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					Section 1: A View of the Landscape

A Look Inside ...
Barry Wides, Deputy Comptroller for Community Affairs, Office of the Comptroller of the Currency (OCC)



T
       he recovery effort in the Gulf         For businesses, the Gulf Opportunity
       Coast from the 2005 hurricanes         (GO) Zone Act of 2005 allows a
       is now entering its fourth             bonus depreciation tax deduction
year. Hurricanes Katrina, Rita, and           for property placed in service
Wilma created the greatest physical           before December 31, 2010. HERA
and economic destruction the United           eliminates a requirement that
States has ever experienced from              construction of these properties
a natural disaster. The response at           start by December 31, 2007. The
the local, state, and national levels,        date change ensures that more
                                                                                                                                                   Holy Cross School
by necessity, involved a great deal           Gulf Coast properties will qualify
                                                                                             Rendering of the new campus of the Holy
of experimentation, as there had              for this bonus depreciation.                   Cross School in New Orleans, which lost its
previously been no similar experience                                                        historic campus to Hurricane Katrina. Banks
                                              Though not specifically targeting the
from which to draw lessons.                                                                  have invested in support of its rebuilding.
                                              Gulf Coast, the increased allocation
                                                                                             (See articles on Capital One (page 13) and
The past three years have included a          of low-income housing tax credits
                                                                                             Whitney National Bank (page 16) for
broad array of initiatives, investments,      (LIHTC) to states will boost the               more details.)
policies, and programs from public,           amount of affordable housing
private, and philanthropic sector actors.     created for lower-income households           As a result of HERA’s enactment, the
This issue of Community Developments          in the Gulf Coast. Additionally,              federal government will put additional
examines some of these initiatives            HERA creates a new type of “high-             resources in the hands of the families
through the vantage point of some of          cost area” for the LIHTC program,             and individuals who live and work
the primary organizations involved            wherein a state credit allocating             in the Gulf Coast and in the hands
in the recovery effort—specifically,          agency can designate specific                 of businesses that help Gulf Coast
national banks, government agencies,          projects to receive extra tax credits         communities thrive. We look forward
and their development partners.               due to their high development costs.          to seeing these resources at work.
Working at their best, national and           Projects so designated would then
                                                                                            As you read the articles in this
regional actors channel resources to          qualify for tax credits of 130 percent
                                                                                            newsletter, we hope you will find
local organizations that understand           of their qualifying basis instead of
                                                                                            the experiences of banks, nonprofit
how to distribute resources to support        the usual 100 percent. This provision
                                                                                            organizations, state agencies,
local recovery. We see this strategy          will improve the financial feasibility
                                                                                            and businesses useful as your
at work in the federal government’s           for LIHTC projects receiving this
                                                                                            bank considers its own support
special allocation of Community               designation in the Gulf Coast.
                                                                                            for the Gulf Coast recovery.
Development Block Grant (CDBG)                HERA restores the authority for
funds to the state government and             banks to make affordable housing              Cover photo credits, clockwise from top left: NeighborWorks
                                                                                            America, NeighborWorks America, Enterprise Community
then down to local communities to             and community development                     Partners, NeighborWorks America.
help renovate and rebuild the housing         investments under the public welfare
stock and public infrastructure. We           investment authority in 12 USC
                                                                                                   Community Developments
see it in the small business loan funds       24 (Eleventh) (Part 24) in a mix
                                                                                                             Deputy Comptroller
established by state governments,             of low-, moderate-, and middle-                                    Barry Wides
national and local nonprofit                  income communities. This enables                   Editorial Staff             Design Staff
organizations, and foundations to             banks to make Part 24 investments                  Beth Castro                 Victor Battista
                                                                                                 Bill Reeves                 Cheryle Robison
support small business recovery.              in distressed middle-income areas                  Kristopher Rengert

The recently passed Housing and               of the GO Zone without needing                     Lily Chin
                                                                                                 Morey Rothberg
Economic Recovery Act of 2008                 to demonstrate that the benefits
                                                                                                    Questions or comments, please phone (202) 874-5556.
(HERA) includes several provisions            will flow primarily to low- and
                                                                                                   This and previous editions are available on our Web site:

that will have a special impact in the        moderate-income people.                                       www.occ.treas.gov/cdd/resource.htm.
                                                                                                                         Disclaimer
Gulf Coast, increasing the resources                                                                Articles by non-OCC authors represent their own views
                                                                                                           and not necessarily the views of the OCC.
available at the local level.


2                                                                                                        Community Developments
                                                                                 Section 1: A View of the Landscape

Community Redevelopment in the Gulf Coast:
How Banks Are Supporting Recovery
John C. Dugan, Comptroller of the Currency



T
       hree years after Hurricane            neighborhoods in the wake of Katrina
       Katrina devastated New Orleans        and Rita. Inevitably, less attention
       and the Gulf Coast – and while        has been paid to the success stories
assessments of the damage from               – the many instances in which
hurricanes Gustav, Ike, and this year’s      banks, community development
hurricane season are still under way –       organizations, entrepreneurs, and
three words strike me as the essential       government entities have worked
keys to long-term regional recovery:         together to get recovery projects
patience, perseverance, and partnering.      funded and to move them from the
Inevitably, disasters of such magnitude      drawing boards to fruition. But if we
create challenges that are more              want to create a climate that supports
complex and difficult to address than        sustainable long-term recovery, it’s
anyone could anticipate. Thus the            vitally important to hear these stories
compelling need for patience – even          and learn how such partnerships are
though, as time goes on, patience can        working. That’s what this issue of
wear thin and is never inexhaustible.        Community Developments is all about.

As for perseverance, it’s obvious            Disaster and Response
to anyone who has been on the
                                             When Katrina struck the Gulf Coast in
scene, whether as a long-term                                                            Lessons Learned from
                                             August 2005, it became the costliest
resident or short-term visitor, that
                                             natural disaster in U.S. history,             Hurricane Katrina
the recovery process will continue
                                             destroying or damaging millions of


                                                                                          I
for many years – during which those                                                          n 2006, the OCC and other
                                             homes and businesses and leaving in
committed to recovery will have                                                              member agencies of the Federal
                                             its wake the greatest displacement of
to overcome countless obstacles,                                                             Financial Institutions Examination
                                             people since dust storms covered the
from uncertain housing market                                                             Council and the Conference of
                                             Great Plains in the 1930s. And Katrina       State Bank Supervisors published
conditions to rising insurance costs.
                                             was followed by Rita. Then Wilma             Lessons Learned From Hurricane
And that brings me to the compelling         struck Florida.                              Katrina: Preparing Your Institution for
need for partnering. A vast natural                                                       a Catastrophic Event. The publication
                                             Ultimately, these storms displaced
disaster demonstrates, beyond                                                             describes financial institutions’
                                             more than 750,000 people, disrupted at       experiences and lessons learned in
dispute, that no one can go it alone.
                                             least 125,000 businesses, and damaged        the aftermath of Hurricane Katrina
No individual or group of citizens,
                                             over 1.2 million housing units, with         that other institutions may find helpful
no government entity, no financial
                                             more than 300,000 totally destroyed or       in considering their readiness for a
institution has all the resources needed                                                  catastrophic event.
                                             severely damaged (see table on page
to restore a great city and revitalize
                                             12 for housing damage estimates).            This report is at www.fdic.gov/regulations/
an entire region. Everyone has to                                                         resources/lessons/index.html.
                                             To a great extent, the storms were
find ways to work together – pooling
                                             equal-opportunity calamities, afflicting
resources, sharing expertise, cutting
                                             affluent as well as low- and moderate-
red tape, finding creative ways to
                                             income communities and destroying          I visited with area families and business
remove barriers to progress.
                                             large as well as small businesses.         owners and saw first-hand the appalling
There has been ample media coverage          Together they created the most urgent      damage to their homes, businesses,
of the obstacles encountered by              and extensive need for community           and communities. It was clear that the
Gulf Coast residents and institutions        development investment in the modern       recovery effort would require massive
trying to rebuild livelihoods and            banking era.                               resources and many years of work, and
                                                                                        that banks would play a key role.



Fall 2008                                                                                                                               3
Section 1: A View of the Landscape
Three years later we can see                  lawmakers and regulators to channel        facilities. Areas experiencing
considerable evidence of progress –           more funding resources to the region       substantial in-migration also faced a
while harboring no illusions about the        by having it designated it as the Gulf     severe need to develop new housing
challenges that still lie ahead. Those        Opportunity (GO) Zone. Areas in            and community facilities. East Baton
challenges have been magnified by this        the GO Zone include those directly         Rouge Parish, for example, suddenly
year’s hurricane season, even though          affected by storm and flooding damage      gained some 19,000 storm-displaced
the damage has not been on the same           from the hurricanes as well as those       residents, and other communities found
scale.                                        affected by the movement of residents      themselves similarly stressed.
In the immediate aftermath of the 2005        from the directly impacted areas to        National banks are addressing these
storms, banks helped to avert additional      surrounding areas.                         needs. For example:
disasters, both personal and regional,        High on the critical list was the need     •   Banks are partnering with local
by working with borrowers needing             to replace structures that had been            nonprofit organizations to support
to postpone mortgage and other credit         destroyed and to renovate damaged              the rehabilitation and reconstruction
payments. They also worked with               housing, businesses, and community             of single-family homes. Banks
                                                                                             provide financing; the nonprofits
        $1 Billion Gulf Coast Rebuilding Challenge                                           provide construction management
                                                                                             and financial counseling for
            Channels Capital into Gulf Region
                                                                                             homeowners.


    T
           he $1 Billion Gulf Coast           With CDARS, a bank that belongs to
           Rebuilding Challenge (the          the Promontory Network can offer a
                                                                                         •   Banks are supporting small business
           Challenge) channels capital in     depositor access to up to $50 million          recovery and efforts to establish
    the form of deposits from America’s       in FDIC coverage. Through CDARS,               new businesses. In one partnership
    large corporations to local community     the community bank places the funds            with local government and a
    banks participating in the Certificate    in FDIC-insured CDs issued by multiple         nonprofit community development
    of Deposit Account Registry Service,      banks, making the deposits eligible            financial institution (CDFI), several
    or CDARS.                                 for FDIC insurance for up to $50               banks are supporting the Baton
    By simply depositing funds in Federal
                                              million. The community bank receives           Rouge Small Business Loan Fund,
    Deposit Insurance Corporation
                                              matching deposits from other banks,            providing flexible financing for
                                              making the full amount available for           start-up or operating capital and
    (FDIC)-insured, interest-bearing
                                              Gulf Coast area lending.                       targeting women and minority
    certificates of deposit (CD),
    corporations and other depositors         To receive deposits through the                entrepreneurs.
    are helping to rebuild the region.        Challenge, a bank must have less
                                                                                         •   Congress provided supplemental
    These corporations include Bank of        than $500 million in assets, be located
                                                                                             New Markets Tax Credit (NMTC)
    America, Fannie Mae, First American,      in areas affected by the storms as
                                                                                             allocations for the GO Zone, with a
    General Motors, the Home Depot,           designated by the Gulf Opportunity
    and Microsoft.                            Zone Act, and be a member of the
                                                                                             major share going to banks. Banks
                                              Promontory Network.
                                                                                             are using their NMTC investments
    The Challenge was announced                                                              to support businesses, schools, and
    in November 2006. Thirty-five             Alden J. McDonald Jr., President
                                                                                             other community facilities.
    community banks in the storm-             and Chief Executive Officer of the
    damaged region are currently eligible     New Orleans-based Liberty Bank             •   Housing developers – including
    to receive deposits. Corporate            & Trust, a participating community             for-profit and nonprofit entities,
    participants pledge to deposit            bank, summed up the purpose of the             established national entities, and
    $1 million to $5 million for five         Challenge: “Get us the money to do             local start-ups – have used the
    years through an eligible Gulf area       our jobs and we’ll help get people             expanded Low-Income Housing
    community bank, though some               back on their feet.”                           Tax Credit (LIHTC) program in the
    participants have deposited much          For more information, contact                  GO Zone to rehabilitate, replace,
    more than $5 million.                     Phil Battey at (703) 292-3357 or               and create affordable multifamily
    The funds are placed in CDs using         pbattey@promnetwork.com. You may also          housing, creating opportunities for
    the CDARS service, which makes the        contact Brian Christie at (703) 292-3456       bank investments in the process.
    full amount of the deposit eligible for
                                              or bchristie@promnetwork.com.
    FDIC insurance.




4                                                                                                Community Developments
                                                                                           Section 1: A View of the Landscape
•   Banks are investing in regional               CRA consideration for activities                 in the 2008 Housing and Economic
    funds supporting the reconstruction           supporting recovery has recently                 Recovery Act (HERA). This change
    and creation of new, affordable               been extended from 2008 to 2011                  facilitates national bank direct public
    housing. Several banks have                   (see OCC Bulletin 2008-24).                      welfare investments, such as affordable
    invested in the Louisiana Loan                                                                 housing, in areas of the GO Zone that
                                           •      Additional bank support will
    Fund, a public/private partnership                                                             were not defined as low- and moderate-
                                                  be needed to help communities
    managed by the Local Initiatives                                                               income in the 2000 Census. (See “A
                                                  impacted by this year’s hurricanes
    Support Corporation and Enterprise                                                             Look Inside ... ” on page 2 for more
                                                  Gustav and Ike, and potentially
    Community Partners. The fund                                                                   details on other HERA changes).
                                                  by other storms. CRA credit is
    provides much-needed acquisition
                                                  available for bank activities in
    and predevelopment financing for
                                                  support of recovery efforts to                   Looking Forward
    affordable housing developers in
                                                  revitalize and stabilize federally               Three years after the storms of 2005,
    Louisiana’s GO Zone.                                                                           national banks and their partners are
                                                  designated disaster areas for three
                                                  years after the designation has been             providing much of the financial fuel
The OCC’s Support                                 made. To determine which counties                and technical support needed to help
In 2005, we created a new position                have been designated and when,                   bring back Gulf Coast communities.
to serve as our Gulf Coast liaison – a            banks should review the Federal                  As you’ll learn from the articles in this
District Community Affairs Officer                Emergency Management Agency                      issue, those three key words – patience,
(DCAO) based in the region helping                Designated Disaster Areas listing at             perseverance, and partnering – are hard
to organize working groups of banks,              www.fema.gov/news/disasters.fema.                at work in a striking variety of ways.
local government officials, and leaders                                                            But there’s much more to be done.
from business and nonprofit sectors.                It was clear that the                          For years to come, innovative
                                                   recovery effort would                           and resourceful bank lending and
Federal regulators, including the                                                                  investments can help shore up
OCC, reinforced the importance of                require massive resources
                                                                                                   infrastructure, rebuild businesses,
banks’ roles in supporting recovery.              and many years of work,                          and provide affordable homes for
The Compliance Corner article on
                                                 and that banks would play                         people impacted by the Gulf Coast
page 29 describes how the definition                                                               storms. These are not just good
of community development in the                          a key role.
                                                                                                   works: it can be good business for
rules implementing the Community           To help maximize the impact of                          banks. The challenges and economic
Reinvestment Act (CRA) was amended         bank investments in affected areas,                     opportunities presented by the Gulf
to include support for recovery efforts    the OCC worked with congressional                       Coast offer a variety of ways for
in a federally declared disaster. Other    leaders to restore banks’ public                        bankers to spur development and
regulatory changes have increased the      welfare investment authority to                         economic revitalization and grow
level of CRA consideration that banks      include distressed middle-income                        their business in ways that are both
may receive for supporting recovery.       census tracts, and this was included                    sound and constructive.
For example:
•   The 2006 CRA Q&As explain that                                       Contacts for Key Organizations
    activities will be considered to                                      Mentioned in This Newsletter
    revitalize or stabilize a designated       Organization                                       Contact               Phone Number
    disaster area if they are recovery-        Federal Deposit Insurance Corporation              Kevin Williams        (225) 201-1717 x6725
    related and help attract or retain         Federal Reserve System                             Nancy Montoya         (504) 593-3256
    businesses or residents.                   Office of the Comptroller of the Currency          Scarlett Duplechain   (504) 828-6555
                                               Office of Thrift Supervision                       Aaron Satterthwaite   (972) 277-9569
•   OCC Bulletin 2006-6 explains
                                               Fannie Mae                                         Tim Carpenter         (985) 249-7392
    how national banks located outside
                                               Freddie Mac                                        Nancy Gresham-Jones   (770) 857-8860
    designated disaster areas may
                                               Enterprise Community Partners                      Michelle Whetten      (504) 821-7242
    receive positive CRA consideration
                                               Local Initiatives Support Corporation              Evelyn Brown          (212) 455-9800
    for activities supporting recovery.
                                               NeighborWorks America                              Tom Deyo              (202) 220-2301
•   The time period for which                  Federal Emergency Management Agency                Cindy Taylor          (202) 646-4600
    banks may receive positive                 U.S. Department of Housing and Urban Development   Brian Sullivan        (202) 402-7527



