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U.S. Department of the Treasury, Emergency Capital Investment Program: "Investing for Impact: 2023 Annual Report"

Summary

Treasury's Emergency Capital Investment Program 2023 Investing for Impact Report, dated July 12, 2024. It states that through ECIP, authorized by the Consolidated Appropriations Act, 2021, Treasury invested more than $8.57 billion in community financial institutions, and that the 175 institutions are headquartered in 35 states, Guam, and the District of Columbia. According to the report, participants originated a total of $58.3 billion in loans in approximately 18 months, of which $43.0 billion was Qualified Lending and $20.6 billion was Deep Impact Lending. During 2023, participants originated approximately $34.4 billion in loans, about 74% of it Qualified Lending. The report closes with lists of top participants by category, including lending to Indian Reservations and Native Hawaiian Homelands.

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“U.S. Department of the Treasury, Emergency Capital Investment Program: ‘Investing for Impact: 2023 Annual Report.’” Original at home.treasury.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/u-s-department-of-the-treasury-emergency-capital-investment-program-in-8bcfeabf36/, SHA-256 0f9afce1da87ea8a13b9f8e042327ef47add833f84b3594b34978bec777e92ac.

Full text

Emergency Capital Investment Program




        2023 Investing for Impact Report
                  July 12, 2024
July 12, 2024



I.       Executive Summary
Through the Emergency Capital Investment Program (ECIP), authorized by the Consolidated
Appropriations Act, 2021, the U.S. Treasury Department (Treasury) invested more than $8.57
billion in community financial institutions to support lending to financially underserved
borrowers and communities. ECIP participants are 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. The 175 institutions that Treasury invested in are
headquartered in 35 states, Guam, and the District of Columbia.
ECIP was established to support the efforts of low- and moderate-income community financial
institutions to provide financial products and services for low- and moderate-income and
underserved communities that have disproportionately suffered from the impacts of the COVID–
19 pandemic, by providing capital investments in community financial institutions. Data from
the first 18 months of the implementation of the program demonstrate that community financial
institutions participating in ECIP were well-positioned to deliver loans and other resources, at
scale, to financially underserved communities that were particularly impacted by the pandemic.
Each quarter, participants submit reports to Treasury, known as the Quarterly Supplemental
Reports (QSRs), that provide data on new loan originations during the quarter. Participants
reported this data starting with their lending in Q2 2022. 1 In addition to reporting their total
lending, participants provide data on their Qualified Lending and Deep Impact Lending.
Qualified Lending includes lending to low- and moderate-income (LMI) borrowers, minority
communities, rural communities, and businesses with annual revenues of $1 million or less,
among other categories, as outlined in the ECIP Rate Reduction Incentive Guidelines. 2 Deep
Impact Lending is a subset of Qualified Lending that represents more challenging types of
lending to more underserved target communities that face the greatest barriers to accessing
capital. Deep Impact Lending includes lending to low-income borrowers, businesses with annual
revenues of $100,000 or less, financing of deeply affordable housing, and lending in persistent
poverty counties, on Indian reservations and in U.S. territories, among other categories, also as
outlined in the ECIP Rate Reduction Incentive Guidelines. The Qualified Lending and Deep
Impact Lending categories illustrate how ECIP participants are advancing the statutory goals of
the program and provide a data-driven method for understanding their impact on communities.
The following are key impacts of the ECIP program to date. Unless otherwise noted, the data
presented below are for the period from May 2022 through December 2023.



1
  Each participant is required to begin reporting on the loans it originates starting from the date it received its ECIP
  investment. Over 90% of ECIP participants received their ECIP investments in Q2 2022.
2
  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.

