A bank loan through the State Small Business Credit Initiative may be eligible for Community Reinvestment Act (CRA) credit, according to a frequently asked questions (FAQ) document published Monday by the national bank regulator under the heading of CRA.
The Office of the Comptroller of the Currency (OCC) issued the FAQs via Bulletin 2024-1. The FAQs describe the SSBCI, a program administered by the Treasury Department to support lending in low- and moderate-income, minority, and other underserved communities, including women- and minority-owned small businesses.
The FAQs address aspects of the SSBCI, the types of areas or organizations that are the intended recipients of SSBCI-supported loans and investment, impact of SSBCI-associated guarantees or collateral on the risk weight of a participating bank’s exposures, and, more specifically, lending to and investment in tribal enterprises.
Specifically regarding the CRA, an answer to one of the FAQs notes that a loan made through the SSBCI may be eligible for CRA credit. “For additional information, please visit the OCC’s Community Reinvestment Act web page or contact the applicable OCC supervisory office,” it states.
Regarding OCC examiners’ focus on banks’ SSBCI lending programs, another answer states that examiners “will determine whether banks have established sound underwriting and risk management practices that are consistent with the bank’s overall strategic goals and objectives. As with all lending programs, examiners assess the adequacy of the bank’s risk management practices relative to the risks associated with the activity.”