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U.S. Department of the Treasury, Emergency Capital Investment Program: "2022 Investing for Impact Report highlighting top Deep Impact Lending Performers"

Summary

The Emergency Capital Investment Program's Investing for Impact Report on Lending in 2022, dated March 29, 2024, built from the Quarterly Supplemental Reports that participants submit to Treasury. It states that through the ECIP, Treasury invested more than $8.5 billion in CDFIs and MDIs, including $3.2 billion in MDIs. During 2022, from each institution's closing date through year end, participants originated approximately $24.4 billion in loans, of which about 73 percent, or $17.8 billion, was Qualified Lending, Deep Impact Lending, or both, and approximately $8.3 billion was Deep Impact Lending. It lists the Top 25 ECIP Participants by Deep Impact Lending as a percentage of total originations, among them Latino Community Credit Union and Asian Financial Corporation.

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“U.S. Department of the Treasury, Emergency Capital Investment Program: ‘2022 Investing for Impact Report highlighting top Deep Impact Lending Performers.’” Original at home.treasury.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/u-s-department-of-the-treasury-emergency-capital-investment-program-20-7e9f2d2d39/, SHA-256 471cddb2a597c080a5912743ba0ab632e773eca7e960e6a34d2816c2586ea9d9.

Full text

March 29, 2024


                  Emergency Capital Investment Program: Investing for Impact
                                         Report on Lending in 2022


The following report presents 2022 lending information for institutions participating in the Emergency
Capital Investment Program (ECIP). ECIP was created by the Consolidated Appropriations Act, 2021 to
support eligible mission-driven institutions in their lending to financially underserved borrowers and
communities. The statute authorized Treasury to make ECIP investments in community financial
institutions, which include federally insured banks, savings and loan associations, holding companies, and
credit unions that are certified as community development financial institutions (CDFIs) by Treasury’s
CDFI Fund or designated as minority depository institutions (MDIs) by their federal regulator.
This report is based on data submitted by ECIP participants to Treasury in their Quarterly Supplemental
Reports (QSRs). The information contained in this report reflects the data as of the date indicated in each
table. This report may be updated from time to time to reflect data corrections and revisions. Readers are
encouraged to access this report on Treasury’s ECIP website to ensure they are reviewing the most recent
version of the report.


I.     Program Overview
Through the ECIP, Treasury invested more than $8.5 billion in CDFIs and MDIs, including $3.2 billion in
MDIs. Community financial institutions have the relationships needed to deliver responsible capital,
credit, and services to financially underserved communities that the statute seeks to benefit, including
low- and moderate-income (LMI), minority, and rural communities. Unlike some past federal investment
programs that were aimed at stabilizing financial institutions in a time of economic stress, the ECIP is
designed to work through these CDFIs and MDIs to deliver loans and other investments to underserved
communities that were particularly impacted by the COVID-19 pandemic.
Under the ECIP, Treasury invested in preferred stock or subordinated debt issued by participating CDFIs
or MDIs. Beginning two years after issuance, the investments carry a maximum dividend or interest rate
of 2 percent. Participating institutions may qualify for a reduction in this interest or dividend rate by
increasing their “Qualified Lending” compared to a pre-ECIP baseline period. Qualified Lending
includes lending to minority, rural, urban low-income, and underserved communities, LMI borrowers,
and other similar lending as outlined in the ECIP Rate Reduction Incentive Guidelines. 1 When ECIP
participants engage in “Deep Impact Lending,” Treasury will provide additional credit toward this rate
reduction. Deep Impact Lending, also outlined in the ECIP Rate Reduction Incentive Guidelines, includes
loans to Low-income Borrowers 1 and Underserved Businesses, for Deeply Affordable Housing, and in
Persistent Poverty Counties, among others. 2 The additional credit recognizes the fact that the kind of
lending that will be most impactful in achieving the statutory purpose of the program often requires more

1
  ECIP Rate Reduction Incentive Guidelines. For additional information, please see the QSR instructions for Credit
Unions and Insured Depository Institutions and Holding Companies (collectively, the QSR Instructions). “Qualified
Lending” is a subset of Lending Activity. Lending Activity is considered Qualified Lending if it is made to one of the
Target Communities listed in Table 1–Target Communities in the QSR Instructions.
1
  Defined terms used but not defined in this document have the meanings set forth in the QSR Instructions.
2
  “Deep Impact Lending” is a subset of Qualified Lending. Lending Activity is considered Deep Impact Lending if it
is made to one of the Target Communities listed in Table 1–Target Communities in the QSR Instructions.

