Comptroller of the Currency Discusses Community Reinvestment Act and Small Business Lending

Remarks of Thomas J. Curry, Comptroller of the Currency before the 2015 State Small Business Credit Initiative Conference

May 12, 2015

Good morning and welcome to Constitution Center. This is the second year that the Office of the Comptroller of the Currency is hosting the annual SSBCI conference, and I’d like to welcome all of you, newcomers, as well as those who joined us last year.

The two things I find most intriguing about the State Small Business Credit Initiative, referred to as SSBCI, is that it was designed to leverage private capital, and it gave the states the flexibility to reinvigorate existing state small-business credit programs or to develop new ones. This has allowed you, as state program administrators, the flexibility to be creative and devise approaches that best meet local needs. And this approach has brought success; your programs have deployed over $1 billion in funding for small businesses.

This conference is a great opportunity to share experiences and explore new ways to expand small business lending. I understand this is the largest attendance yet for this gathering, and I’m sure you have a lot to discuss.

For those of you who are not familiar with the Office of the Comptroller of the Currency, the OCC is the primary regulator and supervisor of national banks and federal savings associations. The OCC supervises over 1,600 financial institutions with collective assets of $10.9 trillion or 71 percent of all the banking assets in the United States. Approximately 1,400 of these institutions are community banks with assets under $1 billion and community banks are the most active participants in the SSBCI.

The OCC is an independent bureau of the Department of the Treasury, and we work closely with Treasury to advance common policy objectives. Currently, we are collaborating with Treasury to help broaden banks’ awareness of the SSBCI program.

Soon after the Small Business Jobs Act creating SSBCI was enacted, the OCC developed a publication for bankers that identified the various opportunities the legislation presented to spur small business lending, including the SSBCI. We continued our efforts to expand awareness about this dynamic program with a 2013 report explaining how banks could participate in the SSBCI and providing case studies to illustrate how banks are successfully partnering with the agencies you represent to make loans to small businesses. The OCC and the FDIC also developed “Frequently Asked Questions,” that are posted in the Small Business Resource Directory on the Community Affairs page of the OCC’s Web site, occ.gov.

Understandably, some banks have voiced concern about how regulators would view loans made under programs, such as SSBCI, that otherwise might not meet the bank’s standard underwriting guidelines. The OCC has emphasized in our guidance that as long as a bank’s actions reflected a prudent, comprehensive review of a borrower’s financial condition, generally, the bank would not be subject to supervisory criticism for participating in an SSBCI program. The OCC also expects banks to ensure that their participation in the SSBCI or other federal small business programs is consistent with, and supports, their institution’s overall strategic goals and objectives.The OCC has been working with our colleagues at the Treasury Department to

The OCC has been working with our colleagues at the Treasury Department to encourage participation in the SSBCI by partnering with some of you in conducting banker outreach and training. Our examiners speak to their banks about small business and community development finance opportunities in the course of their supervisory activities. We also have a cadre of Community Affairs Officers who have participated in a number of banker outreach events sponsored by SSBCI program administrators. David Black, a member of the OCC’s Community Affairs team, will be participating in this conference, and I would encourage you to speak to David about any ideas you have for how our Community Affairs team can assist you.

Another way that the OCC supports banks’ involvement in small business programs is through our supervision of banks’ performance under the Community Reinvestment Act. CRA, which was enacted in 1977, directed the financial institution regulators to periodically evaluate how well a bank or thrift meets the credit needs of its community and assign a rating that reflects the institution’s performance.

A bank’s CRA rating is important both as a matter of public reputation and for a variety of business reasons. A bank’s record of CRA performance is considered as part of the corporate application process, so CRA ratings can affect banks that want to grow and expand their footprint. The SSBCI Frequently Asked Questions that I mentioned earlier include a discussion about how a bank’s or thrift’s SSBCI loans can be considered when examiners evaluate the bank’s CRA performance.

We also are continuing to enhance our CRA guidance regarding bank participation in small business finance programs. We had been hearing from bankers that the current guidance in the CRA Questions and Answers was deterring some types of economic development activity. One particular concern was that our current CRA guidance may inhibit banks from providing financing to Community Development Financial Institutions and other financial intermediaries that assist start-up businesses.

To address these concerns, in September 2014, the bank regulatory agencies proposed changes to the CRA guidance with respect to how we consider economic development when assessing certain small business loans and investments. The proposed changes would add more detail and provide additional examples of activities that “promote economic development.” The proposal also would add loans to or investments in CDFIs that finance small businesses or small farms to the list of activities that are presumed to support economic development. It is our goal that, once finalized, this CRA guidance will encourage banks to engage in more economic development activities that strengthen small businesses.