Fall 2008                                                                                                                                      5
Section 1: A View of the Landscape

Louisiana Recovery Authority Looks to Match
Investments to the Right Recovery Opportunities
Paul Rainwater, Executive Director, Louisiana Recovery Authority




T
        he Louisiana Recovery                 entrepreneurship that
        Authority (LRA) is the state’s        are ultimately key
        planning and coordinating             to our recovery.
body established in the aftermath             We have dedicated
of hurricanes Katrina and Rita to             more than
lead Louisiana’s recovery efforts.            $11.5 billion to support
Our board of directors includes               homeowners in their
business, civic, and political leaders,       rebuilding efforts and
including representatives from                to increase the supply
the many industries that form the             of affordable rental
backbone of Louisiana’s economy.              housing, approximately
Our mission is to ensure that                 $300 million to
Louisiana rebuilds safer, stronger, and       support small                                                                      Marvin Nauman/FEMA
smarter than before. In pursuing this         business recovery and         New Orleans youth share their ideas for how they would like to see
mission, the LRA initially focused            $700 million for our          their community rebuilt during the LRA’s “Collecting the Voices”
on policy development and planning            local governments to          effort part of Louisiana Recovery Planning Day in January, 2006.
activities and now has power and              jump-start long-term
oversight over the implementation             recovery projects indentified in                   program that provided gap financing
of the programs it helped create.             the early days after the storms.                   for more than 370 affected small
                                              Much of these funds has already                    businesses as it waited for Small
We oversee and distribute billions of                                                            Business Administration (SBA) loans
                                              been put to work in communities,
dollars in federal and state investments                                                         or insurance proceeds. Shortly after
                                              where they are invested alongside
in the recovery effort and ensure that                                                           receiving federal recovery funds, the
                                              more than $3.5 billion in federal
these public investments leverage                                                                state added another $45 million into
                                              funds dedicated through the Federal
additional ones from financial                                                                   this program. This first phase of the
                                              Emergency Management Agency
institutions, businesses, and individuals.                                                       bridge loan program provided short-
                                              (FEMA) for important infrastructure
Currently, we are focused on                  repairs, including repairing schools,              term (up to 180 days) lump sum loans
streamlining our processes, eliminating       health care facilities, and governmental           between $5,000 and $25,000 with zero
any barriers preventing homeowners,           structures. We expect to invest                    or four percent interest rates, depending
businesses, and governments from              billions more in the coming years.                 on the situation of the borrower.
rebuilding, and helping them access                                                              The state invested $35 million into
                                              2008 has been an important year for
the resources they need. While our                                                               phase two, which offered short-term
                                              us. We have focused our efforts on
organizational goals are changing                                                                (up to 180 days) lump sum loans that
                                              removing hurdles from rebuilding,
as Louisiana’s recovery progresses,                                                              either carried a 6.5 percent interest rate
                                              even as we have continued to gather
our objectives and strategies through                                                            or were interest free. The minimum
                                              resources to support the recovery
2009 are formally laid out in our                                                                loan amount for this phase was $5,000,
                                              effort. As we see it, the LRA works not
strategic plan, which can be found at                                                            and the maximum was $100,000.
                                              only to enhance Louisiana’s recovery
http://lra.louisiana.gov/assets/docs/
                                              but also the state’s image as a place                Loan proceeds could be used only
searchable/StrategicPlan0809.pdf.
                                              to live, to work, and to invest—three                to maintain or restart a business in
Louisiana is now three years into a           essential components of a healthy state.             a designated area or in a temporary
rebuilding process that will likely last                                                           location in one of the qualifying
for years, because public investments         Small Business Investments                           parishes that sustained damage or
in the initial stages lay the foundation      Immediately following the storms, the                interruption of operations from
for the private investment and                state put $10 million in state funds                 hurricanes Katrina or Rita. Banks
                                              into a Small Business Bridge Loan                    were essential partners with the


6                                                                                                           Community Developments
                                                                               Section 1: A View of the Landscape
Small Business Bridge Loan program         and other community-based lenders
as they contributed staff time to          originate and service these loans.           The Louisiana
help develop the program and then
                                           The LRA and LED will apply
                                                                                        Recovery Authority’s
originated and serviced the loans
                                           approximately $90 million of the             Core Programs
on the state’s behalf. (See Capital                                                     The LRA has focused its efforts in
                                           repayment stream from the Business
One article on page 13 and Whitney                                                      three areas, with multiple programs
                                           Recovery Grant and Loan program
National Bank article on page 16.)                                                      supporting each.
                                           to establish a revolving loan fund
                                                                                        Small Business
As it became clear in fall 2006 that       for small businesses in communities
SBA loans and insurance proceeds           in South Louisiana. This fund will            •	 Small	Business	Bridge	Loan	Program

were arriving more slowly than             help ensure a continued supply                •	 Business	Recovery	Grant	
                                                                                            and Loan Program
anticipated, the state set aside more      of capital for small businesses
than $200 million for a grant and loan     in the affected communities.                  •	 Small	Business	Revolving	Loan	
                                                                                            Program in South Louisiana
program for small businesses. The first
phase of the Business Recovery Grant       Housing Investments                           Housing

and Loan program, developed by the         The LRA administers the $13.4 billion         •	 Road	Home	program	
                                                                                            supporting homeowners
LRA and administered by Louisiana          in federal disaster recovery funds
Economic Development (LED), was                                                          •	 Piggyback	program	combining	
                                           delivered, using the Community
                                                                                            CDBG and LIHTC programs for
launched in January 2007 and enabled       Development Block Grant (CDBG)                   mixed-income developments
nearly 3,500 grants of up to $20,000       program. Early in the recovery, the           •	 Small	Rental	Property	Repair	Program	
to small businesses and loans of up to     LRA prioritized the bulk of this funding         supporting small-scale landlords
$250,000 to more than 350 businesses.      to be used for replacing lost housing          Municipal Infrastructure
A second phase of this program was         stock and infrastructure repairs, with
                                                                                         •	 Long	Term	Community	
launched in April 2008. It aimed to help   a smaller allocation carved out for              Recovery program
an additional 1,500 small businesses.      economic development. We channeled            •	 FEMA	reimbursement	for	
These funds are not only being used        most of this funding into assistance             infrastructure repairs by
as emergency funding. They are being       for homeowner-occupants through                  local governments

invested in innovative, hard-working       the Road Home program, which soon
businesses, which use the funds to pay     became the largest home rebuilding
critical operating expenses, diversify     program in American history.
business offerings, and provide                                                       through FEMA. This will ensure
                                           The Road Home program offers
critical services to communities.                                                     that rebuilt properties will be safe
                                           grants to homeowners for their losses
                                                                                      from future hurricanes and floods.
The funds support the rebuilding of        up to $150,000, less money received
the fishing industries in Plaquemines      from their insurance companies.            We have also allocated approximately
and Cameron Parishes and serve             So far, we have disbursed more             $1.5 billion in CDBG funding for
as operating capital for cultural          than $6.7 billion directly to more         workforce and affordable rental
businesses that retain the spirit and      than 115,000 homeowners, so they           housing, through our Piggyback
soul of our state. Additionally, these     can repair their storm-damaged             program. This program couples CDBG
funds will repair retail and service       homes through the Road Home.               funds with low-income housing
companies, like CHL Linen in New                                                      tax credits to create unique, mixed-
                                           Participating homeowners must agree
Orleans, which uses its funds to buy                                                  income, and affordable housing
                                           to covenants on their property or enter
fabrics that will help it replenish                                                   units. We have approved more
                                           into contracts ensuring that any new
its stock and serve its customers.                                                    than 30 such projects, and 13 have
                                           or rehabilitated structure will meet
                                                                                      closed and are under construction.
Another company, Beary Cherry              new building code requirements and
Tree Daycare, uses its grant award to      FEMA elevation requirements, if            In addition, we created a Small Rental
pay for increased insurance costs so       applicable. In addition to rebuilding      Property Repair program to aid small
it can provide a critical community        funds, Louisiana has launched a large      “mom and pop” landlords, who
service. Businesses apply for these        home elevation program, devoting a         provided most of the rental housing
grants and loans at designated local       combination of $1 billion in CDBG          for the New Orleans workforce
community development financial            funds with $750 million in Hazard          prior to Katrina. So far, the state has
institutions (CDFIs). These CDFIs          Mitigation Grant program dollars           awarded grants to approximately



Fall 2008                                                                                                                           7
Section 1: A View of the Landscape
                                                                                                           outlined at www.louisianaspeaks.org,
                                                                                                           provide a blueprint for the region’s
                                                                                                           future to help guide assessments of
                                                                                                           different investment opportunities.
                                                                                                           We continue to channel significant state
                                                                                                           and federal resources into recovery
                                                                                                           efforts, which should leverage private
                                                                                                           investments and increase confidence
                                                                                                           that our communities are open for
                                                                                                           business. And, together with our
                                                                                                           partner state and local agencies,
                                                                                                           we have our fingers on the pulse
                                                                                                           of the growing Louisiana economy
                                                                                                           and are eager to share ideas and
                                                                                                           opportunities with investors seeking
                                                                                                           to support our state’s growth.
                                                                     Charlie Simokaitis Photography/LISC   Along with our neighbors in
 Ashley Place, a LIHTC development in Denham Springs, Louisiana.                                           Mississippi, Texas, Alabama, and
                                                                                                           Florida, we recognize that Louisiana
6,800 owners of rental properties                  Infrastructure Investments                              needs banks and other investors to
to restore about 12,800 units.                                                                             support our continued recovery from
                                                   The LRA designated $700 million of
                                                                                                           the hurricanes of 2005. Without
The grants are payable at the                      its federal disaster recovery funds for
                                                                                                           the continued commitment by
completion of construction and                     the Long Term Community Recovery
                                                                                                           banks to invest in our businesses
renovation. Of these, approximately                program, which provides funds to
                                                                                                           and people, we will not be able
1,500 owners have received firm                    support implementation of local long-
                                                                                                           to continue to move forward.
commitments from the state and                     term recovery plans in the most heavily
are proceeding to complete their                   affected communities in the state.                      We also recognize that we have a
units. Nine projects totaling 13                                                                           strong economic foundation in place;
                                                   The program is generally used to repair
units have been completed.                                                                                 together with the public sector funding
                                                   municipal infrastructure damaged
                                                                                                           initiatives, entrepreneurial spirit among
Skyrocketing insurance costs, coupled              by the storms and otherwise to help
                                                                                                           our business owners, and pride and
with the housing credit crunch, are                enhance communities as places to
                                                                                                           dedication among our homeowners
slowing the repair and replacement                 live and places to invest for residents,
                                                                                                           and other property owners, we
process for many owners, but we                    business owners, and the financial
                                                                                                           offer countless opportunities
know that more than 1,000 units are                institutions that support them. These
                                                                                                           for a strong financial return.
currently under construction. We are               funds supplement an almost $7 billion
working with financial institutions to             set aside for infrastructure repairs by                 At the LRA, we are eager to help
use our “conditional award letters”                FEMA, of which the state has disbursed                  match your investment appetite with
to back financing for these landlords,             more than $3 billion to reimburse                       the right business opportunity. We
many of whom have had difficulty                   local governments for their repairs.                    know Louisiana cannot thrive based
securing loans for their repairs.                                                                          on government investments alone.
                                                   The LRA has directed its focus to
Our partner agency, the Louisiana                                                                          It is through banks believing in
                                                   the implementation of longer-term
Housing Finance Agency (LHFA), is                                                                          our state and investing in our small
                                                   strategies and the coordination of
also working to produce about 7,500                                                                        businesses, our property owners, and
                                                   resources and partners to carry out
units across the state through its tax-                                                                    our future that we will meet our goal
                                                   that goal. As such, the LRA should be
exempt bond and HOME Investment                                                                            of rebuilding a better Louisiana.
                                                   a useful partner for banks seeking to
Partnerships programs. Additionally,               invest in the future of Louisiana. Our                  For more information, contact the LRA at
GO Zone tax credits have already                   planning efforts, many of which are                     info@louisianarecoveryauthority.org.
produced about 2,200 rehabilitated
or newly constructed rental units.


