Community Reinvestment Act

Pepper Hamilton LLP is experienced in helping banks, bank holding companies, and a wide range of other financial services businesses to comply with all regulatory requirements, including the Community Reinvestment Act (CRA). Our Financial Services Practice Group of 45+ lawyers includes veterans of federal and state regulatory agencies, as well as former general counsel of major financial institutions and nationally recognized members of the financial services bar. Pepper also has among the most prominent practices in the nation advising on Small Business Investment Companies (SBICs), including advising on qualified investments under the SBIC regulations. The firm’s leading national practice in affordable housing and community development, including advice related to Low Income Housing Tax Credit transactions and related CRA guidance, adds a unique dimension to Pepper’s capabilities in assisting clients with matters involving the CRA.

What We Do

Pepper’s services cover all aspects of CRA compliance. We advise depository institutions on their CRA policies and procedures, as well as their lending and investment activities under the CRA (and similar state laws in certain jurisdictions). We assist with training in CRA requirements (including advice related to the recent federal interagency FAQs on CRA compliance), and advise on the CRA requirements related to transactions such as bank mergers, acquisitions and dispositions. We counsel on examinations by federal regulatory agencies and respond to requests from regulators related to community reinvestment and other fair lending issues.

Investment in an SBIC is specifically identified in the CRA regulations as a type of investment that will be presumed by the regulatory agencies to be a “qualified investment” for CRA purposes. We advise financial institutions as well as SBIC funds on how bank investments become CRA qualified and counsel them on special limited partner agreement provisions dealing with CRA credit.

We advise on LIHTC transactions, including advising bank investors on evaluating investing, exiting, repositioning their investments in LIHTC deals, or other CRA qualified investments.

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