EXPERIENCED COUNSEL

Community Reinvestment Act

Representative Engagements

  • advising a financial entity that operates a mutual fund providing qualified investment CRA credit to bank investors in regulatory compliance and related matters, including assistance with the federal interagency FAQs on CRA compliance
  • representing a trade association focused on SBIC investments regarding CRA issues
  • representing tax credit syndicators in developing an LIHTC deal structure to facilitate the likely awarding of CRA-qualified investment credit to bank limited partner investors, including side letters for allocation of CRA credits from the LIHTC structure in order to avoid double counting among investors, and other regulatory concerns
  • representing bank investors in LIHTC deals or other CRA-qualified investments
  • advising banks seeking to obtain CRA credit for CRA-oriented community and economic development lending in their market assessment area, or on a broader statewide/regional area
  • representing private developers, banks and public housing and nonprofit organizations meeting their community development goals by obtaining private investment through the LIHTC program. We have represented such groups in nearly every state, the District of Columbia, Puerto Rico and the U.S. Virgin Islands.
  • advising banks on state regulatory issues in the course of exams or in other circumstances related to state-level CRA requirements (certain states, such as Massachusetts and New York, have state-only CRA-type obligations)
  • representing a bank-sponsored entity that pools multiple bank investments to create a lending fund to make CRA-eligible housing project loans
  • advised a large nationally chartered bank in developing innovative lending and investment programs to meet CRA requirements.