Pub. 6 2016 Issue 3

women-owned financial institution will be considered as a favorable CRA activity regardless of the location of the minority-owned institution. 23 As the only activity that is not limited to the bank’s individual assessment area, certificates of deposit issued by minority- and women-owned financial insti- tutions can provide an easier venue to purchase CRA-eligible investments (depending upon their availability) versus other potential CRA investments that are bound by the geographic constraints of the assessment area. Conclusion CRA needs continue to drive activity related to both the lending and investment test. Within this article, we have at- tempted to highlight multiple investment options that can be incorporated into one’s CRA strategy to assist in satisfying pre-defined goals throughout the year. While not meant to be comprehensive, we hope this article both provided a refresher and brought to light some lesser known CRA investment alternatives. Please reach out to the Stifel Financial Institu- tion Strategies team or your Stifel representative to discuss further. w 1 Interagency Questions and Answers Regarding Community Reinvestment, FDIC CRA Compliance Manual, May 2014. 2 12 CFR §25.23(b) 3 12 CFR §25.23(e) 4 CRA Fact Sheet, Office of the Comptroller of the Currency, March 2014. 5 Interagency Questions and Answers Regarding Community Reinvestment, FDIC CRA Compliance Manual, May 2015. 6 Interagency Correspondence, OCC Community and Consumer Law Division, Michael S. Bylsma November, 20, 1997. 7 US Municipal Issuance, Securities Industry and Financial Markets Association, March, 10, 2016. 8 Supplemental Interagency Questions and Answers Regarding Community Reinvestment, FDIC CRA Compliance Manual, May 2015. 9 Public Disclosure- Community Reinvestment Act Performance Evaluation, Federal Reserve Bank of New York, March 2012. 10 Public Disclosure- Community Reinvestment Act Performance Evaluation, Office of the Comptroller of the Currency, June 2012. 11 Public Disclosure- Community Reinvestment Act Performance Evaluation, Federal Deposit Insurance Corporation, March 2013. 12 Interagency Questions and Answers Regarding Community Reinvestment, FDIC CRA Compliance Manual, May 2015. 13 Student Poverty FRPM Data, California Department of Education, 2015. 14 Digest of Education Statistics, National Center for Education Statistics, 2015. 15 American Recovery and Reinvestment Act of 2009 16 Interagency Questions and Answers Regarding Community Reinvestment, FDIC CRA Compliance Manual, May 2015. 17 26 U.S.C. § 143(f)(1) 18 About UHC, Utah Housing Corp 19 FAQs: Military Housing Privatization, Office of the Deputy Under Secretary of Defense Installations and Environment, http://www.acq.osd.mil/housing/ faqs.htm. 20 Community Investments (Vol 15, Issue 2), Federal Reserve Bank of San Francisco, August 2003. 21 Statistical Release: Minority-Owned Depository Institutions, Federal Reserve, December 31, 2015. 22 Interagency Questions and Answers Regarding Community Reinvestment, FDIC CRA Compliance Manual, May 2014. 23 Interagency Questions and Answers Regarding Community Reinvestment, FDIC CRA Compliance Manual, May 2014. CRA w Continued from page 17 4 Save The Date 18 www.azbankers.org