8                                                                                                                    Community Developments
                                                                             Section 1: A View of the Landscape

Public and Private Programs Support Homeownership
Kristopher Rengert, Community Development Expert, OCC



D
         espite significant obstacles,    • Raising some existing homes
         public and private                 onto a required raised foundation
         institutions—including             above the flood plain.
banks—have offered a wide range of
                                          • Paying for the increased
resources to support homeownership
                                            cost of insurance.
in the Gulf Coast. Some programs
took effect immediately after the         • Covering the increased cost
2005 devastation had occurred. Many         of building supplies.
forbearance programs, for example,        • Obtaining mortgage loan
automatically suspended mortgage            products in the face of
payments without penalty for several        tightened underwriting.
months. Longer-term programs helped                                                                                 Michelle Miller-Freeck/FEMA

homeowners weigh their options:           How public and private institutions       New elevated housing in Bay St. Louis, Mississippi.
repair damaged homes, dispose             responded during these trying
of them, and find new housing.            times has certainly been debated              its protections for borrowers with
                                          over the years. But this much is              FHA-insured loans, including
Easy answers were hard to come by,        true: these institutions developed            requiring its servicers to extend
given the landscape at the time. More     an array of programs to support               forbearance provisions for 90 days.
than 300,000 housing units suffered       homeownership immediately after
major damage or were destroyed in                                                       Subsequently, FHA provided several
                                          the storms, and many programs
the 2005 storms. Over 190,000 of                                                        extensions of this forbearance program
                                          continue to provide much-needed
these units were owner-occupied.                                                        through June 2006, for borrowers
                                          support for those already owning
(See charts on page 12 for details on                                                   that committed to working with
                                          homes as well as new home buyers.
damage to housing units.) Although the                                                  their servicers to repay outstanding
majority of these homes carried hazard    Immediate Support for                         payments. The U.S. Department of
and/or flood insurance, the coverage                                                    Agriculture and the U.S. Department
                                          Mortgage Borrowers
was insufficient to compensate                                                          of Veterans Affairs instituted similar
most owners for their losses.             Realizing that many homeowners were           forbearance policies (see page 15 of
                                          unable to return to severely damaged          the spring 2006 issue of Community
If the magnitude of loss was great,       homes and could be without access to          Developments). Many banks also
so were the obstacles for moving          their home mail or telephone services,        provided similar forbearance provisions
forward. Gulf Coast homeowners            banks and other financial institutions        to their borrowers. (See Capital
faced these types of challenges:          holding or servicing mortgage loans           One article on page 13 and Whitney
• Repaying mortgages on damaged           reacted quickly by implementing               National Bank article on page 16.)
  properties, while operating             automatic forbearance programs.
  often with reduced income               These gestures of goodwill typically          Longer-Term Support to
  from job loss or disruption.            allowed borrowers to suspend                  Preserve Homeownership
• Dealing with insecurity as              mortgage payments for several
                                                                                        Programs Supporting
  planning organizations decide           months. Sometimes, extensions were
                                                                                        Existing Homeowners
  which severely damaged                  granted and payment plans were
  neighborhoods will have                 reduced. Fannie Mae and Freddie               The federal government provided
  their infrastructure repaired           Mac implemented these policies                special allocations totaling
  and services provided and               for loans they guaranteed or owned            $16.7 billion to Alabama, Florida,
  when this will happen.                  in the hurricane-affected area.               Louisiana, Mississippi, and Texas
                                                                                        through the U.S. Department of
• Negotiating insurance claims.           The Federal Housing Administration
                                                                                        Housing and Urban Development’s
                                          (FHA) has a standard set of
• Locating and paying for skilled                                                       (HUD) Community Development
                                          protections for Presidentially Declared
  labor to renovate their homes.                                                        Block Grant (CDBG) program.
                                          Disaster Areas. The FHA extended



Fall 2008                                                                                                                                   9
Section 1: A View of the Landscape
                                                 properties for redevelopment or          not compensated by FEMA, private
                                                 conversion to open space.                insurance, or other sources. This
                                                                                          phase served more than 20,000
                                                 To qualify, an owner would have had
                                                                                          homeowners through April 2008 with
                                                 to prove that he or she owned and
                                                                                          grants amounts averaging $71,000.
                                                 occupied the property as a primary
                                                                                          By the time all grants have been
                                                 residence before August 29, 2005,
                                                                                          made, phase one will have used
                                                 and the home must have been in
                                                                                          approximately $1.28 billion out of the
                                                 a single- or double-unit structure.
                                                 The owner must have registered for       $3.24 billion that the state
                                                 Federal Emergency Management             allocated for its Homeowner
                                 NeighborWorks   Agency (FEMA) Individual                 Grant Assistance Program.
 A new home being constructed in McComb,         Assistance, and the home must be         Phase two is still in operation and is
 Mississippi.                                    categorized by FEMA as having been       expected to have made 5,100 grants
                                                 destroyed, having suffered major         after it finishes processing approved
The bulk of this funding went to
                                                 damage, or be verified as meeting the    applications. This part of the program
Louisiana, which received more
                                                 FEMA damage classification at the        provides compensation grants of up
than $10.4 billion, and Mississippi,
                                                 destroyed or major damage levels.        to $100,000 to homeowners whose
which received $5.5 billion.
                                                 The maximum funding under the            primary residences were damaged.
As described in greater detail below,
                                                 program is $150,000 per homeowner.       In addition, phase two provides grants
both states dedicated substantial
                                                 Actual maximum funding may               of up to $30,000 to eligible applicants
portions of these resources to help
                                                 be less and is the gap between           to help them elevate their homes above
existing homeowners rehabilitate
                                                 the required resources for repair,       the flood zone. Applicants must have
their homes. The legislation
                                                 rebuilding, or resettlement and the      a household income at or below 120
providing the special allocations
                                                 resources available from insurance,      percent of the area median income
lowered the normal CDBG income-
                                                 FEMA, or other sources. Individual       (AMI) and agree to a covenant on
targeting requirement for activities
                                                 homeowners often may not receive         their property that establishes building
to benefit low- and moderate-income
                                                 this maximum funding under the Road      code, homeowner insurance, and
persons from 70 percent to 50
                                                 Home program because the assistance      elevation requirements for them and
percent of the special allocations.
                                                 available to the program is capped.      any future owner of the land. This
In addition to providing this CDBG                                                        program is intended to ensure that
                                                 The Louisiana Recovery Authority
funding through the states, the                                                           grant recipients protect their properties
                                                 (LRA) runs this program (see
federal government, through the                                                           from flooding from future storms.
                                                 article on page 6), and applications
FHA and private mortgage lenders,
                                                 were due July 31, 2007. The
assists families whose homes were                                                         FHA’s Rehabilitation Mortgage
                                                 program has assisted 105,000
damaged or destroyed through                                                              Insurance Programs
                                                 homeowners through April 2008.
mortgage programs. As described                                                           HUD’s FHA 203(k) program provides
below, the FHA administers two                   For more information, visit the LRA’s
                                                                                          refinance loans covering both the
mortgage programs that support                   Web site at www.lra.louisiana.gov.
                                                                                          existing mortgage and the cost of
homeowners’ efforts to rehabilitate                                                       needed rehabilitation. For owners of
their properties or, in cases where              Mississippi’s Homeowner
                                                 Grant Assistance Program                 homes affected by the hurricanes, HUD
their housing units were rendered                                                         increased the amount of rehabilitation
uninhabitable, that help homeowners              The Mississippi Homeowner Grant          that could be financed under the
and renters to purchase new homes                Assistance Program includes two          program and extended the time for
                                                 phases to help rebuild homes destroyed   completing financed rehabilitation
Louisiana’s Road Home                            by the 2005 storms. Some homeowners
Homeowner Assistance Program                                                              activity. (See Capital One article
                                                 will receive grants under phases one     on page 13 for more details.)
The Road Home program helps                      and two.
homeowners repair or rebuild their                                                        Another HUD program, FHA 203(h),
                                                 Phase one provided up to $150,000
homes, buy or build replacement                                                           provides mortgage financing for
                                                 in compensation grants for damages
homes, or sell unwanted                                                                   families whose homes are destroyed or
                                                 to a primary residence that were
                                                                                          severely damaged in a Presidentially


10                                                                                                Community Developments
                                                                                                   Section 1: A View of the Landscape
Declared Disaster Area. This financing          and construction management to the                                targeted economically distressed
is available to families who had been           owners. (See the NeighborWorks                                    census tracts or in targeted parishes
homeowners or renters and if their              America article on page 22 for an                                 impacted by hurricanes Katrina or
homes were destroyed or damaged                 example of how the Neighborhood                                   Rita. The requirement is also waived
to such an extent that reconstruction           Housing Services of New Orleans                                   for buyers who had owned a home
or replacement is necessary.                    has partnered with banks.)                                        as of August 28, 2005, that was
Insured mortgages may be used to                                                                                  rendered uninhabitable by hurricane
                                                Mortgage Revenue Bond                                             Katrina. Since the hurricanes, the
finance the purchase or reconstruction
                                                Programs for First-                                               LHFA has issued more than
of a one-family home that will be the
principal residence of the homeowner.
                                                Time Home Buyers                                                  $200 million in MRBs, helping over
The mortgage amount is limited to the           The Louisiana Housing Finance                                     1,700 families buy homes in 2006.
standard FHA insurance limit for the            Agency (LHFA) operates several                                    The Mississippi Home Corporation
area where the home is purchased or             mortgage revenue bond (MRB)                                       used $157 million in tax-exempt bond
reconstructed. Participants may buy             programs and one program that                                     authority to issue MRBs to support
homes anywhere in the United States.            combines HOME Investment                                          Mississippi home buyers, many of
For more information, visit www.hud.            Partnership and MRB funds (HOME/                                  whom were affected by hurricane
gov/offices/hsg/sfh/ins/203h-dft.cfm.           MRB program) to support first-                                    Katrina. Qualifying home buyers are
                                                time homeownership for low- and                                   eligible for below-market interest rates,
Banks have partnered with nonprofit
                                                moderate-income families.                                         and the program helps pay for a portion
organizations to finance the
rehabilitation of owner-occupied                The first-time home buyer requirement                             of closing costs. More than 2,700
units. In these partnerships, the banks         is waived for the MRB-financed                                    low- to moderate-income families,
provide construction financing, and             programs (not for the HOME/                                       including 400 in the coastal counties,
nonprofits offer financial counseling           MRB program) for those buying in                                  have purchased their first homes


            Gulf Opportunity Zone Act Extends Reach of Tax Credit Programs

   T   he Gulf Opportunity Zone Act (the Act), passed by
       Congress in 2005, increases the resources available
   under three federal tax credit programs to support
                                                                                     Gulf Opportunity Zones by State
                                                                                                              Mississippi
                                                                                                                             Alabama

   the rebuilding effort in the Gulf Coast region. These
   programs are the:                                                                          Louisiana
                                                                             Texas
   •	 Low-Income	Housing	Tax	Credit	(LIHTC),	which	
      allows developers of low-income housing to sell
                                                                                                                                                       Florida
      federal tax credits equal to a large percentage
      of the cost that is incurred when building the
      low-income units in a rental housing project.
   •	 Historic	Tax	Credit	(HTC),	which	provides	
      a tax credit applied to the rehabilitation
                                                                                                          Katrina GO Zone only
      costs of historic buildings.                                                                        Wilma GO Zone
   •	 New	Markets	Tax	Credit	(NMTC),	which	permits	tax	                                                   Rita GO Zone only
                                                                                                          Katrina and Rita GO Zone
      credits for investments in Community Development
      Entities serving low-income communities.                 Source: U.S. Government Accountability Office (GAO) presentation of Internal Revenue Service information. Map
                                                               originally published in a July 2008 GAO report to the Committee on Finance, U.S. Senate, and the Committee
   The Act increases the tax credit available under LIHTC      on Ways and Means, U.S. House of Representatives. Report is titled Gulf Opportunity Zone: States Are Allocating
                                                               Federal Tax Incentives to Finance Low-Income Housing and a Wide Range of Private Facilities. Original map
   in those 2005 hurricane disaster areas, also known as
                                                               appears on page 8 of the GAO report, which can be downloaded from www.gao.gov/new.items/d08913.pdf
   “GO Zones,” designated by the President to require
   individual and public assistance under the Stafford
   Disaster Relief and Emergency Assistance Act (the Stafford Act).
   The Gulf Opportunity Zone Act also provides that properties placed in service during 2006-2008 in any of the hurricane disaster
   areas be considered to exist in a difficult development area, which increases the amount on which tax credits are calculated. The
   designation of any community as a difficult development area under the Act will extend through 2010.
   The Act authorizes the issuance of bonds to finance the construction and rehabilitation of residential and nonresidential property
   located in those hurricane disaster areas deemed to require assistance under the Stafford Act.




Fall 2008                                                                                                                                                                        11
Section 1: A View of the Landscape
through this program. Mortgages are                               Insurance Commissioner to reduce the                                nominal interest rate charged by the
originated by participating lenders.                              increase in wind and hail insurance                                 HOME/MRB program is 4.85 percent.
                                                                  rates, from a requested 400 percent                                 As the borrower makes mortgage
Additional Funding for                                            increase to a 90 percent increase,                                  payments, the loan servicer deposits
Increased Insurance                                               saving the affected homeowners an                                   two percentage points of the interest
Premiums                                                          average of more than $2,000 a year.                                 into the borrower’s escrow accounts
The “wind pool”—officially known                                  By 2007, the wind pool had doubled                                  for insurance and sends the remaining
as the Mississippi Windstorm                                      to include 32,000 policyholders. That                               2.85 percent to LHFA. According to
Underwriting Association—is                                       year, Mississippi passed the Mississippi                            LHFA, 35 buyers participated in the
a wind and hail insurer of last                                   Growth and Redevelopment Act of                                     first five months of this program.
resort for homes and businesses in                                2007, which created the Mississippi
                                                                                                                                      Looking Forward
Mississippi’s coastal areas, including                            Windstorm Underwriting Association
Harrison, Hancock, Jackson, Stone,                                Reinsurance Assistance Fund. This                                   Many homeowners and prospective
George, and Pearl River counties.                                 fund created long-term resources to                                 home buyers are reticent to invest
                                                                  help the state keep wind pool premium                               in Gulf Coast real estate. Indeed,
The wind pool is funded through                                                                                                       many still have not addressed storm
                                                                  increases at a manageable level. The
customer premiums and assessments                                                                                                     damage to their properties.
                                                                  fund is set up to operate through 2010.
from every insurance company in
Mississippi. In 2006, the 16,000                                  In 2006, LHFA created an innovative                                 Yet public and private partnerships
policyholders insured for wind                                    addition to its HOME/MRB program                                    continue unabated, programs
and hail damage, almost all                                       by creating an insurance assistance                                 continue to offer important financial
of whom had already incurred                                      program that provides for two                                       assistance, and hope remains. As the
devastating personal losses, faced                                percentage points of the interest                                   planning processes in Gulf Coast
the prospects of huge increases in                                paid by borrowers to be placed in an                                municipalities are completed and their
their annual wind pool premiums.                                  escrow account to be used to prepay                                 plans executed—and as economic
                                                                  the homeowner’s insurance premiums.                                 conditions strengthen regionally and
To offset the increased cost of                                                                                                       nationally—homeownership in the Gulf
                                                                  This subsidy is covered by the HOME/
reinsurance associated with the                                                                                                       Coast should reach a new equilibrium.
                                                                  MRB program in the form of a lowered
wind pool, Mississippi set aside
                                                                  interest rate charged to the borrower.                              For more information, contact
$50 million in CDBG funding.                                                                                                          Kristopher Rengert at (202) 874-4798 or
                                                                  For instance, as of August 2008, the
This action enabled the Mississippi                                                                                                   kristopher.rengert@occ.treas.gov.


                                                                Hurricane Damage to Housing

                          Owner-Occupied Units Damaged                                                             Rental Units Damaged
              Alabama                                                                                  Alabama

                Florida                                                                                  Florida

             Louisiana                                                                                 Louisiana

            Mississippi                                                                              Mississippi

                 Texas                                                                                     Texas
                                                                                                                   0


                                                                                                                           10,000


                                                                                                                                    20,000


                                                                                                                                              30,000


                                                                                                                                                        40,000


                                                                                                                                                                 50,000


                                                                                                                                                                          60,000


                                                                                                                                                                                   70,000
                          0


                                 10,000


                                          20,000


                                                    30,000


                                                             40,000


                                                                      50,000


                                                                               60,000


                                                                                        70,000




                                                   Housing Units                                                                             Housing Units


                                                   Severe Damage or Destroyed                            Major Damage

                          Source: FEMA
                          Note: Major damage refers to units that sustained between $5,200 and $30,000 in damages. Severe damage indicates units with over $30,000 in damages.




