The Bar Association, with the bank's grant, will operate a program to amass an inventory of vacant apartments that property owners will make available to individuals in need at initially lower rents and generally without any deposit. These properties generally will be used as transitional residences with a duration of six months to a year. The bank's grant will enable the Bar Association to dedicate a full-time employee to establish and coordinate the program. Assuming that the program proves successful, the bank's commitment to the program will likely be ongoing. Consideration under the CRA You have indicated that your bank will be evaluated under the lending, investment and service tests of the new CRA regulations.
Examiners consider large institutions' qualified investments under the investment test.
Qualified investments may also be considered to determine if a small institution merits an outstanding CRA rating. See 12 C.F.R. pt. The community development test, which is appropriate for wholesale and limited purpose institutions, evaluates, inter alia , the number and amount of qualified investments. Therefore, examiners will give positive consideration as a qualified investment to such a grant. I trust this letter has been responsive to your inquiry.