Banks can also receive CRA consideration under the Service Test for providing small businesses with technical assistance on financial matters. At times, a bank may not initially be able to approve a loan for a small business applicant. Nonetheless, a bank can receive CRA consideration for providing technical assistance directly to a small business owner or for providing financial support to a partner that will help the small business owner improve business operations to become more bankable.

Instead of simply saying “No,” a bank can help a small business owner improve the chances of getting to “Yes.” After receiving technical assistance, the small business owner can be referred back to the bank, or to a financial intermediary, such as a CDFI, or to another bank that is participating in SSBCI for financing.

Last week was National Small Business Week, and I want to take this opportunity to recognize the crucial role that small businesses play in creating jobs and stimulating the health of our economy. Small businesses rely heavily on large and regional financial institutions for their credit needs, but community banks also play a very significant role in providing small business credit. Even though community banks hold just 8 percent of the assets of the banking industry, according to the Independent Community Bankers Association smaller community banks with less than $1 billion in assets made one-third of outstanding bank loans to small businesses. Mid-size community banks with less than $10 billion in assets made another 18 percent of outstanding bank loans to small businesses.

Moreover, several Federal Reserve banks recently conducted a joint survey of small business credit, and they found that approval rates at small regional or community banks were significantly higher, particularly for growing small business firms, than approval rates at larger banks. Throughout the country, community banks help small businesses thrive by offering personalized service and credit products tailored to their customers’ needs, and these smaller institutions have been important partners in the success of your SSBCI programs.

CDFIs also are important players in underserved markets and often target market segments that banking institutions may not be able to serve. Frequently, CDFIs have strong business relationships with banks. Small business customers benefit when a bank refers them to a CDFI for a loan, or when a CDFI helps a small business owner improve its operations and creditworthiness. In turn, that may enable a bank to approve a loan to that business. I’m very pleased to see that the SSBCI programs are working so successfully with community banks and CDFIs.

In closing, I want to applaud your continuing efforts to develop your states’ SSBCI programs. The SSBCI program has been particularly effective because it focuses on results. SSBCI has supported over 12,000 transactions and for every $1 in federal funding, $7.40 has been generated in private lending or investment. Because the funding stays with your programs, these amounts will continue to grow and be recycled to support more transactions in the months and years to come.

I wish everyone success in your discussions over the next two days. Thank you for inviting me to join you today, and I hope you have a great conference.


Financial Strategies for Small Business – Lunch and Learn

Opportunities to finance small business start-ups and expansions are improving as the economy improves.

Register today to attend and  learn about available financial strategies for starting and/or expanding your small business.

 

Date: March 25th

Time: 11:30 a.m. – 1:00 p.m.

Location: Southeastern Technical College’s Economic Development Center (100A Brinson Rd; Vidalia)

 

A light lunch will be provided. Pre-registration is required. Seating is limited. To reserve a seat, contact David Yarbrough:

912-538-3119 or dyarbrough@southeasterntech.edu


SBAC St. Patrick’s Day Open House

A shamrock will bring luck your way… especially if you stop in to see us on St. Paddy’s Day. Join us for a wee bit o’ malarkey and lots of Irish coffee.
Watch the parade from our office. Enjoy free food and fun for the entire family.
SBAC’s
St. Patrick’s Day Open House
Tuesday, March 17
8AM -2PM
Date: Tuesday, March 17
Time: 8:00 AM- 2:00 PM
Location: 111 E. Liberty Street, Suite 100
Savannah, Georgia 31401
Phone:912-232-4700
For more information, contact LeAndrea Mikell. lmikell@sbacsav.com

 


SBAC Welcomes Victoria Burch as Staff Accountant

Victoria Burch

(Savannah, GA) The Small Business Assistance Corporation is excited to welcome Victoria Burch as Staff Accountant. Her duties include maintaining financial records, preparing financial statements, preparing managerial and financial reports, reconciling bank statements and assisting with development and monitoring of budgets.

“I am excited to be an addition to the SBAC team. I look forward to assisting in the continuation of the organization’s mission of economic development as it continues to finance the goals of individuals and businesses in the community,” said Burch.

Ms. Burch has many years of experience in working with accounting functions, and she also has experience with non-profit organizations. Ms. Burch currently works with the Coastal Children’s Advocacy Center.