12                                                                                                                                                     Community Developments
                                                          Section 2: How Banks Contribute to the Recovery Effort
 How Banks Contribute to the
 Recovery Effort                               Capital One Bank: Meeting the Needs of
 Section 2 includes two articles               Customers, Employees, and the Gulf Coast Region
 examining how Whitney National
                                               Dorothy Broadman, Head of Community Development Banking,
 Bank and Capital One responded to
                                               Capital One Financial Corporation
 the hurricanes of 2005. The articles




                                               I
 describe how the banks reacted to
 support their local employees and                  n 2005, Capital One acquired
 their customers in the immediate                   Hibernia Bank, the largest
 aftermath of the storms, as well                   financial institution in Louisiana.
 as how they have adapted their                Headquartered in New Orleans, Capital
 business lines to support the medium          One Bank associates soon found
 and longer-term recovery of the               themselves literally and figuratively in
 region. Section 2 also presents the           the eye of Hurricane Katrina when it
 experiences of Wisznia Associates,            hit landfall that year. Critical issues of                                                   Capital One
 a New Orleans architectural and               survival and restoration immediately                   The Park at Lemoyne in D’Iberville,
 development firm, working with its                                                                   Mississippi, a LIHTC housing development
                                               confronted us, our customers, and                      by the Park Companies, created with
 lending partners, in adapting various
                                               the communities we serve.                              construction funding by Capital One.
 federal funding programs to support
 mixed-use developments in New                 The unparalleled dimension of the
 Orleans. We also present a sidebar on         crisis wreaked by Katrina required a                   estate, mortgage, consumer, community
 the Gulf Coast Opportunity Challenge          comprehensive and proactive response.                  development banking, and community
 program organized by Promontory               Building on Hibernia’s 140-year history                relations.
 Interfinancial Network to channel             of serving New Orleans, Capital One
 large-scale investments into FDIC-                                                                   Each of these units played a role in the
                                               Bank mobilized resources across the
 insured deposits in community banks                                                                  immediate aftermath of the disaster,
                                               company, including retail banking, all
 in the Gulf Coast area.                                                                              and they continue to assist with the
                                               of our lending areas including small
                                                                                                      region’s recovery today.
                                               business, commercial, commercial real



                                          An Affordable Development in
                                             D’lberville, Mississippi


    T
            he Park at Lemoyne is a development of The Park Companies, the third-largest affordable-housing developer in the nation,
            according to Affordable Housing Finance. The Park at Lemoyne will have 160 new rental units, all designated as affordable.
            Construction began in October 2007 and should be completed by July 2009.
    The Park at Lemoyne is located in D’Iberville, Mississippi, just north of Biloxi and about halfway between New Orleans and Mobile.
    Thirty-two units will be affordable to 50 percent of area median income (AMI) at rents from $360 to $488 per month, and 128
    units will be affordable to 60 percent of AMI at rents from $450 to $610 per month. These affordable rents compare favorably with
    market rents of $800 to $1,016 for older properties that are generally fully occupied.
    The financing for The Park at Lemoyne consists of a construction loan and low-income housing tax credits (LIHTCs). When the
    property is built and leased, the construction financing will be replaced by a permanent loan from Charter Mac/Fannie Mae.
    Centerline Capital syndicated the tax credits. Capital One is
    providing the construction loan and a standby letter of credit (LC)
    to secure the permanent loan rate lock.
                                                                                                  The Park at Lemoyne
    Capital One studied many competing affordable complexes
                                                                                                     Sources of Funds
    in the Biloxi/Gulfport area when it underwrote The Park at              Capital Sources - Construction                    Amounts
    Lemoyne development plan, and it found no vacant units.                 Construction Loan (Capital One N.A.)              $ 8,922,000
    Almost all of the comparable properties have a substantial list         Standby LC (Capital One N.A.)                        106,000
    of prospective tenants—some at as high a level as 20 percent
                                                                            LIHTC Equity                                       14,930,000
    of total units. Based on these findings, Capital One believes
    that The Park at Lemoyne, like Riverchase, may be one of                Total                                            $23,852,000
                                                                            Source: Capital One
    the most needed developments it has financed to date.




Fall 2008                                                                                                                                          13
Section 2: How Banks Contribute to the Recovery Effort
                                                   no reporting to the credit bureaus. In      thousands of housing units. The extent
                                                   addition, the bank provided mortgagors      of damage to housing required that
                                                   with 18-month forbearance, established      banks and regulators rethink mortgage
                                                   a skip-pay in September for credit          rehabilitation products.
                                                   cardholders, and lowered interest rates
                                                                                               Along with the Finance Authority of
                                                   and minimum payments for six months.
                                                                                               New Orleans, Capital One employees
                                                   Access to Branch Service                    took the lead in advocating for changes
                                     Capital One                                               to the Federal Housing Administration
 Riverchase in Gulfport, Mississippi, a            Recognizing that all bank customers in
                                                                                               (FHA) 203(k) rehabilitation product
 LIHTC housing development created with            the affected areas, not just Capital One
                                                                                               and the FHA Streamline product,
 construction funding by Capital One.              customers, needed access to banking
                                                                                               specifically for hurricane-affected
                                                   services, the bank, in an unprecedented
Supporting Associates                                                                          areas. The resulting modifications
                                                   collaboration, provided space to
                                                                                               extended the permitted rehabilitation
Immediately Before                                 competitor banks that were unable to
                                                                                               period and expanded the types of
and After Katrina                                  open their own offices. We arranged
                                                                                               construction allowed for the 203(k)
                                                   bus service to Capital One branches
As the likelihood of a hurricane                                                               product and increased the dollar limit
                                                   and to our competitors’ branches so
became apparent, the bank’s first                                                              for the Streamline product.
                                                   local residents could cash Federal
priority was assisting our employees.              Emergency Management Agency                 Approved in October 2006, more than
The bank expedited payroll to assist               (FEMA) checks, and we waived                550 families have benefited from these
with evacuation costs. Immediately                 foreign automated teller machine            modifications through May 2008. As
after the hurricane, we located and                (ATM) fees. Additionally, the bank:         homeowners become increasingly
assisted 3,100 displaced employees                                                             able to address a myriad of challenges
by establishing emergency hotlines                 •   Established an emergency hotline
                                                                                               presented by the hurricane, including
to provide answers to individual                       to provide the latest update on the
                                                                                               access to federal recovery funds, the
questions.                                             status of efforts to restore customer
                                                                                               availability of qualified contractors,
                                                       service.
Additionally, the bank broadcast radio                                                         weakened credit scores, and increased
and television advertisements with                 •   Created and distributed disaster        insurance and construction costs, we
information updates, and it made                       recovery fact sheets in branches.       anticipate a significant increase in the
$30 million available for bank                     •   Distributed stored-value cards for      number of families who will benefit
employees’ housing and emergency                       Red Cross disaster relief assistance.   from the modified products.
shelter needs. The bank spent an
                                                   •   Provided spare checks and ATM/          Capital One also led the advocacy
additional $2.7 million on other
                                                       debit cards.                            to increase first-time home buyer
emergency expenses, such as food,
                                                                                               subsidies from the city of New Orleans
child care, and car rentals.                       Capital One was the first bank to           for low- and moderate-income families
Helping employees address basic                    restore banking in New Orleans East,        still struggling to find housing post-
life needs and cope with personal                  one of the city’s largest neighborhoods     Katrina. The additional subsidies,
trauma enabled the bank to reopen                  and one of the areas hardest hit. The       increased from $25,000 to $50,000,
branches quickly and ensure that staff             bank was also one of the first to open      were needed because of significant
members were available to provide                  a temporary branch in the heavily           increases in housing and insurance
much-needed banking services.                      impacted St. Bernard parish.                costs following the hurricane.
Supporting Borrowers                               Public Policy Advocacy                      Small Business Lending and
through Forbearance                                Enhancing Home                              Economic Development
Forbearance was a key principle in                 Mortgage Lending
                                                                                               Small business needed as much
meeting customer needs in the wake                 Following the hurricane, Capital One        attention as homeowners did in the
of the hurricane. Capital One deferred             joined other banks and regulators in        recovery period, and Capital One
payments on all consumer and most                  meeting the needs of bank customers         pursued a number of small business
small business loans and lines of credit.          recovering from the disaster. One           initiatives. These included participating
Consumer loans were deferred until                 of the priorities was supporting the        in two rounds of the Louisiana
January 2006, and mortgage loans were              housing market in the wake of storms        Emergency Bridge Loan Program by
suspended for up to three months with              that severely damaged hundreds of


14                                                                                                     Community Developments
                                                     Section 2: How Banks Contribute to the Recovery Effort
providing nearly $8 million to 183         to refer declined small business
small businesses. The bank accounted       applicants to select nonprofit partners.
for 30 percent of loans extended in        Our partners have technical assistance
the first round of the program and         programs and provide access to capital
10 percent of the loans in the second      through micro-business loan funds.
round. The bank also participated
in the Louisiana Society of CPAs’          New Markets Tax
Disaster Recovery Seminar series,          Credit Financing
which disseminated information about       Providing capital to commercial
governmental assistance programs to        businesses continues to be an essential
                                                                                                                         Holy Cross School

business owners.                           element of recovery efforts. In June
                                                                                          Rendering of new Holy Cross School campus
                                                                                          in New Orleans.
The bank provided payment deferrals        2006, the bank received an allocation
to all small businesses located in         of $100 million in new markets
                                                                                      Community Development
hurricane-affected areas for 90 to 120     tax credits (NMTC). This program
                                           provides loans to businesses investing
                                                                                      Finance
days following the hurricane. Finally,
Capital One issued updated disaster-       in low-income communities across the       The bank continues to work with
planning guidelines to help businesses     country. Capital One’s allocation was      developers throughout the Gulf
prepare for future hurricane seasons.      targeted to communities located in the     Coast region to provide capital
This information was disseminated          Louisiana GO Zone. The bank used this      for developing new housing and
through press releases; the guidelines     program to provide financing to various    rebuilding homes that were lost.
are available at www.capitalonebank.       commercial borrowers that offer health,
                                                                                      We have coupled the knowledge of
com/disasterplanning.                      educational, and other services.
                                                                                      our local bankers with the expertise
Capital One also supported a number        Many of the bank’s NMTC projects           of the bank’s national community
of strategies to assist small businesses   have involved redevelopment of             development division to fund
needing loans that did not meet            vacant or abandoned buildings in           investments in low-income housing
standard banking credit requirements.      inner-city areas. Capital One has          tax credits (LIHTC). In 2007,
Among these strategies was the             implemented an innovative program          Capital One invested $66 million in
establishment of the Baton Rouge           that couples NMTCs with funds from         LIHTCs in Louisiana, and we expect
Micro and Small Business Fund              FEMA and other public agencies.            to invest as much as $150 million
created in partnership with the mayor                                                 in the Gulf Coast region in 2008.
                                           Because the public monies are not
of Baton Rouge and other financial         available until completion of the          Examples of recovery lending and
institutions. The fund promotes            projects, the bank added a bridge loan     investing activities include:
economic development by providing          component to its NMTC product,
technical assistance and financing to                                                 • $14 million LIHTC investment
                                           thereby making these important
non-bankable, small businesses that                                                     in New Orleans East, an area
                                           rebuilding projects feasible. As
create jobs. The Baton Rouge fund is                                                    that suffered substantial damage,
                                           one example, the bank used this
an important part of the recovery effort                                                to replace a National Housing
                                           combination of products to support
because many New Orleans small                                                          Partnership Foundation housing
                                           the development of the Holy Cross
business owners seeking to start anew                                                   development. (See article on
                                           School originally located in the Lower
relocated in Baton Rouge after Katrina.                                                 NHP Foundation on page 26.)
                                           Ninth Ward of New Orleans. Capital
Capital One also invested in the fund      One made a $42.1 million investment        •     $9 million loan to D’Iberville
and provided an operating grant. This      to help finance the rebuilding of the            Partners, LLC, in D’Iberville,
fund is just beginning and already has     school in the Gentilly neighborhood              Mississippi, to construct 160
a substantial pipeline of projects and     and created 375 construction                     affordable rental units. These units
a few loan closings. Seedco Financial      jobs and 27 permanent jobs.                      will be affordable to low- and
Services, a national community                                                              moderate-income families in a
development financial institution          In addition to the bank’s own tax credit
                                                                                            market where virtually no available
(CDFI), has been retained as the fund      allocation, Capital One has invested an
                                                                                            rental units exist today (see sidebar
operator.                                  additional $200 million in other NMTC
                                                                                            on page 13). A second $7.3 million
                                           projects in the Gulf Coast, including
In Baton Rouge and New Orleans,                                                             loan was provided to a related
                                           areas designated as a GO Zone.
the bank also implemented a program                                                         entity to construct an additional



Fall 2008                                                                                                                             15
Section 2: How Banks Contribute to the Recovery Effort
     216 units of affordable housing
     in the Riverchase development                   Whitney Bank: Helping Our
     in Gulfport, Mississippi.                       Communities on the Road to Recovery
•    $5 million participation in the                 Liza Copping, Assistant Vice President, Whitney Bank
     Louisiana Loan Fund, LLC, a


                                                     W
     product of the Local Initiative                             hitney National Bank’s                   90-day deferral period on all consumer
     Support Corporation (LISC); and in                          business footprint extends               loans in certain areas of Alabama,
     the Enterprise Louisiana Loan Fund                          along the Gulf Coast                     Louisiana, and Mississippi. Payments
     LLC, providing predevelopment                   from Houston, Texas, to Tampa,                       were automatically suspended and
     funding for local developers to build           Florida, with more than 150 branches                 no credit reporting was required.
     affordable housing. (See articles on            and 2,500 employees. In 2005,
     LISC on page 25 and on Enterprise                                                                    Consumers with first mortgage
                                                     hurricanes Katrina and Rita inflicted                loans serviced by Whitney were
     Community Partners on page 28.)                 massive devastation and dislocation                  offered a deferral of loan payments
Through 2009, Capital One will                       throughout South Louisiana and the                   for up to three months. In addition,
have supported the rehabilitation and                coastal areas of Texas, Mississippi,                 Whitney bankers worked with
construction of over 939 housing                     and Alabama, including dozens                        individual business clients to craft
units throughout the Gulf Coast                      of Whitney branch locations.                         deferral arrangements designed
region. Most of these units are in                   These two storms caused widespread                   for each unique situation. These
the form of affordable housing.                                                                           programs provided a much-needed
                                                     property damage, required the
Philanthropic Support                                relocation of an unprecedented number                lifeline for the many customers in
                                                     of residents and business operations,                the affected markets displaced and
Soon after the hurricane, the bank                   and severely disrupted normal                        incurring unexpected expenses.
provided philanthropic support for                   economic activity in the affected
educational needs and social services.                                                                    Later that year, Whitney participated in
                                                     areas. Many Whitney customers and                    a U.S. Small Business Administration–
In May 2006, we announced grants
                                                     more than 800 Whitney employees                      backed Gulf Opportunity Loan
totaling $3 million to help support
                                                     suffered staggering losses. Through                  program that was designed to help
Orleans Parish and communities
                                                     it all, Whitney and its bankers relied               expedite financing for recovery and
across Louisiana. The grants included
                                                     upon their fundamental strengths                     rebuilding efforts in areas affected
$125,000 to restore the libraries at two
                                                     while continuing to serve customers.                 by hurricanes Katrina and Rita.
charter schools in New Orleans that
were heavily damaged by Katrina
                                                     Meeting Customer Needs                               Whitney originated loans totaling
Committed for the Long Term                                                                               $370,000 in the Houston area, $227,500
                                                     Immediately following the storms,
                                                                                                          in the New Orleans assessment area,
By employing a comprehensive and                     Whitney offered loan assistance and
                                                                                                          and $100,000 in Mississippi. Whitney
proactive approach to rebuilding                     payment deferral programs, including a
the Gulf Coast region, Capital One
is having a substantive impact on
the lives of residents today, as well
as in the future successes of these
communities. For us, rebuilding New
Orleans and other affected areas is
an imperative, not a choice. With
our 140-year legacy in New Orleans,
we are committed to being a catalyst
for recovery and an integral part of
the future of this historic market.
For further information, contact Dorothy Broadman,
Capital One Community Development Banking, at
                                                                                                                                              Barry Bahler/FEMA
(703) 720-2368.
                                                      A new elementary school - public library combination in the lower 9th Ward, St. Bernard Parish of
                                                      New Orleans.




