WASHINGTON - National banks that invest in community development banks have two chances to receive credit under the new Community Reinvestment Act rules, the Comptroller's office said in an interpretive letter released last month.
Under the lending test, if a bank contributed 10% of the capital of a community development bank, which then made $8 million in community development loans, the investing bank would get credit for $800,000 in loans.
Under the investment test, a bank would receive consideration only for its own investment and not for investments made by the community development bank, wrote Matthew Roberts, director of community and consumer law for the Office of the Comptroller of the Currency.
If a bank wanted credit under both tests, it would be able to count under the investment test only that portion of its investment not used to make loans. That is, if a bank invests $1 million, and loans make up 40% of the community development bank's assets, the investing bank could receive consideration for only 60% - $600,000 - of its investment.