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March 29, 2024


time and resources from the lender. This approach is designed to help level the playing field for borrowers
that face the greatest barriers to accessing capital and will provide greater transparency into the impact of
the program.


II.       Total, Qualified, and Deep Impact Lending
An ECIP participant’s lending activity is considered Qualified Lending or Deep Impact Lending if it is
made to one of the Target Communities listed in Table 1 below. Deep Impact Lending, a subset of
Qualified Lending, represents the hardest-to-serve borrowers, including Low-Income Borrowers,
minority-owned businesses, and residents of Tribal lands and US territories. A full description of the
Qualified and Deep Impact Lending categories can be found in the QSR Instructions.

Table 1: Qualified and Deep Impact Lending Categories
 Categories of Target
                             Qualified Lending                        Deep Impact Lending
 Communities
                             • LMI Borrowers                          • Low-income Borrowers
 People                      • Other Targeted Populations             • Mortgage Lending to Other
                                                                        Targeted Populations
                             • Rural Communities                      • Persistent Poverty Counties
                             • Urban Low-Income Communities           • Indian Reservations and Native
 Places
                             • Underserved Communities                  Hawaiian Homelands
                             • Minority Communities                   • US Territories
                             • Qualified Businesses, including        • Underserved Businesses
 Businesses
                               Small Businesses or Farms
                             • Affordable Housing                     • Deeply Affordable Housing
                             • Public Welfare and Community           • Public Welfare and Community
 Borrowers or projects
                               Development Investments if they          Development Investments if they
 that create direct
                               primarily benefit LMI Borrowers          primarily benefit Low-income
 benefits for LMI
                               or communities, Minority                 Borrowers, Minority borrowers,
 communities or Other
                               borrowers, or Minority                   or Minority Businesses
 Targeted Populations
                               Businesses
                             • Community Service Facility

Treasury started funding investments in ECIP participants at the end of April 2022 and closed
approximately 91 percent of investments, representing 92 percent of total dollars invested, by the end of
June 2022. During 2022, for the period from each institution’s closing date through year end, ECIP
participants originated a total of approximately $24.4 billion in loans, of which about 73 percent, or $17.8
billion, was Qualified Lending, Deep Impact Lending, or both. Approximately one third of ECIP
participants’ total originations during this time, or $8.3 billion, was Deep Impact Lending, a subset of
Qualified Lending, as shown in Figure 1 below.




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March 29, 2024


                                Figure 1: 2022 Lending by ECIP Recipients1
                                                                            Lending by Number of
        Lending by Amount (Million $)
                                                                                Originations




                                    $6,556                                                      148,889
                $8,302
                                                                               246,078




                              $9,526                                                           325,871




   Other Lending Activity                                         Other Lending Activity

   Qualified Lending other than Deep Impact Lending               Qualified Lending other than Deep Impact Lending

   Deep Impact Lending (a subset of Qualified Lending)            Deep Impact Lending (a subset of Qualified Lending)

1 Data presented is based on Quarterly Supplemental Report submissions as of March 29, 2024.




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March 29, 2024


Table 2 below shows originations by ECIP recipients between the date of each institution’s ECIP
investment and December 31, 2022 by the Call Report lending category for which data was collected.
Note that Qualified Lending originations in this table include only Qualified Lending that is not also Deep
Impact Lending.

                    Table 2: Summary of 2022 Qualified and Deep Impact Lending
                                                                       Qualified Lending                 Deep Impact Lending
                                       Total Originations1
                                                                          Originations                        Originations
       Lending Activity
                                       # of             $ in           # of            $ in                # of            $ in
         Categories
                                   Originations       Millions     Originations     Millions           Originations     Millions
                                        (A)             (B)             (C)            (D)                  (E)            (F)
                                                           Credit Unions
 Non-commercial loans/lines
                                     392,274           $9,346          141,313            $3,930         170,428           $2,645
 of credit2
 Commercial loans/lines of
                                       1,826            $926              804             $477              593             $151
 credit
 Total                               394,100          $10,271        142,117              $4,407         171,021           $2,796
                                                   IDIs and Holding Companies
 Loans secured by
 constructions, land
                                       4,058           $2,609            1,157            $911             1,642           $1,003
 development, and other
 land loans
 Loans secured by farmland             1,153            $401              336             $120              705             $228
 Loans secured by 1-4 family
 residential properties               13,148           $3,537            3,904            $966             6,376           $1,510

