loan-to-deposit 

ratios and small business lending in minority counties. The small business loan-to-deposit 

ratio for Appalachia was 7% in contrast to 5.2% for the nation, or 35% higher in 
146

Appalachia than the nation. In addition, banks made loans to 39.4% of the businesses in 

counties in which less than 20% of the population is minority in Appalachia, which was 

similar to national loan penetration rates of 41% for these counties. However, in counties 

in which more than 20% of the population is minority, banks made loans to 51.4% of the 

businesses in Appalachia, compared to national loan penetration rates of 42%. The lending 

levels within high minority population counties were 22% higher in Appalachia than the 

nation. 

Nationally, banks provided significantly more small loans per branch than did banks in 

Appalachia, but Appalachian banks provided more loans per branch in non-metropolitan 

counties. In 2003, banks across the country originated 85.6 loans per branch, which was 

35% higher then the 63.6 loans per branch for banks in Appalachia. But for nonmetropolitan counties, banks loaned at higher levels in Appalachia. Banks in Appalachian 

non-metropolitan counties provided 57.5 loans per branch, which was 8% higher then the 

53.2 loans per branch for similar counties in the nation. 

Trends within Appalachia 

Within Appalachia, businesses in low- and moderate-income census tracts and businesses 

with revenues under $1 million experienced particular difficulties accessing credit. In 

2003, 14% fewer businesses in low- and moderate-income census tracts received loans as 

compared to businesses throughout the region (35.4% compared to 41% for the region). In 

addition, only 23.6% of the small businesses with less than $1 million in revenues located 

in low- and moderate-income tracts received loans, which was 43% below lending levels 

for the Region as a whole. 

Banks have more difficulty serving non-metropolitan and distressed counties than 

metropolitan and non-distressed counties. In the Appalachian portion of nine states, the 

ratio of loans per small business was lower in non-metropolitan counties than metropolitan 

counties. For example, in Alabama, 58.6% of the businesses received loans in 

metropolitan counties while 48.6% of the businesses received loans in non-metropolitan 
147

areas during 2003. In addition, just 32.1% of the small businesses in distressed counties 

obtained small business loans in contrast to 41.9% of the businesses in non-distressed 

counties (Distressed counties have higher unemployment, higher poverty rates, and lower 

income levels). 

Banking industry structure impacts access to credit for small businesses in Appalachia. It 

is more likely that small businesses will receive loans in counties in which banks compete 

vigorously for customers by building and maintaining branches than in counties dominated 

by fewer banks that are less concerned with their branch presence. The study finds that 

small business lending was higher in counties with higher levels of bank branches. In 

counties with above median number of branches, the median number of loans by all banks 

was 1,287. In counties with below median number of branches, the median number of 

loans was 235. In contrast, overall lending was lower in counties with higher levels of 

bank concentration or consolidation. In Appalachian counties with below median levels of 

concentration (as measured by the Herfindahl-Hirschman index), the median number of 

small business loans was 1,120. In counties with above median levels of concentration, the 

median number of small business loans was 287 during 2003. 

The econometric analysis in the report reaffirmed the finding that lending in Appalachian 

counties was higher in counties with higher numbers of minorities. The federal 

government reports that minority-owned firms are expanding at a rapid clip across the 

country. Perhaps the rapid growth contributes to more lending in counties with high 

minority populations in Appalachia. Perhaps counties with greater diversity have more 

robust economies. This dynamic needs further exploration since it appears to be unique to 

Appalachia, and is a strength that can be built upon by stakeholders in Appalachia. 

Role of Small and Mid-Size Banks 

Another asset in Appalachia is its significant sector of small and mid-size banks. The 

literature suggests that small and mid-size banks are particularly oriented to the needs of 
148

small businesses in underserved communities. This study tends to confirm the distinct 

lending focus of smaller banks in Appalachia. The findings from the study include: 

Banks with assets between $250 million to $1 billion (mid-sized banks) had a higher 

percentage of total loans in non-metropolitan counties (12.3% of all loans) than 

metropolitan counties (6.5% of all loans) during 2003. Mid-size banks also had a higher 

market share of loans in distressed counties (14.7% of all loans) than non-distressed 

counties (8.4% of all loans) during 2003. 