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July 12, 2024


    •   In approximately 18 months, ECIP participants originated a total of $58.3 billion in
        loans, of which more than one third was to the most underserved borrowers.
        Approximately three quarters, or $43.0 billion, of these originations was Qualified
        Lending. More than one third of these total originations, or $20.6 billion, was Deep
        Impact Lending to the most underserved borrowers.
    •   ECIP participants significantly increased their total lending and qualified lending
        above their pre-ECIP baseline, even as interest rates rose. ECIP participants reported
        $33.0 billion in total originations in the baseline year ending September 30, 2020. In the
        year between July 1, 2022 and June 30, 2023, ECIP participants reported $38.7 billion in
        total originations. During the same periods, Qualified Lending increased from $24.8
        billion to $28.1 billion. Since July 1, 2023, participants have continued to report total
        originations and Qualified Lending at or above their pre-ECIP baselines, even though
        interest rates were significantly higher in this time period than in the baseline year.
    •   Since receiving their ECIP investments, participants have steadily increased the
        amount and percentage of their Qualified Lending and Deep Impact Lending. The
        percentage of ECIP participants’ total originations that was Qualified Lending increased
        from 72% in Q3 2022 to 76% in Q4 2023. The percentage of ECIP participants’ total
        originations that was Deep Impact Lending to the most underserved borrowers increased
        from 33% in Q3 2022 to 39% in Q4 2023.
    •   ECIP participants reached underserved geographies. Through the end of 2023, ECIP
        participants originated $10.3 billion in Rural Communities and $17.5 billion in Minority
        Communities, two categories of Qualified Lending. In the same period, ECIP
        participants’ lending in some of the most distressed communities in the United States
        included $10.2 billion in Persistent Poverty Counties; $850 million in Indian
        Reservations and Native Hawaiian Homelands; and $459 million in Puerto Rico and
        other U.S. territories.
    •   ECIP participants unlocked access to capital for the hardest-to-serve small
        businesses. Through the end of 2023, ECIP participants reported 24,540 originations
        totaling $4.5 billion of lending to small businesses with annual revenues of $1 million or
        less. Of this lending, 7,395 originations totaling $1.2 billion were to the smallest and
        hardest-to-serve businesses with annual revenues of $100,000 or less, including many
        start-ups. Through the end of 2023, ECIP participants reported 2,623 originations
        totaling $1.4 billion of lending to minority-owned businesses (not including Hispanic-
        owned businesses) and 2,266 originations totaling $1.2 billion of lending to Hispanic-
        owned businesses.
    •   ECIP participants financed the production of affordable housing and provided
        mortgages to underserved homebuyers. Through the end of 2023, ECIP participants




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July 12, 2024


        invested $1.2 billion in 434 Affordable Housing projects, 3 including $345 million for
        Deeply Affordable Housing projects. 4 During the same period, ECIP participants
        provided 8,984 mortgage loans totaling $2.6 billion to Other Targeted Populations. 5
    •   Most ECIP participants are collecting and reporting to Treasury demographic data
        about the borrowers they serve, consistent with a statutory exemption from certain
        restrictions on demographic data collection. Under the Equal Credit Opportunity Act,
        lenders are generally prohibited from collecting data on the race and ethnicity of
        borrowers except for mortgage loans. The ECIP statute provides a limited exemption
        from the Equal Credit Opportunity Act for ECIP participants. 6 Treasury provided
        flexibility to allow ECIP participants additional time to implement this new data
        collection and expects all ECIP participants to provide complete reporting by Q3 2024.
        By the end of 2023, about 60% of ECIP participants reported non-mortgage lending to
        Other Targeted Populations, indicating that they had begun collecting data on the race
        and ethnicity of at least some non-mortgage borrowers.
The following chart provides a snapshot of lending reported by ECIP participants in 2022 and
2023.