 Loans secured by
 multifamily (5 or more)                476            $1,117             235             $536              173             $351
 residential properties
 Loans secured by nonfarm
 nonresidential properties             2,854           $3,162            1,069            $1,444           1,389           $1,069

 Loans to finance agricultural
 production and other loans            1,972            $449              334              $60             1,558            $373
 to farmers
 Commercial and industrial
                                       9,641           $1,855            2,817            $725             5,630            $639
 loans
 Loans to individuals for
 household, family, and other        293,377            $965           173,890            $346            57,576            $332
 personal expenditures
 Lease financing receivables            25               $13              11               $10               6               $1
 Direct and indirect
 investments in real estate              3              $1.5               0               $0                1              $1.5
 ventures
 Equity investments without
 readily determinable fair              31              $3.5               1               $0.1              1               $1
 values
 Total                               326,738          $14,113          183,754            $5,120         75,057            $5,506
 ECIP Total                          720,838          $24,384          325,871            $9,526         246,078           $8,302
1 Data presented is based on submissions as of March 29, 2024 and is subject to change.
2 Non-commercial loans include real estate loans, auto loans, and personal credit such as unsecured credit cards and other secured

and unsecured loans.




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March 29, 2024


      III.       Top 25 ECIP Participants by Dollar Amount of Deep Impact Lending as a Percentage
                 of Total Originations in 2022 (listed alphabetically): 3

                Asian Financial Corporation (PA)
                Caldwell Holding Company (LA)
                Carson Financial Holding Company Inc. (OK)
                Centric Federal Credit Union (LA)
                CheckSpring Community Corporation (NY)
                Commerce Bancorp Inc. (MS)
                Community First Guam Federal Credit Union (GU)
                First Antlers Bancorporation Inc. (OK)
                Gibsland Bancshares, Inc. (LA)
                Grandview Bankshares, Inc. (OK)
                Homeland Bancshares Inc. (LA)
                Hope Federal Credit Union (MS)
                Latino Community Credit Union (NC)
                Lone Star National Bancshares (TX)
                Mechanics Banc Holding Company (MS) 4
                Millennium Bancorp, Inc. (IL)
                New Covenant Dominion Federal Credit Union (NY)
                Pyramid Financial Corporation (MS)
                Rio Financial Services, Inc. (TX)
                Security Bancshares Corporation (OK)
                Self-Help Federal Credit Union (CA)
                Sisseton-Wahpeton Federal Credit Union (SD)
                South Texas Federal Credit Union (TX)
                The Native American Bancorporation Co. (CO)
                TNB Bancshares (TX)




3
    This list does not include any ECIP participants that requested not to be included on such lists.
4
    Mechanics Banc Holding Company was acquired by BankFirst Capital Corporation after December 31, 2022.

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March 29, 2024


    IV.      Top ECIP Participants by Dollar Amount of Lending to Specific Targeted Communities
             in 2022 (listed alphabetically) 5
Lending to Low-income Borrowers: 6
By total dollar amount of lending as a percentage of total originations:
            Afena Federal Credit Union (IN)
            Alternatives Federal Credit Union (NY)
            Central Willamette Credit Union (OR)
            City Federal Credit Union (TX)
            Commodore Perry Federal Credit Union (OH)
            Community Plus Federal Credit Union (IL)
            DC Federal Credit Union (DC)
            Episcopal Community Federal Credit Union (CA)
            Genesee Co-op Federal Credit Union (NY)
            Holy Rosary Credit Union (MO)
            Latino Community Credit Union (NC)
            Members Credit Union, Inc. (CT)
            MERCO Credit Union (CA)
            Newrizon’s Federal Credit Union (WA)
            Peninsula Community Federal Credit Union (WA)
            Self-Help Federal Credit Union (CA)
            Sisseton-Wahpeton Federal Credit Union (SD)
            SkyPoint Federal Credit Union (MD)
            Toledo Urban Federal Credit Union (OH)
            Turner Bancshares, Inc. (TX)


By total dollar amount of lending:
            Beneficial State Bancorp, PBC (CA)
            Central Willamette Credit Union (OR)
            Commerce Bancorp, Inc. (MS)
            ELGA Credit Union (MI)
            Financial Partners Credit Union (CA)
            Freedom First Federal Credit Union (VA)
            Heritage Financial Credit Union (NY)
            Lake Trust Credit Union (MI)
            Latino Community Credit Union (NC)
            Leader Bancorp, Inc. (MA)
            Leaders Credit Union (TN)
            Local Government Federal Credit Union (NC)
            Marine Federal Credit Union (NC)
            NMB Financial Corporation (NJ)

5
  These lists do not include any ECIP participants that requested not to be included on such lists.
6
  “Low-income Borrower” means having an income of not more than: (1) for borrowers in Metropolitan Areas, 80%
of the area median income; and (2) for borrowers in Non-Metropolitan Areas, the greater of 80% of the area median
income or 80% of the statewide Non-Metropolitan Area median income.