A native of Augusta, Victoria has a Bachelor’s degree in Accounting from Savannah State University and a Master’s Degree in Accounting (MACC) from Georgia Southern University. She can be reached at vburch@sbacsav.com

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About SBAC: Small Business Assistance Corporation (SBAC) is a community financial development institution (CDFI) as well as a certified development company (CDC). SBAC is authorized to provide business financing an assistance services by the City of Savannah, the Small Business Administration (SBA), the state of Georgia’s Department of Community Affairs, and the United States Department of Agriculture (USDA). For more information, visit http://www.SBACSAV.com or call 912.232.4700.


Welcome Back Brady Cannon

SBAC Welcomes Brady Cannon as

Community Development Lending Officer

Brady Cannon

Brady Cannon

(Savannah, GA) The Small Business Assistance Corporation is pleased to announce that Brady Cannon has joined SBAC as the Community Development Lending Officer. In his new role, he will be responsible for marketing community development loans to potential borrowers, third party lenders and other referral sources. The primary responsibility of this job is to develop and originate new small business loans and promote economic development.

“We are excited to have Brady Cannon join the SBAC team of business lenders,” said Tony O’Reilly, SBAC President. “He is a great fit, both in lending skills, and commitment to our Community Development Financial Institution (CDFI) mission.

Brady served in the United States Peace Corps as an Agricultural and Rural Business Consultant in the Republic of Moldova for over two years. After the Peace Corps, he worked with the Small Business Assistance Corporation as a Micro-business Finance Associate. In 2011, Brady joined Technology Association of Georgia (TAG) as Director.

“I am excited to join such a well respected organization with decades of experience fueling economic development across Savannah and southeast Georgia through its small business lending programs,” said Cannon.

A native Savannah, Brady has a degree in economics from the University of Georgia’s Terry College of Business. He can be reached at bcannon@sbacsav.com.

 

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About SBAC: Small Business Assistance Corporation (SBAC) is a community financial development institution (CDFI) as well as a certified development company (CDC). SBAC is authorized to provide business financing an assistance services by the City of Savannah, the Small Business Administration (SBA), the state of Georgia’s Department of Community Affairs, and the United States Department of Agriculture (USDA).


SBAC Holiday Hours

The Small Business Resource Center will close Wednesday, December 31, 2014 at 12pm. We will reopen Monday, January 5, 2015 at 8am.


SBAC 23rd Annual Luncheon & Awards Ceremony

Jenny Dent of Visit Savannah (T McCoy Cornerstone Award), Adam Turoni of Chocolat’ By Adam (Micro entrepreneur of the Year), Mark and Trudy Sauer of Savannah Global Solutions, LLC (Michael Bunn Sr. Rising Star Award)

Jenny Dent of Visit Savannah (T McCoy Cornerstone Award), Adam Turoni of Chocolat’ By Adam (Micro entrepreneur of the Year), Mark and Trudy Sauer of Savannah Global Solutions, LLC (Michael Bunn Sr. Rising Star Award)

 

SAVANNAH, GA December 3, 2014– The Small Business Assistance Corporation (SBAC) hosted its 23rd Annual Luncheon and Awards ceremony today at Savannah Station. Guests enjoyed food and live entertainment as the SBAC recognized Ameris Bank as the Small Business Lending Unit of the Year. This last fiscal year, SBAC and Ameris’ commercial lending department funded loans totaling $1,729,780 for projects that totaled $2,981,100; most notable is the project for Sorry Charleys, a previously blighted property facing Ellis Square in Historic Downtown Savannah.

 The Micro entrepreneur of the Year award was presented to Adam Turoni of Chocolat’ by Adam and the T McCoy Cornerstone Award recipient was Jenny Dent of Visit Savannah. This award is given to a person achieving the highest level of excellence as an Administrative Professional. “We love to take this time to honor those who have personified values we share” said Tony O’Reilly, SBAC President.

The Michael Bunn, Sr. Rising Star Small Business of the Year was awarded to Mark and Trudy Sauer of Savannah Global Solutions, LLC.  “As small business owners, time is always in short supply.  There is no way we would have had the energy and in-house expertise to pull together all of the information needed to apply for an SBA loan without the hand-holding provided by the patient and knowledgeable staff of the SBAC in Savannah.  They walked us through the process, deciphered the requirements, and working hand in hand with SunTrust, helped us present our paperwork in the manner that is preferred by the SBA when reviewing requests for funding.  It was definitely a positive experience for us!  The SBAC in Savannah is truly a tremendous resource for small business” said Trudy Sauer.

Savannah Global Solutions, LLC markets and manufactures mechanical and chemical site preparation equipment used to forest and reforest commercial timber plantations, prepares sites for bio-fuel crops such as sugar cane, and converts native land and cut-over timber land back to crop land. The use of this highly sophisticated soil preparation equipment results in better survival and growth of trees and crops in very rugged soil conditions.