3
  “Affordable Housing” means financing for any (1) affordable housing development project that has received a
  funding allocation under a state’s Low-Income Housing Tax Credit program (9% or 4% credits), from a U.S.
  Department of Housing and Urban Development grantee utilizing HOME or Housing Trust Fund grant funds, or a
  project that has received funding from the Farm Labor Housing Direct Loans & Grants program or Housing
  Preservation Grants program at the U.S. Department of Agriculture; or (2) financing for any affordable housing
  units restricted to households earning below 60% of AMI for a period not less than 10 years, prorated based on the
  percentage that such units make up of the total number of housing units.
4
  “Deeply Affordable Housing” is a subset of affordable housing and is defined as financing for any (1) affordable
  housing units restricted to households earning below 30% of AMI for a period not less than 10 years, prorated
  based on the percentage that such units make up of the total number of housing units; or (2) affordable housing in
  a “high opportunity area” as defined by the Federal Housing Finance Agency in 12 C.F.R. § 1282.1(b).
5
  “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.
6
  See 12 U.S.C. 4703a(k).

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July 12, 2024


                 Summary of ECIP Institutions’ Lending in Selected Categories1,2,3

                                               May 2022 – Dec. 2022         Jan. 2023 – Dec. 2023              Total
       Lending Activity Categories
                                                    ($Billions)                   ($Billions)                ($Billions)

 Total Originations                                     23.873                       34.415                    58.288
 Total Qualified Lending Originations             17.463                    25.558                             43.021
 Total Deep Impact Lending
                                                  8.009                     12.558                             20.567
 Originations
                                     Selected Categories of Qualified Lending
 LMI Borrowers                                          4.641                        7.007                     11.647
 Rural Communities                                      4.048                        6.305                     10.353
 Minority Communities                                   7.106                        10.401                    17.506
 Affordable Housing                                     0.530                        0.674                      1.204
 Small Businesses (annual revenue
                                                        1.759                        2.740                      4.499
 <=$1 million)
                                       Selected Categories of Deep Impact Lending
 Low-Income Borrowers                                   2.469                        3.699                      6.168
 Persistent Poverty Counties                            3.817                        6.362                     10.179
 Indian Reservations and Native
                                                        0.339                        0.510                      0.849
 Hawaiian Homelands
 U.S. Territories                                       0.166                        0.293                      0.459
 Deeply Affordable Housing                              0.155                        0.190                      0.345
 Mortgage Lending to Other Targeted
                                                        1.129                        1.442                      2.571
 Populations
 Minority-owned Businesses (other
                                                        0.556                        0.880                      1.436
 than Hispanic-owned Businesses)
 Hispanic-owned Businesses                              0.456                        0.754                      1.211
 Smallest businesses (annual revenue
                                                        0.429                        0.806                      1.235
 <=$100,000)
1 Data presented is based on Quarterly Supplemental Report submissions as of June 24, 2024 and is subject to change.
2 The categories are not mutually exclusive. For example, a loan may be made to a Low-income Borrower in a Persistent Poverty

County and will be counted in both categories. Further, the same loan or investment may be included in both Qualified Lending
and Deep Impact Lending. For example, a loan made to a Low-income Borrower will also be counted as a loan to an LMI
Borrower since a Low-income Borrower is, by definition, also an LMI Borrower.
3 Lending for 2022 is from the date each institution received its ECIP investment through December 31, 2022 and thus does not

include lending for the full period from May to December 2022 for all participants. Q3 2022 includes 162 ECIP recipients; Q4
2022 includes 170 ECIP recipients; Q1 2023 includes 169 ECIP recipients; Q2 2023 includes 169 ECIP recipients; Q3 2023
includes 174 ECIP recipients; and Q4 2023 includes 174 ECIP recipients.