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March 29, 2024


            Orange County’s Credit Union (CA)
            REV Federal Credit Union (SC)
            Security Credit Union (MI)
            Self-Help Federal Credit Union (CA)
            Suncoast Credit Union (FL)
            Texas Bay Credit Union (TX)


Lending to Other Targeted Populations: 7
By total dollar amount of lending as a percentage of total originations:
            Bright Force Holding, Inc. (TX)
            Broadway Financial Corporation (DC)
            City Federal Credit Union (TX)
            Community First Guam Federal Credit Union (GU)
            Genesee Co-op Federal Credit Union (NY)
            Hope Federal Credit Union (MS)
            Kauai Federal Credit Union (HI)
            Latino Community Credit Union (NC)
            Liberty Financial Services, Inc. (LA)
            Lower East Side People’s Federal Credit Union (NY)
            M&F Bancorp, Inc. (NC)
            Members Credit Union, Inc. (CT)
            Millennium Bancorp, Inc. (IL)
            NMB Financial Corporation (NJ)
            One World Holding, Inc. (TX)
            PrimeWay Federal Credit Union (TX)
            Rio Financial Services, Inc. (TX)
            Self-Help Credit Union (NC)
            Self-Help Federal Credit Union (CA)
            Sisseton-Wahpeton Federal Credit Union (SD)


By total dollar amount of lending:
            Bright Force Holding, Inc. (TX)
            Broadway Financial Corporation (DC)
            Community Bank of the Bay (CA)
            Community First Guam Federal Credit Union (GU)
            Latino Community Credit Union (NC)
            Leader Bancorp, Inc. (MA)
            Leaders Credit Union (TN)
            Liberty Financial Services, Inc. (LA)
            Lone Star National Bancshares (TX)


7
  “Other Targeted Populations” means Minorities and, solely for CDFIs, populations designated as Other Targeted
Populations for that CDFI pursuant to any regulation issued by the CDFI Fund. “Minority” means any Black
American, Native American, Hispanic American, Asian American, Native Alaskan, Native Hawaiian, or Pacific
Islander.

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March 29, 2024


         Millennium Bancorp, Inc. (IL)
         NMB Financial Corporation (NJ)
         One World Holding, Inc. (TX)
         Orange County’s Credit Union (CA)
         PCB Bancorp (CA)
         Ponce Financial Group, Inc. (NY)
         PrimeWay Federal Credit Union (TX)
         Self-Help Credit Union (NC)
         Self-Help Federal Credit Union (CA)
         Suncoast Credit Union (FL)
         TNB Bancshares (TX)




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March 29, 2024


      V.       Top ECIP Participants by Dollar Amount of Lending to Underserved Businesses in
               2022 (listed alphabetically):


Lending to Minority Businesses 8 (other than Hispanic-owned businesses):

By total dollar amount of lending as a percentage of total originations:
            Asian Financial Corporation (PA)
            Citizens Bancshares Corporation (GA)
            IBW Financial Corporation (DC)
            M&F Bancorp, Inc. (NC)
            Millennium Bancorp, Inc. (IL)
            Ponce Financial Group, Inc. (NY)
            The Native American Bancorporation Co. (CO)

By total dollar amount of lending:
            Asian Financial Corporation (PA)
            Broadway Financial Corporation (CA)
            Citizens Bancshares Corporation (GA)
            IBW Financial Corporation (DC)
            Millennium Bancorp, Inc. (IL)
            Ponce Financial Group, Inc. (NY)
            Southern Bancorp, Inc. (AR)

Lending to Hispanic-owned businesses:

By total dollar amount of lending as a percentage of total originations:
            Asian Financial Corporation (PA)
            Banesco USA (FL)
            Commerce Bancorp, Inc. (MS)
            Hope Federal Credit Union (MS)
            Lone Star National Bancshares (TX)
            Rio Financial Services, Inc. (TX)
            TNB Bancshares (TX)


By total dollar amount of lending:
            Asian Financial Corporation (PA)
            Banesco USA (FL)
            Community Bank of the Bay (CA)
            Lone Star National Bancshares (TX)
            Ponce Financial Group, Inc. (NY)
            Rio Financial Services, Inc. (TX)
            TNB Bancshares (TX)




8
    “Minority Business” means a business or farm that is majority-owned by a Minority.