16                                                                                                                   Community Developments
                                                             Section 2: How Banks Contribute to the Recovery Effort
                                                                                                         America article on page 22).
                                                                                                         “DASH” stands for “Dependable,
                                                                                                         Affordable, Sustainable Housing.”
                                                                                                         WCDC extended other lines of credit
                                                                                                         in excess of $1 million to enable
                                                                                                         nonprofit developers to renovate
                                                                                                         houses in New Orleans’ Ninth Ward
                                                                                                         and the Central City area. Since the
                                                                                                         storms, WCDC has also financed
                                                                                                         several nonprofit developers to build
                                                                                                         single-family homes in Lake Charles,
                                                                                                         Lafayette, and Boutte, Louisiana.
                                                                   Charlie Simokaitis Photography/LISC
 LIHTC development by M&T Development in South Rayne, Louisiana.                                         Federal Home Loan Bank
                                                                                                         In early October 2005, the Federal
also originated 61 loans totaling                fund administered by Community                          Home Loan Bank (FHLB) of Dallas
$2.9 million through the Louisiana               Development Capital (CDCapital),                        offered disaster-relief grants designed
Department of Economic Development,              a certified CDFI. This fund provides                    to address housing and community
which established a bridge loan                  predevelopment financing to developers                  investment needs of areas in Louisiana,
program for small businesses affected            of affordable housing to cover                          Mississippi, and Texas affected by
by the hurricanes. Loan proceeds                 acquisition, environmental, demolition,                 hurricanes Katrina and Rita. As an
could be used only for maintaining or            and other predevelopment costs.                         FHLB member, Whitney obtained
restarting a business in a designated                                                                    grants totaling over $284,000 through
                                                 This predevelopment financing
area or in a temporary location in                                                                       the three components of the program:
                                                 supports these developers’ ability to
one of the qualifying parishes that                                                                      the Economic Development Disaster
                                                 access more conventional financing
sustained damage or interruption of                                                                      Relief Grant ($20,000), the Disaster
                                                 for construction and permanent
operations as a result of the storms.                                                                    Relief Partnership Grant ($18,000),
                                                 financing, thereby increasing the
Whitney is also among several other              supply of affordable housing in New                     and the Housing Disaster Relief
financial institutions participating in          Orleans and southeast Louisiana.                        Grant ($246,000). For families that
the Baton Rouge Small Business Loan              Since the hurricanes, CDCapital has                     were uninsured or underinsured, the
Fund, a $2.5 million fund through                made six loans totaling $1.85 million,                  Housing Disaster Relief Grant quite
Seedco Financial Services, a certified           resulting in 225 completed units                        literally put a roof over their heads.
community development financial                  and 147 additional planned units.                       Whitney also participates in the
institution (CDFI). As described
                                                 Whitney Community                                       FHLB of Dallas Affordable Housing
in this newsletter’s “This Just
                                                 Development Corporation                                 Program. Since the storms, the bank
In ...” article on page 31, this fund is
                                                                                                         has sponsored and been awarded
designed to serve small businesses               Another part of Whitney’s GO Zone                       five grants in the GO Zones, totaling
that previously have been unable to              strategy is to use Whitney Community                    $654,000, to provide homeownership
obtain start-up or operational financing         Development Corporation (WCDC)                          opportunities for 59 low- and moderate-
through traditional sources. It provides         to fund the interim construction of                     income families and assistance with
below-market-rate loans ranging from             affordable housing. WCDC extended                       home repair for another 15 families.
$5,000 to $150,000 with flexible                 $2.9 million in lines of credit to
repayment terms to eligible Baton                the local NeighborWorks America                         GO Zone Investments
Rouge entrepreneurs who employ                   nonprofit partner “DASH for the                         Whitney Bank invested $40 million
fewer than 50 employees. Since its               Gulf Coast” to construct homes in                       in Mississippi General Obligation
inception in the fourth quarter of               Mobile, Alabama, and Pascagoula,                        Gulf Tax Credit Bonds, otherwise
2007, the fund has closed seven loans            Mississippi, in participation with                      known as GO Zone bonds, and
totaling $441,000 and is currently               Neighborhood Housing Services of                        another $25 million invested in
processing over 50 loan applications.            America—CDFI (see NeighborWorks                         similar bonds issued by the state of
Whitney also participates in the loan


Fall 2008                                                                                                                                       17
Section 2: How Banks Contribute to the Recovery Effort
                                                                                                            allocatee also decided to fund a
                                                                                                            100 percent scholarship for a low-
                                                                                                            income minority student. This will
                                                                                                            allow up to five students to attend
                                                                                                            all eight years of school at no cost.
                                                                                                            WNMF has many more projects
                                                                                                            in its pipeline, of which it hopes to
                                                                                                            finance at least seven—four of which
                                                                                                            would involve nonprofit borrowers.
                                                                                                            From these, WNMF estimates that
                                                                                                            its NMTC allocation will create
                                                                                    Whitney National Bank
 Whitney National Bank volunteers participating in park cleanup with “Katrina Krewe.”
                                                                                                            approximately 1,933 permanent
                                                                                                            jobs and 400 affordable for-sale
                                                                                                            units of housing in low-income
Louisiana. These GO Zone bonds                      economically disenfranchised citizens.
                                                                                                            areas throughout the GO Zones.
were unique in that they did not pay a              WNMF has committed the majority of
traditional semiannual cash coupon.                 the 2007 NMTC allocation to funding                     WNMF seeks projects that would
                                                    these organizations, including schools,                 not be viable without the subsidy
The federal government paid
                                                    nursing homes for the indigent,                         provided by the NMTCs, of which
the interest on these bonds via a
                                                    nonprofit developers, and others.                       the King Edward Revitalization
quarterly tax credit in an amount
                                                    The effect of funding these nonprofit                   Project is a prime example. Despite
equal to what a fair market rate
                                                    programs will be to strengthen these                    a total project cost of more than
on the bonds would equal. This
                                                    community stakeholders and enable                       $80 million, the property appraised
federal-state partnership provided
                                                    them to continue indefinitely to                        at only $40 million, creating a gap of
funds to local municipal entities to
                                                    serve the low-income communities                        $40 million. Conventional financing
service their outstanding debt.
                                                    and populations they benefit.                           would not cover such a situation
Ensuring that the affected jurisdictions                                                                    when the project costs were so high
                                                    To date, WNMF has funded two
could continue to make timely                                                                               relative to the appraised value.
                                                    projects. The first project was the
payments of principal and/or interest
                                                    redevelopment in downtown Jackson,                      This was part of the reason the
on their debt enabled them to focus
                                                    Mississippi, of a blighted property,                    property sat vacant for so long.
their limited resources on immediate
                                                    which had been vacant for more than                     But with many different subsidies
problems, such as the repair,
                                                    40 years. Named the King Edward                         cobbled together from various local,
renewal, and rebuilding of municipal
                                                    Revitalization Project, it will include                 state, and federal sources (including
infrastructure and meeting operating
                                                    a 186-room Hilton Garden Inn,                           NMTCs), the project achieved
expenses. In essence, these tax-credit
                                                    3,000 square feet of retail space, 64                   financial feasibility and moved ahead.
bonds helped municipal agencies to get
                                                    market-rate apartments, and a parking                   Ultimately, community development
and keep essential services operating.
                                                    garage. This project was the result of                  finance added to the community
New Markets Tax Credits                             a request for proposals issued by the                   jobs, services, and an economically
                                                    Jackson Redevelopment Authority.                        productive facility in place of a
In 2007, the bank created the Whitney
                                                                                                            blighted, long-vacant property.
New Markets Fund (WNMF) and                         The second project is the rebuilding
successfully applied for a $50 million              of the Holy Cross School, which,                        Community Lenders
new markets tax credit (NMTC) to                    after 125 years in New Orleans’ Ninth                   and Philanthropy
more holistically meet the needs of                 Ward District, was decimated by
                                                                                                            Whitney has designated specific
its most vulnerable and economically                Hurricane Katrina. The school serves
                                                                                                            mortgage originators as “community
distressed communities. Applications                grades 5 through 12. WNMF financed
                                                                                                            lenders” who work with first-time
for this funding from developers have               the acquisition and construction of a
                                                                                                            home buyers in the GO Zones. These
surpassed the available capital.                    new school campus in conjunction
                                                                                                            lenders conduct home-buyer training
                                                    with several other NMTC allocatees.
WNMF investments focus on lending                                                                           programs and use bond programs,
                                                    In addition to the acquisition and
to nonprofit community facilities                                                                           as well as the bank’s in-house,
                                                    construction financing, each NMTC
to support the most vulnerable and


18                                                                                                                  Community Developments
                                                           Section 2: How Banks Contribute to the Recovery Effort
affordable mortgage product.                    Whitney bankers throughout the
                                                Gulf Coast have devoted many
Whitney participates in the United
                                                hours volunteering for numerous
Way Individual Development Account
                                                organizations. Volunteers have
program, along with other partners,
                                                constructed homes with Habitat for
promoting homeownership and
                                                Humanity, built playgrounds with
encouraging financial independence
                                                KaBOOM!, cleaned neighborhoods
by enabling participants to start or
                                                alongside the Katrina Krewe (see
expand child-care facilities or purchase
                                                photo on opposite page), bought
an automobile. The program was
                                                and distributed school supplies (see
rolled out in the fall of 2007 with
                                                photo), participated in regional
more than 60 accounts opened so far.                                                                                         Whitney National Bank
                                                recovery boards, volunteered at the
The program expects to support 619                                                           Children receiving school supplies from
                                                local chamber, and so much more.             Whitney National Bank volunteers.
participants at full capacity. Displaced
residents can take advantage of these           Whitney allocates a portion of              These contributions take the form of
programs to help them rebuild and               its revenue each year for cash              grants that support critical services;
return to hard-hit neighborhoods.               contributions to the community.             housing initiatives; and innovative
                                                                                            programs delivered by not-for-profit
               Helping Employees While Serving                                              organizations, schools, universities, and
                      Customers in Need                                                     community organizations located in our
                                                                                            markets. Since the storm, a substantial


  O
          nce it became clear that Hurricane    with their needs.
                                                                                            portion of these grants have been
          Katrina’s path would affect bank      Hundreds of Whitney bankers had
          branches along the Gulf Coast,
                                                                                            allocated to recovery efforts, housing
                                                damage to their homes, many with
  Whitney implemented its comprehensive                                                     initiatives, and charter-school support.
                                                severe damage or total destruction.
  disaster recovery plan, and key personnel     In response to this unprecedented
  started evacuation to safe areas,             devastation, the bank established
                                                                                            Future Investments
  principally Whitney’s backup facilities in    the Whitney Employee Lifeline Loan
                                                                                            for Whitney Bank
  Houston.                                      Program to provide no-interest loans to     While it will take a long time for the
  As evidence mounted that the relocation       employees pending receipt of insurance      Gulf Coast to fully recover, partnerships
  could be lengthy, operations were             proceeds or other sources of recovery
                                                                                            between banks; local, state, and federal
  expanded at backup sites in Houston,          funds.
  Chicago, Atlanta, Baton Rouge, and
                                                                                            organizations; private corporations;
                                                To date, the program has originated
  Mobile. Many Whitney relationship                                                         and neighborhood associations can
                                                over $13.1 million of such Lifeline loans
  officers were deployed to safe locations      for Whitney bankers who wanted to
                                                                                            accelerate the revitalization. Whitney’s
  throughout the company’s business             purchase new homes or who suffered          strategy throughout the Gulf Coast is
  footprint, staying as close to their          uninsured residential and/or personal       to create sustainable growth for long-
  customers as possible.                        property losses.                            term community recovery. Whitney
  As a result of this experience, Whitney has   In addition, Whitney established the        is committed to continuing efforts
  relocated its principal computer systems      Whitney Employees Disaster Assistance       to keep investment capital flowing,
  to a specialized, secure center in Dallas.    Fund through the Baton Rouge Area
  In addition, it has established backup
                                                                                            while nurturing partnerships with local
                                                Foundation with an initial contribution
  computer systems in Atlanta and Chicago.                                                  leaders and community organizations.
                                                of $500,000. The purpose of this fund,
  Whitney’s main focus was on serving           which can accept contributions from         Over the next few years, prospects
  customers during these unprecedented          anyone, is to provide assistance in the     for business and consumer growth
  dislocations. As soon as communications       form of grants to Whitney employees
                                                                                            are significant, relying not only on
  could be established, Whitney bankers         who have suffered significant economic
  began contacting their clients. Branch        loss that will not be reimbursed by
                                                                                            restoring what was but also creating
  damage was quickly assessed, and,             insurance or other sources. This fund       new opportunities throughout the Gulf
  as electricity was restored, damages          will remain active to serve employees       Coast. For Whitney Bank, investing
  repaired, and offices staffed, they were      should disasters strike in any Whitney      in the future of the Gulf Coast is not
  quickly reopened. Whitney bankers, many       markets in future years.                    only a priority—it’s a responsibility.
  who had lost everything themselves,
  worked extra hours to assist customers                                                    For more information, contact Richard Ainsworth,
                                                                                            CRA Officer, at rainsworth@whitneybank.com or at
                                                                                            (504) 586-3473.



Fall 2008                                                                                                                                     19
Section 2: How Banks Contribute to the Recovery Effort

Wisznia Associates: Deploying Creative Financial Solutions
for Redevelopment
Marcel Wisznia, President, Wisznia Associates



T
       o help New Orleans recover               Downtown New Orleans clearly                a master lease structure. This means
       from the devastation                     fits the strategy Wiznia had in mind        that the real estate owner borrows
       caused by Hurricane                      because this is where the multistory        the project debt and undertakes the
Katrina, Wisznia Associates, an                 and historic structures are located. It     rehabilitation activities, and the
architectural design and real estate            also presents a chance to maximize          master tenant operates the project and
development firm headquartered                  tax credits as a source of equity.          enters into subleases with end users/
in New Orleans, decided to use its                                                          occupants of the individual units. A
design capabilities and business                Creatively Combining                        “pass-through” provision of the Internal
experiences to help shape a smarter             Funding Sources                             Revenue Code (Section 50(d)) permits
redevelopment strategy for the city.            Nearly the entire Downtown                  the owner and the master tenant to
                                                Development District falls within           share the federal HTCs. Maximizing
In doing so, the firm developed and
                                                two historic districts, and, as a result,   the benefit of the HTC requires that
applied a creative technique for
                                                development projects in this area may       investors have a primary interest in
combining different federal funding
                                                apply for federal HTCs and Louisiana        profits associated with the project.
programs that previously were
rarely combined due to conflicting              HTCs. Because of the devastation            The structure of the NMTC differs
programmatic requirements. Wisznia              caused by the hurricane, most of this       considerably from that of the federal
combined federal historic tax credits           same area falls within census tracts        HTC. Under the NMTC program,
(HTC), federal new markets tax                  that qualify for federal NMTCs (see         a community development entity
credits (NMTC), and Federal Housing             sidebar on page 11 to read how recent       (CDE) receiving the NMTCs lends
Administration (FHA) financing—                 changes to the federal NMTC program         to, or invests in, qualified low-income
together with state programs—to                 expanded the number of eligible tracts      community businesses (QALICB)
support the adaptive reuse of multistory        inside the GO Zone). Louisiana has          that are “unrelated” to the CDE. The
commercial buildings into mixed-                implemented its own NMTC program,           NMTC system prohibits investors
use structures with the residential             which is also available in this area.       from owning more than half of
units safely above the flood zone.              Using multiple federal and state tax        the profits or capital interest in the
                                                credits to raise equity is an essential     business receiving the investment.
As a cornerstone to implementing
this strategy and as a first application        element in Wiznia’s development             The pass-through lease structure
of its creative financing, Wisznia              projects, as is FHA financing               allows the CDE to make NMTC
decided to transform the historic               (specifically Section 220 and 221(d)        qualified loans or investments directly
Maritime Building—a vacant, storm-              (4) insured loans, which are based on a     to the real estate owner/QALICB. At
damaged, 10-story commercial                    40-year non-recourse, fixed interest rate   the same time, the CDE owns all or
structure—into offices for the firm,            that is assumable), because construction    most of the profits or interest in the
plus additional offices available for           costs increased after Hurricane Katrina     master tenant entity and thus avails
lease, ground-floor commercial space,           by roughly 40 percent. The prime            itself of the HTCs passed through
and 105 market-rate apartments.                 reason for these higher construction        by the real estate owner (see April
                                                costs was the increased cost of supplies    2008 issue of the Novogradac New
Restoring the Maritime Building is the
                                                and labor. Additionally, insurance rates    Markets Tax Credit Report). In this
first of several adaptive reuse, mixed-
                                                climbed as much as 500 percent.             way, the benefits of the NMTC and
use projects on Wiznia’s agenda. Its
                                                The technical requirements of the           HTC programs are combined.
strategy is simple—focus development
opportunities in areas that remained            FHA loans and the NMTCs and HTCs,           Previously, the Department of Housing
high and dry in Katrina’s aftermath             which conflict in some respects with        and Urban Development (HUD) did not
and adapt and reuse existing historic           each other, compounded the complexity       allow properties with master leasing
multistory structures by providing              of this financing package. Federal          structures to use FHA-insured loans
new housing units on upper floors and           HTC projects typically incorporate          because HUD required a mortgagor
commercial space on lower floors.                                                           to own and operate the property,


20                                                                                                  Community Developments
                                                       Section 2: How Banks Contribute to the Recovery Effort
subject to the HUD Regulatory
Agreement. Wiznia successfully
petitioned HUD to allow the company
to use a master lease ownership
structure so that it could combine
HTCs, NMTCs, and FHA financing.