Savannah Global Solutions secured a loan for the purchase, modification and improvement of a commercial building. SBAC Partnered with Gabe Thomas and Carol Coppola of SunTrust Bank on the project totaling $1.7MM.

 Retiring member of the board, Jennifer Sawyer was also honored for her service.

 

About the SBAC

The SBAC, located at 111 E. Liberty, Suite 100 in Savannah, is a specialized, non-profit business development organization licensed by the U. S. Small Business Administration and supported by the City of Savannah and the U. S. Department of Housing and Urban Development to promote economic growth.  Since 1989 the SBAC has been offering loan products in the City of Savannah, southeast Georgia and Low Country of South Carolina.

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If you would like more information on the Small Business Assistance Corporation, please contact us at 912-232-4700 or visit online at www.sbacsav.com. The SBAC is an equal opportunity lender, provider and employer.


Small Business Assistance Corporation Donates to the USO on its 73rd Birthday

Tony O'Reilly (SBAC President) and LeAndrea Mikell (Communications/PR) present donation to USO Chairman and volunteer coordinator.

Tony O’Reilly (SBAC President) and LeAndrea Mikell (Communications/PR) present donation to USO Chairman and volunteer coordinator.

Savannah, GA—The SBAC celebrated with the USO at its 73rd birthday celebration by donating to the local chapter. The SBAC collected $1,243.00 in monetary donations through its Lenders’ League networking group. Supplies were dropped off by members of the local community. SBAC President, Tony O’Reilly, was on hand to meet with volunteers of the USO and others as they celebrated over seven decades in existence as a national organization. “We are pleased that the USO allowed us to help in their mission. It’s an honor to meet with the individuals that selflessly give of their time and have such an impact in our local and national community.”

The USO provides support for our area’s troops and their families. There are nearly 200 volunteers supporting the USO operations at the Savannah Airport and Hunter Army Air Field. “It’s our honor to help the USO. We couldn’t think of a better group,” stated SBAC Vice President, Stephen George. The USO was chosen as the SBAC’s charity of choice for 2013, and the organization began collecting donations in October through its Lenders’ League networking group and from the local community.

About the SBAC: The SBAC is a specialized, non-profit business development organization licensed by the U.S. Small Business Administration and supported by the City of Savannah, the U. S. Department of Housing and Urban Development and the U.S. Department of Agriculture to promote economic growth.  Since 1989 the SBAC has been offering loan products in the City of Savannah, Southeast Georgia and Low Country of South Carolina.

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For additional information, contact the SBAC at 912-232-4700, or visit online at www.sbacsav.com .


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The Small Business Assistance Corporation Hosts Annual Luncheon and Awards Ceremony

Dr. H. Cribe of the Telfair Medical Center

Dr. H. Cribe of the Telfair Medical Center

SAVANNAH, GA– The Small Business Assistance Corporation hosted its Annual Luncheon and Awards ceremony at Savannah Station. Guests enjoyed food and live entertainment from the Armstrong Atlantic State University Chorus as the SBAC recognized the Small Business Lender of the Year, the Michael Bunn, Sr. Rising Star Small Business of The Year and the T McCoy Cornerstone Award to a person achieving the highest level of excellence as an Administrative Professional. “We love to take this time to honor those who have personified values we share” said Tony O’Reilly.

 

The SBAC awarded the 2013 Rising Star Award in honor of Michael Bunn, Sr. to the Telfair Medical Center owned by Doctor Habigaile Cribe. The Rising Star is SBAC’s small business of the year for highest achievement in entrepreneurial success and community service. Ryan Martin of Sea Island Bank was chosen as the SBAC’s Lender of the year for 2013 and Ms. Gloria Pace of SCAD was awarded the T McCoy Cornerstone Award. Retiring members of the board, Larry Blige, Patrece Grant and Linda Jaeger were also honored for their service. Tom Butler, who served as chairman also retired.   

 

About the SBAC

The SBAC, located at 111 E. Liberty, Suite 100 in Savannah, is a specialized, non-profit business development organization licensed by the U. S. Small Business Administration and supported by the City of Savannah and the U. S. Department of Housing and Urban Development to promote economic growth.  Since 1989 the SBAC has been offering loan products in the City of Savannah, southeast Georgia and Low Country of South Carolina.

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If you would like more information on the Small Business Assistance Corporation, please contact us at 912-232-4700 or visit online at www.sbacsav.com. The SBAC is an equal opportunity lender, provider and employer.