 

In contrast to their loan penetration in non-metropolitan and distressed counties, mid-size 

banks were not as uniformly successful in counties with significant numbers of minorities. 

Mid-size banks made almost 30% of the loans in counties with more than 50% minorities 

but had their lowest market share of 6.7% of the loans in counties with 20% to 50% 

minorities. Mid-size banks therefore had mixed success reaching minority counties in 

Appalachia during 2003. 

As predicted in the literature, mid-size banks did not base their lending in Appalachia on 

the distribution of small business credit scores on a county level whereas all banks had 

higher levels of lending in counties with the greatest portions of low risk businesses. In 

addition, mid-size bank lending levels were not dependent on the size of small businesses 

whereas all banks had higher levels of lending in counties with a greater portion of 

businesses with 10 to 19 employees. This suggests that mid-size banks may be more 

oriented to the smaller businesses that may not have established credit histories. The midsize banking sector in Applalachia is therefore an important sector to start-ups and smaller 

businesses seeking to grow and expand. 

Trends in Small Business Administration (SBA) Lending 

The major lending program of the Small Business Administration (SBA) was more 

successful in reaching non-metropolitan counties than minority small businesses during 

2003. In Appalachia, African-Americans were 8.3% of the population but were issued just 
149

2.1% of the SBA 7(a) loans. SBA-guaranteed lending fared better in serving nonmetropolitan counties as the SBA 7(a) market share of loans was higher in nonmetropolitan counties than metropolitan counties during 2003. 

In contrast to overall lending, SBA 7(a)-guaranteed lending was not higher in counties with 

greater portions of minorities. It is possible that the relatively low levels of SBAguaranteed loans to minority-owned businesses or businesses in minority counties were due 

to relatively high levels of conventional lending to these businesses. In contrast to the 

findings for minorities, SBA-guaranteed lending exhibited more of a focus on nonmetropolitan counties. 

Role of the Community Reinvestment Act 

In addition to measuring how many home and small business loans banks and thrifts make 

to low- and moderate-income borrowers, the Community Reinvestment Act (CRA) exams 

scrutinize banks’ level of financing for affordable housing, and small business and 

community development. NCRC’s study found substantial levels of community 

development financing in Appalachia due to CRA. 

Banks and thrifts in Appalachia made about $3.52 billion and $1.69 billion in community 

development lending and investing during a time period of approximately once every 2.5 

years (which is the average time period evaluated by CRA exams in the study). In other 

words, lenders made about $5.4 billion in community development lending and investing 

every 2.5 years. This figure of more than $5 billion represents a significant financial 

resource for economic development in Appalachia. 

Banks with higher ratings on CRA exams were found to have substantially higher levels of 

community development lending, investing and branches in low- and moderate-income 

communities. Through the rating system, CRA exams are providing motivation and public 

recognition for banks to increase their level of community development financing in 

Appalachia. 
150

Despite the overall benefits of CRA, disparities remain in community development 

financing. Non-metropolitan and distressed counties had considerably smaller shares of 

bank assets. Banks located in the metropolitan counties had combined assets of $420.6 

billion (117 banks) versus $73.3 billion for assets of banks located in non-metropolitan 

counties (103 banks). Only 11 banks with combined assets of $4.3 billion were 

headquartered in distressed counties in Appalachia. The substantial differences in bank 

assets translated into non-metropolitan and distressed counties receiving less community 

development financing than metropolitan counties. 

Despite the large total dollar amount for community development financing, relatively 

fewer dollars were devoted to small business development. In total, all banks and thrifts in 

Appalachia made $297 million in community development loans that financed affordable 

housing versus $117 million in community development loans for small businesses in 

Appalachia. Similarly, banks and thrifts issued $807 million in investments for affordable 

housing as opposed to $174 million in investments for small businesses in Appalachia. 