Maritime Building Project
Restoring the Maritime Building
supports the revitalization of New
Orleans’ downtown area by helping
to replace the dwindling supply of
rental housing in this area as well
as by replenishing the supply of
market-rate housing units in the
                                                                                                                        Wisznia Associates
New Orleans metropolitan area.
                                                  Maritime Building in 1956.               Maritime Building in 2008, being
The number of downtown rental                                                              redeveloped by Wisznia Associates.
residential dwelling units has declined
over the past six to eight years, as many
historic buildings have been converted      of which will add to the fabric of
from rentals to condominiums. This          the neighborhood and vibrancy of               Maritime Building Project
conversion process, combined with           the historic downtown district.
the destruction of tens of thousands of                                                    Uses of Funds                       Amounts
                                            The Maritime Building project uses an
single and multifamily units throughout     acquisition bridge loan from Wachovia          Land                                  $6,800,000
greater New Orleans by Hurricane            Bank, which assisted in maintaining            Hard Costs                            16,639,999
Katrina, has created a tremendous           site control as the additional financing       Soft Costs                              4,796,249
need for affordable rental housing.         was arranged. Project financing                Other Costs                             8,298,212
Since the hurricanes of 2005, most          consists of equity from the state and          Total                               $36,534,460
developers have focused on mixed-           federal NMTCs and HTCs described
or low-income developments but              above and permanent/construction               Sources of Funds                    Amounts
few 100 percent market-rate projects        financing in the form of FHA                   FHA Mortgage                        $16,422,100
have begun construction. Maritime           221(d)(4) and 200 loans. Wachovia              Federal HTC Equity                      6,811,980
will be only the fourth downtown            also will be the FHA lender. A local           Louisiana HTC Equity                    3,500,000
market-rate residential development         community bank partner, Omni Bank,             Federal NMTC                            1,800,000
announced since the storm (two have         is providing tax credit bridge financing.
                                                                                           Deferred Architect and                  1,050,000
been completed and construction             (See chart at right for financial details.)    Developer Fees
on the third has just begun); all                                                          Builder’s Profit                        1,919,464
                                            This financing effort has taken a
four projects total only 400 units.
                                            year longer to accomplish than the             Owners’ Equity Contribution             5,030,916
The residential density in downtown         traditional 6 to 12 months required for        Total                               $36,534,460
New Orleans must increase                   the preliminary and final applications         Source: Wisznia Associates

dramatically because it is one of           that are typical in the FHA lending
only a few areas in the city on higher      process. Wachovia’s patience as the
ground. Additionally, the existing          acquisition bridge lender has been
                                                                                          Wiznia has two other projects
urban condominiums and rentals              essential. The relationship with
                                                                                          planned, totaling another $65
need more downtown amenities,               Wachovia began with the bridge
                                                                                          million in downtown New Orleans
such as restaurants, grocery stores,        loan to purchase the building and
                                                                                          development—part of the continuing
and bookstores. The Maritime                will ultimately culminate in a HUD
                                                                                          recovery of a great American city.
Building’s ground floor will include        closing, through Wachovia. The project
a regional bank, a coffee shop/             is on pace to close in fall 2008 and          For more information, contact Marcel Wisznia at
bakery, and a pizza restaurant—all          construction will be completed in 2009.       mwisznia@wisznia.com.



Fall 2008                                                                                                                                    21
Section 3: How Nonprofits Contribute to the Recovery Effort

  How Nonprofits Contribute
  to the Recovery Effort
                                                        NeighborWorks® Leverages
  Section 3 examines how nonprofit                      Partnerships to Rebuild from
  organizations throughout the Gulf
  Coast have supported the recovery                     the ‘Neighborhoods Up’
  effort. Here we include feature                       Tom Deyo, Senior Advisor for Gulf Rebuilding and Green Strategies, NeighborWorks America
  articles about NeighborWorks



                                                        R
  America and the NHP Foundation.                                ebuilding the nation’s Gulf
  NeighborWorks America brings                                   Coast region represents perhaps
  together financial resources                                   one of the greatest challenges
  from banks and other sources to
                                                        to the community development
  support local partner organizations
                                                        industry in recent years. Nearly
  in repairing and replacing
                                                        900,000 owner-occupied homes
  affordable rental housing and
                                                        and 1.2 million housing units across
  owner-occupied housing. NHP
                                                        Louisiana, Mississippi, Alabama,
  Foundation is engaged in replacing
                                                        Texas, and Florida sustained damage
  its affordable rental housing stock                                                                                                          NeighborWorks
  in New Orleans and in expanding
                                                        or were destroyed by hurricanes                  Single-family modular homes under
  its inventory of affordable rental                    Katrina and Rita in 2005. Low- and               construction by NeighborWorks America’s
  housing in the Gulf Coast region.                     moderate-income families occupied                partner, DASH for the Gulf Coast, in Mobile,
                                                        a substantial portion of these, a                Alabama.
  We also present sidebar articles
  summarizing the recovery                              major segment of the workforce                   national leader in the development,
  activities of the Southern Mutual                     that cannot return without safe and              preservation, and management of
  Help Association, Local Initiatives                   healthy affordable housing options.              affordable housing, NeighborWorks
  Support Corporation, and                              NeighborWorks America, a                         has a 30-year track record of
  Enterprise Community Partners.                        congressionally chartered nonprofit              strengthening the performance and
                                                        organization that focuses on                     capacity of affordable housing and
                                                        community revitalization, has been               community development organizations
                                                        working since the storms to restore              to respond most effectively and
                                                        affordable housing for homeowners and            efficiently to local community needs.
                                                        renters in the region. NeighborWorks’            NeighborWorks has built its capacity
                                                        efforts have been grounded on                    in the Gulf region by opening field
                                                        the principal of rebuilding “from                offices in Jackson, Mississippi, and
                                                        neighborhoods up,” working with local            New Orleans. Don Phoenix directs
                                                        organizations and financial institutions         the organization’s Gulf rebuilding
                                                        to restore the bedrock of thriving               initiative from the Southern District
                                                        communities—safe neighborhoods that              region. He says that the organization is
                                                        families would be proud to call home.            committed to supporting organizations
                                        NeighborWorks
                                                        NeighborWorks America is well                    with grants and investments to provide
Completed modular housing by DASH for the
Gulf Coast, in Mobile, Alabama.                         positioned for implementing a long-              100,000 families with financial
                                                        term Gulf rebuilding strategy. A                 counseling and to support the building
                                                                                                         or rehabilitating of 10,000 affordable
             NeighborWorks America Organizations in                                                      homes in the region by 2010.
               Alabama, Louisiana, and Mississippi                                                       A Partnership Approach
Organization                                                     Contact Person    Phone Number
Community Service Programs of West Alabama - Tuscaloosa, AL      Cynthia Burton    (205) 752-5429 x231   Although the challenges have been
Neighborhood Housing Services of Birmingham - Birmingham, AL     John Colón        (205) 328-4292        great and the needs enormous,
Neighborhood Housing Services of New Orleans - New Orleans, LA   Lauren Anderson   (504) 899-5900        NeighborWorks America has
Southern Mutual Help Association - New Iberia, LA                Lorna Bourg       (337) 367-3277        made significant progress in the
Voice of Calvary Ministries - Jackson, MS                        Erma Driver       (601) 857-1256




22                                                                                                                Community Developments
                                               Section 3: How Nonprofits Contribute to the Recovery Effort
region working with local partners.        track record of doing these types of
Over the past three years, it has          transactions and doing them well.”
developed more than 30 strategic           NHSA-CDFI’s success in these
partnerships with local organizations      transactions stems from its expert
throughout Alabama, Louisiana,             role as a financial intermediary,
and Mississippi. NeighborWorks’            managing financial investments
grants of more than $10 million            in local nonprofit developer
since the storm to its partners are        partners using capital provided by
helping to build the capacity of these     its investors, including banks.
organizations as well as advance
the development of more than $150          A Desire to Have                                                               NeighborWorks

million in new and rehabilitated           People Come Back                           Building neighborhood playgrounds
single and multifamily units.                                                         with “KaBOOM!”
                                           Whitney Community Development
A linchpin of NeighborWorks’               Corporation, a subsidiary of the           planned 300-unit, single-family
success in the region is its work with     Whitney Holding Corporation, is            housing development in the Hillsdale
Neighborhood Housing Services of           providing key investments to capitalize    neighborhood in Mobile, Alabama,
America-Community Development              NHSA-CDFI funds for Gulf Coast             and the Chipley neighborhood
Financial Institution (NHSA-CDFI).         rebuilding. With headquarters in New       in Pascagoula, Mississippi.
NHSA-CDFI has committed to raising         Orleans, and branches throughout           The new modular homes are
$30 million for an interim development     Alabama, Florida, Louisiana,               1,400–1,700 square feet and built to
financing fund for land and property       Mississippi, and Texas, Whitney is         withstand a Category 5 hurricane (see
acquisition, predevelopment financing,     highly motivated to be involved in         photos on opposite page). Grants and
site and infrastructure development, and   recovery efforts (see Whitney article on   subsidies from the city, county, and
construction financing for development     page 16). The storms damaged many          state governments, as well as from
of affordable housing in the region.       of its branches, but more than that, the   the Federal Emergency Management
                                           storm destroyed their communities.         Agency and NeighborWorks America,
To date, NHSA-CDFI has secured
$7 million in investments toward           “There is a tremendous desire on           will ensure that the new homes are
the fund from banks, insurance             the part of most of those displaced        affordable, with prices ranging from
companies, and a regional health care      by Katrina, and who have been              about $90,000 to $150,000. The total
system. The organization is soliciting     separated from their family and            project value will exceed $28 million.
additional investments from banks,         friends, to return home and rebuild,”
insurance companies, foundations, and      said Richard Ainsworth, Vice               Reducing the Risk in
corporations. NHSA-CDFI has used           President of Community Affairs             Rehabilitation Lending
these investments to make more than        for Whitney National Bank and              Several banks, including Whitney
$7 million in interim development          President of Whitney Community             National Bank, Fidelity Homestead,
loans to locally based Gulf Coast          Development Corporation. “The lack         and Standard Mortgage, are working
nonprofit developers, with                 of housing opportunities has also          with another NeighborWorks
$3 million more pending. Loans             prevented a number of employers            organization, Neighborhood
include predevelopment financing,          from hiring more workers.”                 Services (NHS) of New Orleans,
property acquisition, and construction     With Whitney’s support, NHSA-CDFI          on rehabilitation and construction
financing for affordable housing           has made three interim loans totaling      management projects for homeowners.
development in Alabama, Louisiana,         nearly $2 million to NeighborWorks
Mississippi, and Texas.                                                               “We make it easier for banks to do
                                           partner Dependable, Affordable,
                                                                                      rehab lending,” said Lauren Anderson,
“We are working with really strong         Sustainable Housing (DASH) for the
                                                                                      CEO of NHS of New Orleans. “It
nonprofits that are getting the work       Gulf Coast, a nonprofit developer
                                                                                      is sometimes difficult for banks
done,” said Jack Gilbert, President        of affordable housing based in
                                                                                      to invest in renovation financing
and Chief Executive Officer (CEO)          Mobile, Alabama. The loans will
                                                                                      because there is greater risk. Jobs
of NHSA-CDFI. “We have a proven            help fund the development of a
                                                                                      can take longer than expected and




Fall 2008                                                                                                                         23
Section 3: How Nonprofits Contribute to the Recovery Effort
there can be cost overruns. But                NHS develops a detailed scope of               NHS of New Orleans is also working
we’ve never had a situation where              work. NHS helps the homeowner                  with Freddie Mac on a special loan
we have been unable to deliver a               select general contractors (who have           product that is being piloted in the
project on time and on budget.”                been qualified by NHS) to invite to            Broadmoor, Gentilly, and Pontchartrain
                                               a pre-bid conference at the house.             Park neighborhoods in New Orleans.
NHS of New Orleans has been
                                                                                              Named “Rebuild New Orleans,” this
supporting homeowner rehabilitation            The homeowner selects the contractor
                                                                                              is a conventional loan product that
projects, including their bank financing,      based upon this competitive bid
                                                                                              allows a lender to make one loan for
since it began operations in 1976. NHS’        process. NHS develops a contract
                                                                                              acquisition/rehabilitation or refinance/
construction management services               between the homeowner and the
                                                                                              rehabilitation. It is similar to a product
include the development of an initial          contractor. NHS monitors the work
                                                                                              Freddie Mac created to support the
feasibility study with the homeowner           and issues progress payments to
                                                                                              recovery effort following the 1994
to determine the approximate scope             the contractor. Since 2006, NHS
                                                                                              Northridge earthquake in Los Angeles.
and cost of the construction work.             has completed the renovation
Once NHS and the lender have                   of 54 homes, 20 of which were                  Through this product, NHS of New
determined that the project is feasible,       projects in partnership with banks             Orleans will provide counseling,
                                               or mortgage companies.                         home-buyer training, and construction
                                                                                              management services. This product
           Southern Mutual Help Association Aids                                              enables the lenders—Chase,
                                                                                              Countrywide Bank, and Standard
               Neglected Rural Communities                                                    Mortgage Corporation—to be


   O
            ut of the public eye,              an equity equivalent product (EQ2), a          more secure in making what might
            rural Louisiana suffered           long-term deeply subordinated loan             otherwise be considered very risky
            tremendous hurricane-related       with features that make it function like       loans through pre-purchase counseling
   damage to homes and businesses.             equity. It was the first time this financial
                                                                                              that ensures borrowers are better
   Aiding in the state’s recovery is the       tool had been employed in Louisiana.
   financial assistance provided by the                                                       prepared and construction management
                                               The EQ2 was invested with no interest
   Southern Mutual Help Association                                                           that helps ensure construction goes
                                               obligation, increasing SMFS’s ability
   and its lending arm and wholly              to provide affordable mortgage                 according to plan and budget. This
   owned subsidiary, Southern Mutual           financing to low- and moderate-income          pilot, still in its early stage, is an
   Financial Services (SMFS).                  families and individuals. Making this          example of how banks are using the
   Through its Rural Recovery Program,         commitment won MidSouth Bank the               expertise of nonprofit developers
   the association worked to restore           coveted Spotlight Award from the               to facilitate lending, particularly
   more than 800 homes and businesses          Federal Home Loan Bank of Dallas.
                                                                                              in low-income communities.
   across the 11 rural parishes most           Recently, the Southern Mutual Help
   affected by the hurricanes.                 Association returned to its founding           Financial Counseling Plus
   Established in 1969, the association        objective—providing affordable                 ‘BestFIT’ Equals Success
   collaborates with Louisiana banks           rural housing. Teche Ridge, its latest
   through SMFS, a community                   venture, will be a mixed-use, mixed-           In another innovative partnership,
   development financial institution (CDFI),   income development providing 184               NeighborWorks America worked
   to encourage investment opportunities       housing units in phase one and 370             with Mississippi-based Enterprise
   and strengthen poor families and            housing units in phase two, of which           Corporation of the Delta, one of the
   communities throughout the southwest        138 units will be earmarked for low-
                                                                                              nation’s leading CDFIs, to provide
   portion of the state known as Acadiana.     and moderate-income families.
                                                                                              direct financial counseling and
   SMFS concentrates on affordable             The $150 million Teche Ridge project
                                                                                              ongoing support to families. As part
   mortgage financing. Banks can help          will help to counter developing patterns
   their communities by investing in           in rural Acadiana that segregate housing       of this effort, an innovative tool was
   CDFIs like SMFS; at the same time,          by income, geography, and design. The          developed that allows counselors
   they earn consideration with regulators     association is seeking partnerships with       to identify which of several loan
   under the Community Reinvestment            banks and other financial institutions         products a family might qualify for,
   Act investment and lending tests.           to secure funds for the new initiative’s       if they have a financial gap and need
   MidSouth Bank, headquartered in             infrastructure development.
                                                                                              additional funds. Just Price Solutions,
   Lafayette, Louisiana, did just this with    For more information, visit                    a nonprofit subsidiary of NHSA,
   a $75,000 investment in SMFS through        www.southernmutualhelp.org.
                                                                                              developed the “BestFIT” tool.



