COMMUNITY REINVESTMENT ACT

ABOUT

The Community Reinvestment Act requires banks and other financial institutions to assist low- and moderate-income neighborhoods and individuals.  Federal financial institution regulators then assess the record of each bank in fulfilling its obligation to the community and then evaluate and rate each institution.  The High School to College Guide Foundation gives banks a unique and substantial vehicle to fulfill these requirements through education in a targeted & impactful way. 

The High School to College Guide Foundation is a 501(c)(3) non-profit foundation committed to providing high school students with a FREE High School to College Scholarship Guide; copyright TX 9-285-992.  The Guide empowers first-generation, at-risk, & underserved high school students with the foundation to qualify for college admission, scholarships, and grants.  Provided throughout all four years of high school for FREE in the online portal website, it will be accessible to students, parents, high school counselors, and administrators of nonmetropolitan communities, including being made available in multiple languages.

The High School to College Guide is an innovative, responsive, resource designed to improve college preparedness and admissions for low- and middle-income high school students.  The High School to College Guide Foundation meets the responsiveness evaluation of quantity, quality, and performance at a cost per impact of less than $1.00 per student.

The High School to College Guide Foundation will provide this much needed resource to millions of the most vulnerable high school students.  We would like to meet with you to gain your support and simultaneously fulfill your requirements of the CRA.

Criteria of the CRA

and how the Guide fulfills these criteria.

§12 CFR __.12(i) – 1: In addition to meeting the definition of community development in the regulation, community development services must also be related to the provision of financial services. What is meant by “provision of financial services”?  Answer 1. Providing financial services means providing services of the type generally provided by the financial services industry.  Providing financial services often involves informing community members about how to get or use credit or otherwise providing credit services or information to the community. . . financial planning or other financial services education. . . Establishing school savings programs or developing or teaching financial education or literacy curricula for low- or moderate-income individuals.

Here is a list of some of the topics covered in the High School to College Scholarship Guide: 

  • How to open and responsibly manage a Checking Account
  • Savings Account and Certificate of Deposit
  • What is a FICO Score
  • How to start building your credit
  • How to manage your credit profile
  • How to apply for the FAFSA college application 
  • 529 Plans, Coverdell, Custodial, and UGMA-UTMA Accounts
  • Student loans
  • Federal and State Financial Aid
  • How do Grants work
  • Sallie Mae
  • Self-Funding College
  • Bonds and Mutual Funds
  • Life Insurance & Annuities
  • Household budgeting advice and calculators
  • IRAs, 401(k)s and Retirement Plans

Per §12 CFR __.12(g) – 1: Are community development activities limited to those that promote economic development?  Answer 1: No.  Although the definition of “community development” includes activities that promote economic development. . . the rule does not limit community development loans and services and qualified investments to those activities. Community development also includes community- or tribal-based child care, educational, health, social services, or workforce development or job training programs targeted to low- or moderate-income persons. . . and activities that revitalize or stabilize low- or moderate-income areas, designated disaster areas, or underserved or distressed nonmetropolitan middle-income geographies.

The High School to College Guide Foundation will precisely target at-risk & impoverished students in high schools located in underserved or distressed nonmetropolitan middle-income geographies.  A few examples, the Guide will be provided to students and their families from a school at which the majority of students qualify for free or reduced-price meals under the U.S. Department of Agriculture’s National School Lunch Program.  To those eligible for Medicaid, tribal students, foster children, children of single parents, and incarcerated parents.  And other students and parents in eligible nonmetropolitan census tracts on the Federal Financial Institutions Examination Council (FFIEC) Web site (http://www.ffiec.gov).

§12 CFR __.12(g)(4)(iii) – 4: What activities are considered to revitalize or stabilize an underserved nonmetropolitan middle-income geography, and how are those activities evaluated? Answer 4. The regulation provides that activities revitalize or stabilize an underserved nonmetropolitan middle-income geography if they help to meet essential community needs, including the needs of low- or moderate-income individuals.  Activities, such as. . . education. . . of low- or moderate-income individuals. . . [of] a renovated elementary school that serves children from the community, including children from low- and moderate-income families.

§12 CFR __.12(t) – 5: Will an institution receive consideration for charitable contributions as “qualified investments? Answer 5. Yes, provided they have as their primary purpose community development as defined in the regulations. A charitable contribution, whether in cash or an in-kind contribution of property, is included in the term “grant.”

§12 CFR __.21–Performance tests, standards, and ratings, in general.

§12 CFR __.21(a) – 2: Are all community development activities weighted equally by examiners? Answer 2. No. Examiners will consider the responsiveness to credit and community development needs, as well as the innovativeness and complexity. . . [of] community development services. These criteria include consideration of the degree to which they serve as a catalyst for other community development activities. The criteria are designed to add a qualitative element to the evaluation of an institution’s performance.

§12 CFR __.21(a) – 3: “Responsiveness” to credit and community development needs is either a criterion or otherwise a consideration in all of the performance tests. How do examiners evaluate whether a financial institution has been “responsive” to credit and community development needs? Answer 3. There are three important factors that examiners consider when evaluating responsiveness: quantity, quality, and performance context.

https://www.fdic.gov/resources/supervision-and-examinations/consumer-compliance-examination-manual/documents/11/xi-12-1.pdf