Role of Alternative Financial Institutions in Appalachia 

This report also examined the characteristics and abilities of alternative financial 

institutions in financing small businesses in Appalachia. Alternative financial institutions 

consist of Community Development Financial Institutions (CDFIs), community 

development credit unions, loan funds and others that specialize in serving hard-to-reach 

populations and small businesses. The report documents that alternative financial 

institutions were effective in serving Appalachian small businesses and in creating and 

preserving jobs. At the same time, they did not serve the smallest of the small businesses 

to the same extent as their national peers. This study also documents that mainstream 

banks had difficulties serving the smallest businesses with revenues under $1 million; thus 

alternative financial institutions have a gap to fill that perhaps they are not filling as much 

as they could. Also, alternative financial institutions in Appalachia were not financed by 

banks to the same extent as their national peers. This suggests that CRA has a role to play 
151

in encouraging mainstream banks to increase their levels of debt and equity financing for 

small businesses directly and through the alternative financial institutions. 

The community development financial institution (CDFI) industry is made up of a diverse 

set of institutions that specialize in providing a mix of financial products and services to 

distressed communities. There were over 100 CDFIs in the Appalachian region. Seventyone of these were community development loan funds. Appalachian loan funds had a 

strong emphasis on business lending with over 70 percent offering a microfinance product 

for very small enterprises (typically five or fewer employees) and 35 percent offering loan 

products for larger businesses (typically greater than five employees). In the region, 

Pennsylvania had the largest number of loan funds with 21. Kentucky and Tennessee also 

had high concentrations of loan funds. Finally, in Appalachia there were 10 institutions set 

up specifically for community development venture capital investment. 

Appalachian CDFIs predominantly focused on rural markets and had been established 

more recently than counterparts in the national industry. Appalachian CDFIs loaned at 

levels on par with national counterparts of similar size. Appalachian CDFIs had lower loan 

levels by number of loans, but loaned more in terms of dollars and had larger outstanding 

loan pools. 

Appalachian CDFIs were successful in reaching small businesses but were not as 

successful in serving the smallest of the small businesses with less then five employees. In 

FY 2003, over 32 percent of Appalachian CDFI loan dollars outstanding were dedicated to 

small or mid-sized business development compared to only 18 percent for national CDFIs, 

a difference of nearly 14 percentage points. Additionally, in FY 2003, over 61 percent of 

the businesses financed by Appalachian CDFIs were enterprises56 with more than five 

employees compared to 23 percent for national CDFIs who focused more heavily on 

financing micro businesses (with under five employees). 

 

56 The CDFI Data Project defines a larger business as one that has greater than five employees or one that received financing greater 

than $35,000 for the purpose of expansion, working capital, equipment purchase/rental, or commercial real estate development or

improvement. A microbusiness would be a firm with five or fewer employees or one receiving a loan for $35,000 or less. 
152

Financing businesses with greater than five employees allowed Appalachian CDFIs to 

impact more jobs. By focusing on financing businesses with greater than five employees, 

Appalachian CDFIs reported being able to create or retain over 3,300 jobs in the region in 

FY 2003. Appalachian CDFIs reported assisting over 11 jobs per business financed. By 

comparison, national CDFIs, assisted 2.8 jobs per business financed. 

 

Appalachian CDFIs, particularly loan funds, had a heavy dependence on government 

funding and received less bank financing. Forty four percent of Appalachian loan fund 

debt capital came from federal, state, or local government sources while nearly 47 percent 

of venture capital fund capitalization was from government sources. Nationally, loan funds 

received less than 14 percent of debt capital from government sources while venture funds 

received just over 23 percent. Therefore, Appalachian loan funds received over three times 

as much of their debt capital from government sources as their national counterparts while 

Appalachian venture capital funds received twice as much funding from government 

sources as national venture funds. At the same time, Appalachian loan funds received 37 

percent of their debt capital from banks while national loan funds obtained 47 percent of 

their debt capital from banks. 

Appalachian community development credit unions and venture capital funds were more 

self-sufficient than their national peers while Appalachian community development loan 

funds had lower self-sufficiency rates than the national averages. In FY 2003, 

Appalachian community development credit unions had a self sufficiency ratio of .88 and 

Appalachian community development venture capital funds had a self sufficiency ratio of 

.68. Both of these numbers were well above national averages in their respective 

industries. In contrast, Appalachian community development loan funds had a very low 

self-sufficiency ratio of .35 indicating that only 35 percent of total expenses could be 

covered by earned revenue. This number was well below that of national loan funds which 

had self-sufficiency rates of .65. 