                                                                5
July 12, 2024



II.     Overview
This report presents lending information for institutions participating in the ECIP. This report is
based on data submitted by ECIP participants to Treasury in their QSRs through the end of 2023.
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.
Through the ECIP, Treasury invested $8.57 billion in CDFIs and MDIs, including $3.2 billion in
MDIs. Community financial institutions deliver responsible capital, credit, and services to
financially underserved communities that the statute seeks to benefit, including LMI, minority,
and rural communities. 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 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.
When ECIP participants engage in Deep Impact Lending, Treasury provides additional credit
toward this rate reduction. 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
time and resources from the lender and may produce less revenue due to smaller loan sizes or
more favorable rates. 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.
The remainder of this report presents additional information on lending by ECIP participants
through December 31, 2023. Section III presents information on total lending, Qualified
Lending, and Deep Impact Lending. Section IV presents trends on lending since participants
received their ECIP investments. Section V presents data on lending by state. Section VI
presents data by Qualified and Deep Impact Lending category. Section VIII highlights stories of
Deep Impact Lending that were submitted by ECIP participants. Finally, Section VIII lists the
top ECIP participants in various lending categories.

III. 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 U.S. territories. A full
description of the Qualified and Deep Impact Lending categories can be found in the QSR
Instructions.



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July 12, 2024


                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                  • Indian Reservations and
 Places                    Communities                         Native Hawaiian Homelands
                         • Underserved Communities           • U.S. Territories
                         • Minority Communities
                         • Qualified Businesses,             • Underserved Businesses
 Businesses                including Small Businesses or
                           Farms
                         • Affordable Housing                • Deeply Affordable Housing
                         • Public Welfare and                • Public Welfare and
 Borrowers or projects     Community Development               Community Development
 that create direct        Investments if they primarily       Investments if they primarily
 benefits for LMI          benefit LMI Borrowers or            benefit Low-income
 communities or Other      communities, Minority               Borrowers, Minority
 Targeted Populations      borrowers, or Minority              borrowers, or Minority
                           Businesses                          Businesses
                         • Community Service Facility


While ECIP made investments in 175 institutions, the 2023 data represents 174 institutions (83
credit unions and 91 banks or holding companies), as two ECIP participants merged in 2023. Of
these 174 institutions, 119 are CDFIs, 27 are MDIs, and 28 are both CDFIs and MDIs.




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July 12, 2024


During 2023, ECIP participants originated a total of approximately $34.4 billion in loans, of
which about 74%, or $25.6 billion, was Qualified Lending. Approximately 36% of ECIP
participants’ total originations during this time, or $12.6 billion, was Deep Impact Lending, a
subset of Qualified Lending, as shown in Figure 1 below. Total Originations, Qualified
Lending, and Deep Impact Lending by institution can be found in Annex 1 of the 2023 Data
Release.

                           Figure 1: 2023 Lending by ECIP Recipients1
        Lending by Amount (Billion $)                                         Lending by Number of
                                                                                  Originations




                                     $8.9                                                       197,608
                $12.5
                                                                               397,894



                                $12.9                                                           464,928




   Other Lending                                                    Other Lending

   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 June 24, 2024, and is subject to change.




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July 12, 2024


From the summer of 2022 through December 2023, ECIP participants reported total originations
of approximately $58.3 billion. Approximately 74%, or $43.0 billion, of these originations was
Qualified Lending. Approximately 35% of these originations, or $20.6 billion, was Deep Impact
Lending to the most underserved borrowers, as shown in Figure 2 below.

       Figure 2: Summer 2022-December 2023 Lending by ECIP Recipients1
                                                                              Lending by Number of
        Lending by Amount (Billion $)
                                                                                  Originations




                                     $15.3                                                       344,553
                $20.5                                                          641,315



                               $22.4                                                            787,695




   Other Lending                                                    Other Lending

   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 June 24, 2024, and is subject to change.