24                                                                                                    Community Developments
                                                      Section 3: How Nonprofits Contribute to the Recovery Effort
This Web-based technology allows                depth and breadth of our
homeownership counselors and                    work,” said Anderson,
lenders to streamline and centralize            of NHS of New Orleans.
the process of finding the right loan           “Working in tandem with
product for borrowers. Born out of the          qualified nonprofits, banks
counseling efforts in Mississippi, this         can meet the needs of
solution is now being used nationally,          communities and reach
including by actor Brad Pitts’ “Make            the underserved market
It Right Project” in New Orleans.               while lowering risk.”
“Nonprofits play a unique role in               For more information, visit
                                                www.nw.org/gulfrecovery or
facilitating lending, particularly to
                                                contact Tom Deyo at
low-income communities, and we                  tdeyo@nw.org.
                                                                                                                                           SAS Photo/LISC
are always looking for new ways
                                                                                      The Swainer family in Pass Christian, Mississippi celebrates
to partner with banks to expand the
                                                                                      moving into its new home.




                                       Local Initiatives Support Corporation
                                             Stays Focused on ‘Local’


    T
            he business of rebuilding             states, such as Teche Ridge, a                    economic conditions and a significant
            devastated communities has            100-acre mixed-use, mixed-income,                 market shift have significantly
            made significant progress in          traditional neighborhood development              reduced the available investment
    the last three years, but the work is         on the outskirts of New Iberia,                   dollars. Other adverse market factors
    far from complete. Local Initiatives          Louisiana, and Frenchmen’s Hope,                  have been dramatic increases in
    Support Corporation (LISC) was                a homeownership project for low-                  property and flood insurance and
    among the first agencies in 2005 to           income families in New Orleans.                   tightened credit markets affecting
    assess needs in the storm’s aftermath,        LISC, together with its tax credit                commercial developments and
    support local groups best able to             affiliate, National Equity Fund Inc., has         single-family mortgage finance.
    affect recovery, and channel funds            supported many low-income housing                 LISC is eager to expand its existing
    to the organizations and projects             tax credit (LIHTC) developments.                  partnerships with banks and other
    that could have the greatest impact.          In Mississippi, LISC is supporting                investors as it continues to support
    That work continues today, though             a new health clinic in D’Iberville,               the recovery effort in the Gulf Coast
    difficulties in the credit and investment     collaborating with the Biloxi Housing             and to connect these resources with
    markets are creating new challenges.          Authority to support a major mixed-               the local organizations engaged in the
    Since 2005, LISC has infused $180             use development that revitalizes                  bricks-and-mortar work of recovery.
    million in grants, loans, and equity into     Main Street, and working with the                 LISC can facilitate bank investments
    devastated Gulf Coast communities,            state to create a predevelopment                  through its Gulf Region Rebuilding
    while providing extensive technical           and acquisition loan program                      Initiative, which delivers funds
    assistance and pressing the region’s          supporting the state’s Long Term                  and technical assistance to local
    needs with prominent national funders.        Work Force housing strategy.                      development partners; through
    High among LISC’s accomplishments             A critical source of funds supporting             participation in the Louisiana
    is cooperating with other groups              LISC’s efforts have been banks                    Loan Fund; and through LIHTC
    to create the $47 million Louisiana           like JPMorgan Chase, Capital                      deals syndicated via the National
    Loan Fund, a public/private                   One, and Deutsche Bank, along                     Equity Fund Inc. (NEF).
    partnership focused on affordable             with some of the country’s leading                For more information, contact Evelyn Brown,
    and mixed-income housing.                     foundations and public entities.                  LISC Senior Vice President, at
    The partnership is working with                                                                 ebrown@lisc.org or Darrell Hubbard, NEF
                                                  Current market conditions are
    developers helping to rebuild 4,500                                                             Senior Vice President, at
                                                  complicating ongoing redevelopment
    homes with low-interest loans.                                                                  dhubbard@nefinc.org.
                                                  work, however, most notably the new
    LISC has supported dozens of                  pressures on the LIHTC market, where
    projects throughout the affected




Fall 2008                                                                                                                                           25
Section 3: How Nonprofits Contribute to the Recovery Effort

NHP Foundation Contributes to Affordable Housing
Ghebre Selassie Mehreteab, Co-Chairman and Chief Executive Officer, The NHP Foundation




A
          merica’s affordable housing        housing units primarily throughout
          crisis has been most visible       the East and the Gulf Coast states.
          in the aftermath of hurricanes
                                             Integral to the provision of housing
Katrina and Rita. The storms
                                             is NHPF’s Operation Pathways,
drastically affected the housing stock
                                             which offers programs to empower
in the Gulf Coast region, resulting
                                             residents and surrounding communities
in the displacement of hundreds
                                             by providing skills necessary
of thousands of people without
                                             to break the cycle of poverty
adequate and secure housing.
                                             through community building, child
                                                                                                                          NHP Foundation
With so many homes ruined by the             enrichment, and adult education.
                                                                                         The community center under construction at
storms, the demand for affordable                                                        NHP Foundation’s Walnut Square development.
                                             Since 1994, NHPF has acquired and
housing has increased exponentially.
                                             preserved 46 properties in 14 states.
In the New Orleans metropolitan                                                          While LIHTC developers might
                                             Today, NHPF spans 23 communities
area alone, 89,444 affordable                                                            have raised 95 cents to one dollar
                                             in 11 states with 28 properties, serving
homes and apartments suffered                                                            per credit in early 2007, by early
                                             more than 25,000 residents in nearly
major or severe damage from                                                              2008 they were typically able to
                                             6,000 units. Prior to hurricanes Katrina
Katrina and Rita. Of that number,                                                        raise only 80 to 85 cents per credit.
                                             and Rita, this inventory included
only 22,806 homes and apartments
                                             nearly 900 units of affordable rental       Declining equity from tax credits
are in the rebuilding pipeline.
                                             housing in four developments in New         would require developers to either
The NHP Foundation (NHPF) became             Orleans. Over the next three years,         find some way to cut project costs
immediately involved in the recovery         NHPF plans to acquire, rehabilitate,        or to raise additional financing. Both
because Hurricane Katrina destroyed or       and develop an additional 9,000             of these remedies are difficult in the
severely damaged nearly 900 units of         housing units, of which one-third           current economic climate for affordable
the organization’s housing stock in New      will be in the Gulf Coast region.           housing developments, which are
Orleans. As the demand for affordable                                                    typically already on very tight budgets.
housing in the Gulf Coast region             NHPF’s Response to a
                                             Changing Environment                        Material changes to a project, such
became apparent, NHPF decided to add
                                                                                         as reducing the number of housing
to its affordable housing inventory in       Post-Katrina                                units produced to reduce costs, would
the region in keeping with its mission,
                                             The storms severely damaged all             generally require the developer to
which is to provide quality, affordable,
                                             three properties NHPF owned prior           submit an amended application to
rental housing and resident services for
                                             to Katrina. Walnut Square (209              the credit-allocating agency. Thus,
low- and moderate-income families.
                                             units) needed reconstruction. Forest        the developer would run the risk
Who We Are                                   Park (284 units) and Tanglewood I           that its project would no longer be
                                             and II (384 units) needed significant       competitive and could lose its credits.
In 1989, the National Housing
                                             renovation. Organizing the financing        This conundrum has led to some
Partnership—a congressionally
                                             to cover these large-scale construction     projects being shelved, as developers
chartered corporation—created the
                                             projects was complicated.                   were unable to cover the gap left
foundation. NHPF is a national
                                             In a cruel coincidence, the period          by the weakened LIHTC market.
nonprofit with the rigorous financial
discipline of a real estate company and      since the hurricanes saw a dramatic         NHPF has been able to adapt to this
the mission of a charitable organization.    decline in the prices offered for low-      challenging market environment
NHPF leveraged $6 million in                 income housing tax credits (LIHTC),         through its strong reputation as a
initial contributions from 24 major          a principal source of funding for           national affordable housing developer
corporations, including six banks,           affordable housing development.             and manager and its deep network
into more than 9,000 affordable rental                                                   of financial partners in the public,
                                                                                         private, and philanthropic sector.


26                                                                                               Community Developments
                                              Section 3: How Nonprofits Contribute to the Recovery Effort
NHPF bridged the financing gap            development that will serve as a social
to replace its existing New Orleans       hub for the surrounding community.
affordable housing stock through          In addition to constructing 209 mixed-
philanthropic grants from The Ford        income housing units and an acre of
Foundation, The John D. and Catherine     commercial space, the $37.8 million
T. MacArthur Foundation, Bush-            rebuilding project will provide this
Clinton Katrina Fund, Louisiana           neighborhood with a playground,
Disaster Recovery Foundation,             surface parking, laundry facilities,
Qatar Katrina Fund, and others. And       a community center, and more.
residents have begun to move back                                                                                     NHP Foundation
                                          The total development cost was
into the Gulf Coast properties. In the                                              New residences under construction in the
                                          obtained from a combination of public
future, NHPF plans to create 3,000                                                  Walnut Square redevelopment.
                                          and private sources, as well as grants
affordable units in the Gulf Coast
                                          from philanthropic entities. These
area at a total cost of $300 million.
                                          financial partners include Louisiana,
                                                                                    Making Progress
The 2005 Gulf Opportunity Zone Act        Bank of America, Capital One, The         NHPF’s work in the Gulf Coast
defines the entire three GO Zones for     Ford Foundation, NeighborWorks            region has allowed residents not
Katrina, Rita, and Wilma as difficult     America, and the Bush-Clinton Katrina     only to obtain affordable and safe
development areas (DDA) for the           Fund. The property is scheduled to        housing but to begin to rebuild their
purposes of the LIHTC program (see        be completed in December 2008.            lives and their communities. These
sidebar on page 11). This definition                                                efforts required the support of banks
                                          NHPF’s post-hurricane rebuilding
increases the amount on which tax                                                   and other financial partners. NHPF
                                          extends beyond properties in New
credits are calculated to 130 percent                                               sees appropriately priced equity and
                                          Orleans. NHPF also plans to purchase
of new construction or rehabilitation                                               below-market rate predevelopment
                                          1,115 affordable units in Baton Rouge
expenditures. Outside of DDAs,                                                      loans for projects in the Gulf Coast
                                          and Lake Charles to prevent those
tax credits are calculated on 100                                                   region as major areas that banks
                                          units from being converted to market
percent of these expenditures.                                                      can best contribute to the needs for
                                          rate. These rental units will be used
This tax-credit provision temporarily                                               affordable multifamily housing.
                                          to maintain affordable housing to
adds to the value of LIHTC used to        help meet the demand created by the       It is important for banks and other
create or replace affordable rental       thousands of relocated families.          investors to be patient partners,
housing throughout these GO Zones.                                                  because arranging the financing
                                          The acquisition and rehabilitation will
Before 2006, Louisiana and the                                                      for affordable housing projects is
                                          be financed using 501(c)(3) bonds,
affected areas of Mississippi did                                                   a complicated and time-intensive
                                          which will require these units to
not contain DDAs. The expiration                                                    process in the best of conditions.
                                          remain affordable in the long term.
of this provision at the end of 2010
                                          Seventy-five percent of the units must    In return, NHPF, through its
may reduce the areas in the Gulf
                                          be rented to families earning below       strong construction and property
Coast likely to receive LIHTC
                                          80 percent of the area median income,     management history, offers its
investments because, at best, only
                                          and 20 percent of the units must be       investors financial return and
some small subset of the GO Zones
                                          rented to families earning below 50       enhanced community relations by
will likely remain defined as DDAs.
                                          percent of the area median income.        participating in projects that may
Rebuilding After the                                                                also receive positive Community
                                          In addition to 501(c)(3) bonds, NHPF
Storm: Walnut Square                                                                Reinvestment Act consideration
                                          will employ LIHTC, traditional
                                                                                    and the satisfaction of assisting in
One of NHPF’s most ambitious post-        loans, philanthropic support from
                                                                                    the recovery of the Gulf Coast.
hurricane projects is the redevelopment   corporations and foundations, as
                                          well as program-related investments.      For more information, contact
of the 11-acre Walnut Square in New                                                 Ghebre Selassie Mehreteab at
Orleans East (see photos above).          NHPF plans to increase its portfolio
                                                                                    GMehreteab@nhpfoundation.org.
NHPF is working to revitalize Walnut      significantly over the next few years
Square and convert it to a mixed-use      and has several projects in progress.




Fall 2008                                                                                                                       27
Section 3: How Nonprofits Contribute to the Recovery Effort


                                Enterprise Community Partners Provides
                                 Immediate and Long-Term Assistance


     E
            nterprise Community Partners arrived in the              to sell to people with low to moderate incomes. This is
            Gulf Coast following the hurricanes of 2005              a part of Mississippi’s Long Term Workforce Housing
            prepared to provide disaster relief to dislocated        program, which is one component of the state’s
     families and technical assistance to local leaders.             recovery program funded with a special allocation of
                                                                     federal community development block grant funds.
     Enterprise has committed to working with local partners
     to invest $200 million in the Gulf Coast to build 10,000        Banks with single-family foreclosure properties in
     affordable homes. To date, Enterprise’s efforts have led        the Gulf Coast can work with such nonprofits as
     to $63 million invested through low-income housing tax          Enterprise to return those homes to productive
     credit (LIHTC) equity and more than $14.5 million in loans      use by participating in bulk-rate purchasing
     and grants. These investments include nine developments         agreements for the foreclosed homes.
     for families and seniors in Louisiana and Alabama               For more information, visit www.enterprisecommunity.org.
     that will provide homes for nearly 750 households.              To contact Enterprise’s office in the Gulf Coast, call Local Office
     One of Enterprise’s major commitments in New Orleans is         Director Michelle Whetten at (504) 821-7242. For further information
     to the Lafitte public housing redevelopment in the historic     on how banks can contribute to Enterprise’s investment funds on a
     Tremé neighborhood. With local partner Providence               regional or national scale, contact Doug Able, Senior Vice President
     Community Housing, Enterprise has promised one-to-one           of Capital Markets for Enterprise Community Investment, at
                                                                     (410) 772-6005.
     replacement of all affordable units lost to storm damage.