Within the sector of alternative financial institutions, ARC supported revolving loan funds 

were performing admirably. ARC funded revolving loan funds had declining deal flow, 
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but had taken a more active position in the projects in which they participate. The average 

number of loans originated by ARC-funded RLFs had declined since 2000 when an 

average of over four loans were originated per fund. This number declined to low of 2.6 

loans per fund in 2005, but grew somewhat in 2006 where the average increased to 3.4 

loans per fund. 

Despite this decline in deal flow, ARC RLFs had increased their average level of 

participation in deals particularly relative to other government-funded RLFs. Between 

2000 and 2006, the percent of outside project financing tied to ARC RLF lending increased 

from 14.4 percent to over 22 percent. This growing level of project participation by ARC 

RLFs was in contrast to declining levels of participation by RLFs funded by other 

government agencies. Loans through RLFs funded by other government agencies 

contributed nearly 38 percent of total outside project financing in 2000, but this number 

declined to less than 13.5 percent by 2006. 

ARC funded RLFs had been effective at influencing job creation and retention in the 

region. Between 2002 and the first quarter of 2006, loans from ARC capitalized revolving 

loan funds helped create over 3,600 jobs and retain over 8,300 jobs in the region. In 2002, 

ARC RLFs influenced 26.1 jobs per loan and loaned $3,254 per job influenced. In 2005, 

ARC RLFs influenced 48.4 jobs per loan and loaned $1,797 per job influenced. This 

means that ARC RLFs were influencing more jobs per loan, but spending less per job 

influenced. 

The Appalachian Regional Commission has worked to improve access to equity capital in 

the region. In response to lack of available equity capital in Appalachia, ARC began an 

entrepreneurship initiative that focused on promoting the growth of community 

development venture capital funds in the region. To this end, ARC initiated a partnership 

building effort through a series of conferences focused on access to equity capital in rural 

markets that brought together foundations, financial institutions, and economic 

development organizations. ARC also worked with the Community Development Venture 

Capital Alliance to enhance the capacities of area CDVC management teams. 
154

Additionally, as of October 2004, ARC had granted $4.4 million to 13 CDVCs (11 active 

funds) in seven states in the region. These funds had a total capitalization of $96 million 

and have invested $13.6 million in 59 regional businesses creating over 1,000 jobs in the 

region. 

SBA programs using alternative financial institutions recorded mixed success. SBA 

funded microlenders were effective at lending to distressed markets, but SBA microlending 

and 504 lenders provided only limited support to minority businesses in distressed 

counties. In Appalachia, distressed counties received 10.1 SBA microloans per 10,000 

microbusinesses compared to 6.0 per 10,000 microbusinesses in non-distressed counties. 

However, minority owned businesses in distressed counties received far fewer microloans 

than did other businesses throughout the region. Additionally, no SBA 504 loans were 

originated to minority- or women-owned businesses in Appalachian distressed counties, 

while over 20 percent of SBA 504 loans were originated to minority or women-owned 

businesses through the rest of the region. 

Data Limitations 

The CRA small business data has limitations that must be kept in mind when conducting 

research. Firstly, the definition of a loan origination changed over the years. The 

regulatory agencies allowed banks to count one loan renewal for a small business borrower 

as an origination in a given year. This means that if a sizable number of borrowers of a 

particular bank refinanced in one year as opposed to another year, the annual loan volume 

of a particular bank can fluctuate dramatically. When NCRC was starting this report, the 

yearly loan volume of all banks and thrifts in a couple of test cases (New York and West 

Virginia) fluctuated substantially. Because the definition of a loan origination caused a 

significant amount of this fluctuation, NCRC and ARC decided against a time series 

analysis. Nevertheless, it is acknowledged that a one-year snapshot limits the descriptive 

and statistical data analysis. 
155

A second data limitation is that the CRA small business data does not include the race and 

gender of the small business owner unlike the SBA data. It is therefore not possible to 

compare SBA and CRA small business lending patterns to women- and minority-owned 

small businesses. A third data limitation, as discussed above, was the elimination of the 

requirement for mid-size banks to collect and publicly report their CRA small business 

data. 