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March 29, 2024




Lending to businesses with less than $100,000 in annual revenue:

By total dollar amount of lending as a percentage of total originations:
            Asian Financial Corporation (PA)
            CheckSpring Community Corporation (NY)
            Citizens Corporation (MS)
            FSB Bancshares, Inc. (OK)
            Millennium Bancorp, Inc. (IL)
            Security Bancshares Corporation (OK)
            Stark Bancshares, Inc. (MO)

By total dollar amount of lending:
            BankFirst Capital Corporation (MS)
            Grant Bancshares, Inc. (LA)
            Lone Star National Bancshares (TX)
            Millennium Bancorp, Inc. (IL)
            Planters Holding Company (MS)
            Security Bancshares Corporation (OK)
            Southern Bancorp, Inc. (AR)




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March 29, 2024


    VI.      Top ECIP Participants by Dollar Amount of Place-Based Lending in 2022 (listed
             alphabetically):


Lending to Persistent Poverty Counties: 9
By total dollar amount of lending as a percentage of total originations:
            Carson Financial Holding Company, Inc. (OK)
            Centric Federal Credit Union (LA)
            Commerce Bancorp, Inc. (MS)
            Pyramid Financial Corporation (MS)
            Rio Financial Services, Inc. (TX)
            South Texas Federal Credit Union (TX)
            TNB Bancshares (TX)


By total dollar amount of lending:
            BancPlus Corporation (MS)
            Banesco USA (FL)
            BankFirst Capital Corporation (MS)
            Commerce Bancorp, Inc. (MS)
            Guaranty Capital Corporation (MS)
            Lone Star National Bancshares (TX)
            Ponce Financial Group, Inc. (NY)

Lending to US Territories: 10
By total dollar amount of lending as a percentage of total originations:
            Banesco USA (FL)
            Community First Guam Federal Credit Union (GU)
            Marine Federal Credit Union (NC)
            Suncoast Credit Union (FL)
By total dollar amount of lending:
            Banesco USA (FL)
            Community First Guam Federal Credit Union (GU)
            Marine Federal Credit Union (NC)
            Suncoast Credit Union (FL)




9
  “Persistent Poverty Counties” means any county, including county equivalent areas in Puerto Rico, that has had
20% or more of its population living in poverty over the past 30 years, as measured by the 1990 and 2000 decennial
censuses and the 2011–2015 5-year data series available from the American Community Survey of the Bureau of the
Census or any other territory or possession of the United States that has had 20% or more of its population living in
poverty over the past 30 years, as measured by the 1990, 2000 and 2010 Island Areas Decennial Censuses, or
equivalent data, of the Bureau of the Census.
10
   “US Territories” means Puerto Rico, Guam, American Samoa, the US Virgin Islands, and the Northern Mariana
Islands.

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March 29, 2024


Lending to Indian Reservations and Native Hawaiian Homelands: 11
By total dollar amount of lending as a percentage of total originations:
            Carson Financial Holding Company, Inc. (OK)
            First American Credit Union (AZ)
            First Antlers Bancorporation, Inc. (OK)
            Grandview Bancshares, Inc. (OK)
            Security Bancshares Corporation (OK)
            Sisseton-Wahpeton Federal Credit Union (SD)
            The Native American Bancorporation Co. (CO)

By total dollar amount of lending:
            Carson Financial Holding Company, Inc. (OK)
            First Antlers Bancorporation, Inc. (OK)
            Grandview Bancshares, Inc. (OK)
            Lewis Clark Credit Union (ID)
            Ozarks Heritage Financial Group, Inc. (MO)
            Security Bancshares Corporation (OK)
            The Native American Bancorporation Co. (CO)




11
  “Indian Reservations and Native Hawaiian Homelands” means (1) an “Indian Reservation” as defined in the CDFI
Fund regulations at 12 C.F.R § 1805.104 (i.e., any geographic area that meets the requirements of section 4(10) of
the Indian Child Welfare Act of 1978 (25 U.S.C. 1903(10)), and shall include: land held by incorporated Native
groups, regional corporations, and village corporations, as defined in or established pursuant to the Alaska Native
Claims Settlement Act (43 U.S.C. 1602); public domain Indian allotments; and former Indian reservations in the
State of Oklahoma); or (2) Hawaiian Home Lands.

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