     The project is expecting to require $100 million in
     LIHTC equity and is designed to ensure that the
     homes will be affordable, safe, and environmentally
     and economically sustainable. The mixed-
     income development will include market-rate and
     subsidized rental housing and for-sale units.

     Banks and other investors can enhance this and similar
     efforts by investing in tax credits and construction
     lending, supporting homeowner assistance programs
     and financial training, and providing single-family
     mortgages suitable for residents’ incomes.

     Enterprise created the Louisiana Loan Fund in
     conjunction with Louisiana and the Local Initiatives
     Support Corporation (LISC), drawing from Enterprise’s
     experiences in managing similar funds in other states.
     The $47 million fund offers predevelopment and
     acquisition financing to developers that are rebuilding
     affordable homes destroyed by the hurricanes.

     The fund recently approved its first acquisition loan
     for $3 million to the Renaissance Neighborhood
     Development Corporation to acquire property for a new
     mixed-income, high-rise development on the banks
     of the Mississippi River. Banks and other investors
     can increase the fund’s impact by providing take-out
     financing for projects using the fund. This will help recycle
     fund resources so more developers can participate.
                                                                                                                               Enterprise
     Mississippi recently awarded Enterprise $20 million to           Redevelopment of St. Martin Manor, a historic 140-unit
     purchase and rehabilitate 300 bank-owned properties              senior residence damaged by Hurricane Katrina.




28                                                                                                           Community Developments
Compliance Corner: Recent CRA Amendments and Agency Guidance
Kristopher M. Rengert, Community Development Expert, OCC



T
         he combination of the expanded    stabilize a designated disaster area      activities that occur in the broader
         definition of community           if it helps to attract new, or retain     statewide or regional areas surrounding
         development from the 2005         existing, businesses or residents and     a bank’s assessment area may also
amendments to the Community                is related to disaster recovery.          receive positive consideration.
Reinvestment Act (CRA) regulations         Additionally, an activity will be         However, owing to the unprecedented
and the geographic flexibility for         considered to revitalize or stabilize     impacts from hurricanes Katrina
consideration of CRA-related               a designated disaster area if it is       and Rita, examiners have been
activities in the hurricanes Katrina       consistent with a bona fide government    given additional flexibility when
and Rita-designated disaster areas         revitalization or stabilization plan or   evaluating the geographic aspect
enhances the ability of banks to           disaster recovery plan. Accordingly,      of CRA-related activities in these
receive positive CRA consideration         examiners give greater weight to          particular designated disaster areas.
for support of the Gulf Coast recovery     activities that are most responsive       OCC Bulletin 2006-6, “Community
effort. This article discusses the CRA     to community needs, including the         Reinvestment Act: Hurricanes Katrina
treatment of types of investments          needs of low- or moderate-income          and Rita,” provides guidance regarding
banks might make in support of             individuals or neighborhoods.             how national banks located outside
recovery from major disasters.
                                           Activities that may qualify for           the designated disaster areas may
Community Development                      consideration as revitalizing             receive positive CRA consideration
Redefined                                  or stabilizing a designated               for activities that revitalize or
                                           disaster area include:                    stabilize the designated disaster areas
Effective September 1, 2005, the CRA                                                 related to those hurricanes (provided
regulations expanded the definition        •   Financing to help retain
                                               businesses in the area that           that the banks have otherwise
of community development for the                                                     adequately met the CRA-related
purposes of the CRA. The definition            employ local residents,
                                               including low- and moderate-          needs of their assessment area).
added consideration for activities
that revitalize or stabilize designated        income individuals.                   In this regard, national banks may
disaster areas to the list of community    •   Financing to attract a major,         provide CRA-related activities directly
development activities qualified for           new employer that will create         or through a third party. A national
positive CRA consideration. Such               long-term job opportunities,          bank also may receive positive
disaster areas must be “major disaster         including for low- and                consideration for activities benefiting
areas” as designated by the federal            moderate-income individuals.          people who have been displaced
government, typically the Federal                                                    by these hurricanes, including
                                           •   Financing for essential
Emergency Management Agency.                                                         evacuees relocated to other states.
                                               communitywide infrastructure,
These qualifying activities will               community services, and               CRA consideration for qualified
be considered by examiners for                 rebuilding needs.                     activities benefiting the designated
36 months following the date of                                                      disaster areas related to hurricanes
                                           •   Activities that provide housing,
designation, although this period                                                    Katrina and Rita should be discussed in
                                               financial assistance, and services
may be extended when there is a                                                      the narrative section of a bank’s public
                                               to individuals in designated
demonstrable community need to                                                       performance evaluation if they are
                                               disaster areas and to individuals
assist in long-term recovery efforts.                                                outside of the bank’s assessment area.
                                               who have been displaced from
For the Gulf Coast, this period was            those areas, including low- and       The OCC’s District Community Affairs
recently extended until 2011.                  moderate-income individuals.          Officers (DCAOs) can provide technical
In March 10, 2006, the OCC, along                                                    assistance to national banks seeking
                                           Geographic Flexibility                    further information about how their
with other financial regulators, issued
interagency guidance on this additional    CRA performance is evaluated              support of the recovery effort in the
CRA consideration. The 2006 CRA            primarily in the context of how its       Gulf Coast region might receive positive
Q&As explained that an activity            CRA-related activities help meet credit   CRA consideration.
will be considered to revitalize or        and community development needs in        DCAO information can be found at
                                           a bank’s assessment area. CRA-related     www.occ.treas.gov/cdd/contacts.htm.



Fall 2008                                                                                                                  29
This Just in ... the OCC’s Districts Report on New Opportunities for Banks
                       Vonda Eanes (704) 554-7082                              Central District    Paul Ginger (312) 360-8876
                       Bonita Irving (617) 854-6547                                                Norma Polanco-Boyd (216) 447-8866
                       Denise Kirk-Murray (212) 790-4053

                       Affordable Housing                                                         Low-Income Housing Tax
     Northeastern
       District        Assistance in Rhode Island                                                 Credit Investing for Indiana
                                                                                                  Community Banks
Rhode Island Housing is a statewide public housing agency focused
on creating and preserving affordable owner-occupied and rental            The Indiana Community Investor Fund (ICIF) is a new low-income
housing in Rhode Island. The agency offers below-market interest           housing tax credit (LIHTC) pool designed with several features
rate loans and home-buyer education classes for first-time home            intended to have particular appeal for community banks in Indiana.
buyers. To encourage homeownership, the agency offers special
financing options for home buyers purchasing homes in certain              ICIF has a $250,000 minimum investment requirement, which is
targeted communities within the state.                                     low compared with other LIHTC funds, and ICIF will invest only in
                                                                           affordable housing developments in Indiana. ICIF was developed
Rhode Island Housing provides a number of loan programs and                by the Great Lakes Capital Fund (GLCF), a 15-year-old regional
services to existing homeowners to assist them in maintaining and          nonprofit LIHTC syndicator that has placed $1.2 billion of equity
retaining their homes. The agency also oversees the management             in 325 development projects, creating more than 19,000 units of
of a number of affordable rental apartments for low-income senior          affordable housing and 100,000 square feet of commercial space in
citizens and families, and for persons with disabilities.                  Illinois, Indiana, Michigan, and Wisconsin.
Rhode Island Housing offers loan products and services that can            Among the 24 investors in the other funds of GLCF are approximately
be used by participating lenders to increase access to affordable          20 banks, including some of the largest banks in the country as
housing. The agency also issues single-family and multifamily taxable      well as regional and community banks, all of which have invested at
and tax-exempt bonds and administers the federal Low-Income                various levels, and many of which have invested multiple times.
Housing Tax Credit, HOME, and Section 8 Voucher programs.
                                                                           For more information, visit www.capfund.net or contact Fred Hash at
For more information, contact Rhode Island Housing at (401) 457-1234, or   fhash@capfund.net. Also, contact Mark McDaniel at capmac@capfund.net or
visit www.rhodeislandhousing.org.                                          (317) 423-8880.


Foreclosure Assistance in New Jersey                                       Wealth+Education+Collaboration+
HANDS Inc., a local New Jersey community development                       Opportunity=WECO Fund in Ohio
corporation, is taking a leadership role in reducing the community
impact of foreclosures. HANDS (Housing & Neighborhood                      The WECO Fund, a community and economic development
Development Services) is leading a task force in Essex County that is      agency, was established in 1971 in Cleveland, Ohio. Through a
working to develop a new special-purpose entity, Community Asset           continuum of comprehensive services, participants receive financial
Preservation Corporation (CAPC).                                           education, long-term support, and access to capital. WECO runs the
CAPC is designed to preserve homes and prevent a decline in                Microentreprise Center that, aside from entrepreneurship training,
communities from foreclosures. It would address the blight caused          administers a number of “microloan” funds.
by foreclosed, vacant properties. CAPC will identify communities           WECO allows banks to provide community development loans by
affected by subprime mortgage foreclosures and negotiate with              lending to the fund. Typical terms are at four years and interest-
the lenders and servicers to purchase, at a discount, pools of the         free loans. In addition, WECO administers a statewide individual
vacant and at-risk properties in the targeted area. The initial target     development account (IDA) program. IDAs are matched savings
is to acquire title to 1,000 to 1,500 properties. CAPC is expected to      accounts that enable low- and moderate-income families to save and
develop relationships with realtors, lenders, servicers and property       build assets. WECO is seeking $250,000 in private funds to match its
management companies.                                                      public funds.
HANDS has also developed a pilot program called, “Time is the
                                                                           For more information, contact Christine Henry, Executive Director, at
Enemy.” With this program, the organization will partner with one
                                                                           (216) 458-0250 or christine@wecofund.com.
lender at a time, which holds a number of foreclosed properties in a
targeted area. HANDS will work with that lender to develop solutions
to minimize the impact of the foreclosures on the neighborhoods.
The community organization will purchase the mortgages from the
lender, service the loans, and manage the properties, ensuring that
the properties remain affordable.
For more information, visit www.handsinc.org.




30                                                                                                                Community Developments
                       Scarlett Duplechain (504) 828-6555                                             Susan Howard (818) 240-5175
    Southern
      District         Karol Klim (678) 731-9723 x252                                                 Dave Miller (720) 475-7670
                       David Lewis (214) 720-7027

                       Small Business                                                                 A Growing Loan Pool in
                                                                                Western District
                       Financing Tool Debuts                                                          Washington State
                       in Baton Rouge
                                                                                In 1990, a group of 19 Washington state financial institutions joined
Baton Rouge, Louisiana, announced a new tool to assist small                    together to create a revolving, shared-risk loan pool to provide a
businesses with start-up or operating capital. The Small Business               renewable source of permanent financing for multifamily affordable
Loan Fund provides a nontraditional source of financing and targets             housing, as well as to reduce the underwriting and administrative
especially women and minority entrepreneurs. The loan fund provides             costs for this complex financing.
below-market-rate loans ranging from $5,000 up to $150,000, with                In 1992, this shared-risk loan pool began operation as the
flexible repayment terms.                                                       Washington Community Reinvestment Association (WCRA). Today,
The fund is intended to aid in stimulating the city’s current economic          membership has grown to 46 financial institutions, and the original
development efforts and create or preserve jobs by providing flexible           loan pool has been expanded into three lending pools, raising
financing, helping to make East Baton Rouge Parish a stronger                   WCRA’s lending capacity to $105 million.
market for entrepreneurs. The new fund does not compete with                    Since 1992, the WCRA has funded and committed to $199 million in
existing funding sources but is designed to enhance the financial               loans representing nearly 8,000 units of affordable housing and nearly
services already available to small businesses.                                 30,000 square feet of economic development projects throughout the
The initial funding pool of $2.5 million was supplied by seven banks            state of Washington.
and credit unions, Seedco Financial Services, the city of Baton                 WCRA provides multifamily permanent loans, special needs
Rouge, and other corporations. The loan fund is actively seeking                financing, assisted living financing, and economic development
additional loan capital. The fund is managed by Seedco Financial                loans. It also makes available tax-exempt bond financing for
Services, a national nonprofit community development financial                  affordable housing and economic development. Investor banks have
institution.                                                                    also provided construction and bridge financing for WCRA-funded
For more information, contact Robin Barnes at (504) 520-5727 or                 projects.
rbarnes@seedco.org.                                                             For more information, contact WCRA’s President Susan M. Duren at
                                                                                (800) 788-6508 or visit www.wcra.net.

Lone Star CRA Fund in Dallas
This private investment partnership is being formed to make                     REACH CDC in Portland, Oregon
$5 million to $15 million equity-oriented investments in middle-market          REACH CDC Inc. is one of the most successful affordable housing
Texas-based companies.                                                          providers in Portland, Oregon. REACH focuses on providing
As of June 2008, the Lone Star CRA Fund LP (LS CRA) has total                   affordable rental housing targeted at low-income residents of
capital commitments of $57.5 million out of a goal of $75 million. All          Portland, many of whom were previously homeless.
of the funds committed to the LS CRA partnership will be invested in
                                                                                The projects range from single-room-occupancy structures and
companies located in low-income areas of Texas.
                                                                                multifamily properties to single-family housing. REACH develops and
The fund intends to bring jobs to low-income areas by investing in              manages its projects throughout the city. Since its inception in 1986,
companies already located there or by acquiring businesses and                  REACH has added more than 1,000 units to the city’s affordable
moving them to low-income areas. LS CRA expects to complete                     housing stock. However, the organization is considering expanding
fundraising during the balance of 2008 and plans to invest in seven to          its services into the surrounding areas.
10 Texas-based companies.
                                                                                In addition to its housing efforts, REACH runs a home-repair program
For more information, contact Arthur W. Hollingsworth, Managing Partner, Lone   called the Community Builders Program for homeowners who have
Star New Markets LP, at (972) 702-7390.                                         low income or are disabled. To date, more than 3,500 repairs have
                                                                                been provided for more than 1,000 families. REACH also provides
                                                                                other services for its tenants including job training and an individual
                                                                                development account or IDA program for its teen residents called
                                                                                YouthSave, which provides financial literacy and matched savings
                                                                                accounts.
                                                                                REACH’s program support comes from public and private
                                                                                partnerships including loans, investments, such as equity equivalent
                                                                                investments, and grants from local government, financial institutions,
                                                                                and philanthropic organizations. The organization continues to
                                                                                entertain new partnership opportunities especially in construction
                                                                                and permanent financing for new developments.
                                                                                For more information, visit www.reachcdc.org.



Fall 2008                                                                                                                                           31
       Comptroller of the Currency
       Administrator of National Banks

       US Department of the Treasury




  What’s Inside
     Comptroller Dugan on How Banks Are Supporting the Recovery Effort in the Gulf Coast

     Articles on the Gulf Coast Recovery Landscape
       •	 Louisiana Recovery Authority
       •	 Support for Homeownership

     Articles on Banks and Their Private-Sector Partners Investing in Recovery
       •	 Whitney National Bank
       •	 Capital One
       •	 Wisznia Associates

     Articles on Nonprofit Organizations Rebuilding in the Gulf Coast
       •	 NeighborWorks America
       •	 NHP Foundation

     Compliance Corner—CRA and Recovery Efforts in Federally Designated Disaster Areas

     The OCC’s Districts Report on New Opportunities for Banks




Visit the OCC’s Web site—www.occ.treas.gov/cdd/resource.htm—for additional information.

				
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