A fourth issue that may be related to a data limitation was the lack of a relationship in the 

regression equations between lending levels and sector of small businesses. Small 

businesses in different sectors such as retail as opposed to heavy machinery have needs for 

different types of loans. This report tried various versions of a small business sector 

variable but did not generate any statistically significant results for that variable. If we had 

more data on the type or purpose of the loans (such as loans for establishing stable cash 

flow as opposed to purchasing new equipment), the sector variable may have become 

significant. A future study should attempt to procure more detail on the purpose of the loan 

and/or perhaps experiment with specifying various dollar amounts of loans. 

A fifth issue related to data limitations and time constraints is a full investigation of the use 

of credit scoring by in-market versus out-of-market banks and financial institutions. The 

report investigated the use of credit scoring by mid-size banks with branches located in 

Appalachia but did not expand this inquiry to scrutinize the use of credit scoring by all 

banks with branches within Appalachia versus lenders lacking a branch presence in 

Appalachia. This is an area worthy of additional investigation to determine if the use of 

credit scoring corresponds to branch presence as well as the asset size of a bank. 

Another constraint regarding time series analysis involves the CRA exam analysis. NCRC 

conducted an analysis using the most recent CRA exam for each bank and thrift in the 

sample. If resources had permitted, the study could have considered bank lending and 

investing over two CRA exams (the most recent exam and the previous exam). That would 

have permitted the study to assess trends over time in different categories of counties. For 

example, the study found that the levels of community development lending and investing 
156

in non-metropolitan areas were lower than the levels of community development financing 

in metropolitan areas. Nevertheless, the study cannot comment upon whether levels of 

community development financing in non-metropolitan areas had been increasing over 

time since the study did not use the most recent and previous CRA exams for the banks and 

thrifts headquartered in Appalachia. It is possible that levels of community development 

lending and financing have been increasing in non-metropolitan areas due to the increased 

attention CRA received in the late 1990s and into the 21st century. Future studies will be 

able to pick up this important analysis commenced by the NCRC study. 

Policy Options 

Based upon the report’s findings, the following policy options are offered to increase 

access to credit and capital in non-metropolitan areas, distressed counties, and among small 

businesses with revenues under $1 million. A number of these recommendations can be 

implemented by ARC working together with stakeholders in the Appalachian region. 

These stakeholders include state agencies, elected officials, lending institutions, Federal 

Home Loan Banks, federal regulatory agencies, the U.S. Department of Treasury, financial 

intermediaries, public finance markets, development organizations, and the Federal 

Reserve Banks: 

Increase Branch Presence, particularly in non-metropolitan areas and distressed counties 

– The report found that lending is higher in counties with higher number of branches. 

Building bank branches, particularly in non-metropolitan and distressed counties, should be 

regarded as an important part of an economic development program. Public and private 

sector stakeholders should work together on a branch building program. Banks have been 

expanding their branch networks in the last 3 or 4 years; the challenge is to build branches 

in minority and low- and moderate-income communities. ARC, state agencies, and lending 

institutions should investigate New York State’s Banking Development District (BDD) 

Program. Begun in 1998, the BDD program offers partial property tax exemptions for 

branches opening in geographical areas in need of banking services. Local governments 

can also agree to earn below market rates of return on Certificates of Deposits in these 
157

branches. The New York State Banking Department reports significant increases in 

banking services including 256 loans per BDD branch and financial education services 

delivered out of these branches.57

Growth of a Community Banking Sector – Since mid-size banks with assets between $250 

million to $1 billion played important roles in small business financing, stakeholders 

therefore should ensure that the mid-size and smaller bank sector remain viable and 

vibrant. Incentives could be developed to support existing mid-sized banks, or encourage 

the formation of new banking institutions in underserved areas. For example, the Federal 

Home Loan Bank System should consider additional advances and other incentives to 

support the small business lending of mid-size banks. Currently, the Federal Home Loan 

Bank of Pittsburgh operates a Banking on Business (BOB) program that provides financing 

for bank loans that would not otherwise be made due to insufficient cash flow from the 

small business. Since its inception, BOB has provided $20.5 million in funding, creating 

and retaining 3,500 jobs.58 Likewise, the Federal Home Loan Bank of Atlanta runs the 

Economic Development Program that helps provide financing to small businesses.59 ARC 

could also work to stimulate the formation of development banks in the Region. In 

addition, the New York State program for expanding branches mentioned above could 

serve as a model and be especially adapted for mid-size banks headquartered in 

Appalachia. Finally, private sector incentives and investments for mid-size banks can play 

an important role in the preservation and expansion of the community banking sector. 

Increase levels of community development financing for small business development – 

The report found banks located in Appalachia devoted significantly higher levels of 

community development lending and investing for affordable housing than small business 

development. This finding does not mean that community development financing levels 

for affordable housing should go down so that levels for small businesses can go up. 

 

57 See http://www.banking.state.ny.us/pr980226.htm and http://www.banking.state.ny.us/pr050810.htm. Last 

accessed July 3, 2006. 

58 See http://www.fhlb-pgh.com/housing-and-community/real-life-stories/banking-on-business.html, last 

accessed December 21, 2006. 

59 http://www.fhlbatl.com/fhlb_content.cfm?lev1=5cis&lev2=bcedp&lev3=2edp, last accessed December 21, 

2006. 
158

Instead, it suggests that banks should be encouraged to increase their overall levels of 

community development financing and then could devote substantial portions of the 

increases towards small business development. Stakeholders including ARC, state 

agencies, and lending institutions should work together to expand community development 

financing for small business development and support. 

Diversify sources of debt and investment capital for community development loan funds 

and venture capital funds. Appalachian CDFIs need to diversify their funding base. 

Community development loan funds and venture capital funds are heavily reliant on 

government sources for debt and investment capital. These same institutions, however, lag 

national counterparts in accessing capital from depository financial institutions, nondepository financial institutions, and foundations in the case of loan funds and depository 

financial institutions and foundations in the case of development venture capital funds. 

ARC can develop relationships with potential investors and regulatory agencies to 

encourage increased investment within Appalachia, including partnerships with financial 

intermediaries such as the Community Reinvestment Fund, participation in public 

secondary markets, and continue efforts to utilize tax credit financings such as the New 

Markets Tax Credit program. Additionally, ARC should review other potential barriers to 

diversifying CDFI capitalization such as product offerings and loan pricing and structuring. 

Finally, CRA should be used to encourage banks to provide more financing to alternative 

financial institutions. 

Appalachian loan funds must increase operational self sufficiency. Appalachian loan 

funds, both Revolving Loan Funds and microenterprise funds, must increase levels of self 

sufficiency by reducing operating costs or increasing revenues. Costs can be reduced 

through consolidation of back office operations, a growing trend among national CDFIs. 

Costs could also be reduced by undertaking joint marketing efforts among independent 

loan funds. Operating revenues could be increased by increasing loan volume. This would 

likely require increased levels of capitalization or access to new financing through 

intermediaries. 
159

Continue to grow capacity of Appalachian development venture capital funds. Available 

literature shows that there remains a significant gap in access to equity financing in nonmetropolitan markets. ARC’s efforts to develop regional equity investment funds are 

important in bridging this gap and increasing regional entrepreneurship levels. ARC 

should continue to seed these investment funds, but also continue to build the capacity of 

regional fund managers and develop networks and relationships with key investment 

partners outside the region to reduce the reliance of Appalachian venture capital funds on 

government investment. ARC should also closely monitor the performance of these funds 

as they mature. 

Maintain Integrity of CRA exams – Maintaining CRA exam integrity is important since 

substantially different levels of community development financing were recorded by banks 

with different CRA ratings. Most banks headquarted in Appalachia are banks with $250 

million to $1 billion in assets. The federal regulatory agencies have implemented new 

CRA exams for these mid-size banks. Stakeholders must ensure that the new CRA exams 

require these mid-size banks to maintain and increase their levels of community 

development financing in Appalachia. In addition, the regulatory agencies recently 

amended the CRA regulations to provide CRA points for community development 

financing in rural middle-income census tracts located in distressed and underserved 

counties. Stakeholders should monitor CRA exams to ensure that rural low- and moderateincome areas as well as middle-income areas receive community development financing. 

In addition, stakeholders should ensure that metropolitan-based banks are also serving rural 

areas. Finally, more detailed data on the purposes of community development financing is 

needed on CRA exams to assess if the financing is responding to community needs. NCRC 

found that much more detail was available on the purposes (whether for housing or small 

business development) of community development investments than lending. 

Congressional oversight and hearings regarding CRA exam quality would also bolster the 

integrity of CRA exams. 

Restoration of Small Business Lending Data for Mid-Size Banks –The study finds positive 

and important findings of the lending patterns of mid-size banks. In 2005, federal 
160

regulators deleted the small business loan data reporting requirements for banks and thrifts 

with assets between $250 million and $1 billion in assets. It is counterproductive to 

eliminate this data because studies in future years will not be able to carefully examine the 

lending patterns of mid-size banks and fully and accurately assess their role in Appalachia. 

Federal regulators should consider ways to continue to collect this important economic 

data. In addition, federal regulators and Congress should consider requiring banks and 

thrifts to report upon the race and gender of the small business borrower. Lending to 

minority- and women-owned businesses would likely increase just as lending to minority 

and women homebuyers increased because the Home Mortgage Disclosure Act (HMDA) 

was amended in 1988 to require the reporting of race and gender of the borrower. Finally, 

the regulatory agencies need to establish stability in the definitions of loan originations and 

other aspects of the small business data so that time series analysis can become possible. It 

would also be preferable to require separate reporting of loan originations and 

renewals/refinances as is done with HMDA data. 

While data collection imposes costs, the benefits can exceed those costs. The data can 

document positive trends and highlight new opportunities as revealed by this study. 

Moreover, data reporting motivates banks to maintain and increase their lending levels to 

small businesses. 

Encourage Small Business Administration (SBA-guaranteed lending to Minority-Owned 

Businesses – The SBA should investigate ways to increase SBA-guaranteed lending to 

minority-owned businesses and in minority counties. It is possible that the relatively low 

levels of SBA-guaranteed loans to minority-owned businesses or businesses in minority 

counties were due to relatively high levels of conventional lending to these businesses. 

Also, there may be fewer lenders in minority counties that use SBA products. 

Alternatively, it is possible that there are still certain types of credit needs that are not being 

satisfied by the conventional lending, opening up new opportunities for the SBAguaranteed lending. In Appalachia, the counties with high levels of minorities are in 

Mississippi, Alabama, Georgia, South Carolina, and North Carolina. SBA regional offices 

in those states should work with ARC, state officials, lending institutions, nonprofit 
161

counseling organizations, and other stakeholders to investigate credit needs and see if it is 

possible to increase SBA-guaranteed lending in minority counties and to minority-owned 

businesses. 

Increase SBA microloans to minority-owned businesses and SBA 504 lending in distressed 

counties, particularly to minority- and women-owned businesses. No SBA 504 loans were 

originated to women or minority-owned businesses in distressed counties, and, overall, 

distressed counties saw very low levels of 504 lending. In contrast, SBA microloans 

reached distressed counties but were not as successful in reaching minority-owned 

businesses in distressed counties. ARC should investigate possible barriers to 504 lending 

in distressed counties and access for minority-owned businesses to microloans in distressed 

counties. It is possible that lenders in distressed counties are unfamiliar with the 504 

product or are discouraged due to concerns about the length of underwriting or program 

fees. Also, if smaller banks in distressed counties are unable to make 504 loan deals, it 

may be necessary to recruit larger institutions to participate in these loans if demand exists. 

Financial Counseling and Technical Assistance for Small Businesses – Lending was higher 

in counties with higher portions of small businesses with the lowest risk credit scores. This 

suggests that lending will increase to small businesses overall if small businesses improved 

their credit scores. High quality financial counseling efforts are therefore important in 

Appalachia as a means to improve the credit scores of small businesses. In addition, 

technical assistance should be provided to improve the knowledge and skill level of the 

small business entrepreneurs regarding cash flow, understanding financials, business 

planning and taxation issues. ARC, state officials, lending institutions, and community 

organizations should work together to intensify financial counseling directed towards small 

businesses in Appalachia.

Better Understanding of Lending in Minority Counties in Appalachia – The report’s 

finding about higher levels of lending in counties with higher levels of minorities was a 

surprising and positive finding. Future research should be conducted to more fully 

understand why lending is unusually successful in reaching firms in counties with high 
162

levels of minorities in Appalachia. Lessons from this research should be applied to other 

regions of the country since the literature overall suggests serious barriers in access to 

small business lending for minority-owned firms. 
163

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Appendices