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July 12, 2024


Table 2 below shows originations by ECIP recipients in 2023 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 2023 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
                                     644,483          $13,246          231,395           $5,613          288,448           $4,140
 of credit2
 Commercial loans/lines of
                                       3,186            $979             1,488            $496              883             $178
 credit
 Total                               647,669        $14,224         232,883         $6,109               290,331           $4,318
                                 Insured Depository Institutions (IDIs) and Holding Companies
 Loans secured by
 constructions, land
                                       6,265           $4,463            1,916           $1,511            2,425           $1,670
 development, and other
 land loans
 Loans secured by farmland             1,706            $537              478             $125             1,047            $343
 Loans secured by 1-4 family
 residential properties               17,765           $4,756            5,439           $1,336            8,179           $1,823

 Loans secured by
 multifamily (5 or more)                439             $994              193             $485              183             $336
 residential properties
 Loans secured by nonfarm
 nonresidential properties             3,655           $3,314            1,302           $1,346            1,933           $1,328

 Loans to finance agricultural
 production and other loans            3,979           $1,230             772             $184             3,089           $1,014
 to farmers
 Commercial and industrial
                                      15,087           $3,022            4,555           $1,133            8,644           $1,193
 loans
 Loans to individuals for
 household, family, and other        363,789           $1,859          217,329            $761            82,058            $531
 personal expenditures
 Lease financing receivables            73               $13              61               $8                3               $1
 Direct and indirect
 investments in real estate              1               $1                0               $0                1               $1
 ventures
 Equity investments without
 readily determinable fair               2               $2                0               $0                1               $1
 values
 Total                               412,761          $20,191          232,045          $6,890           107,563           $8,240
 ECIP Total                         1,060,430         $34,415          464,928          $12,999          397,894           $12,558
1 Data presented is based on Quarterly Supplemental Report submissions as of June 24, 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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July 12, 2024



IV. Trends in Lending
Figure 3 below shows quarterly trends in Total Lending by ECIP participants.

                             Figure 3: Quarterly Trends in Total Lending1,2
                    $12

                    $10

                    $8


        $Billions
                    $6

                    $4

                    $2

                    $0
                           Q3 2022         Q4 2022        Q1 2023           Q2 2023       Q3 2023          Q4 2023

                                     ECIP Participants' Quarterly Lending             Baseline Lending
1 Data presented is based on Quarterly Supplemental Report submissions as of June 24, 2024, and is subject to change.
2 Q3 2022 includes 162 ECIP recipients; Q4 2022 includes 170 ECIP recipients; Q1 2023 includes 169 ECIP recipients; Q2 2023

includes 169 ECIP recipients; Q3 2023 includes 174 ECIP recipients; and Q4 2023 includes 174 ECIP recipients.

Figure 4 shows quarterly trends in Qualified Lending and Deep Impact Lending as a percentage
of Total Originations for ECIP participants, by dollar amount. For data on individual
institutions, see Annex 1 of the 2023 Data Release.

   Figure 4: Trends in Qualified Lending as a Percent of Total Originations1,2
      80.00%



      60.00%



      40.00%



      20.00%



        0.00%
                          Q3 2022         Q4 2022        Q1 2023            Q2 2023      Q3 2023          Q4 2023

                          Qualified Lending (including Deep Impact Lending)              Deep Impact Lending
1 Data presented is based on Quarterly Supplemental Report submissions as of June 24, 2024, and is subject to change. Qualified

Lending in this figure includes lending which is also Deep Impact Lending.
2 Q3 2022 includes 162 ECIP recipients; Q4 2022 includes 170 ECIP recipients; Q1 2023 includes 169 ECIP recipients; Q2 2023

includes 169 ECIP recipients; Q3 2023 includes 174 ECIP recipients; and Q4 2023 includes 174 ECIP recipients.



                                                                11
July 12, 2024


Figure 5 shows the portion of 2023 lending which was Qualified and Deep Impact Lending as a
percentage of Total Originations for ECIP participants, by dollar amount, by institution type.

  Figure 5: 2023 Qualified and Deep Impact Lending as a Percentage of Total
                       Originations by Institution Type1
      80%


      60%


      40%


      20%


        0%
                                Credit Unions                                 IDIs and Holding Companies

                                       Deep Impact Lending             Qualified Lending
1 Data presented is based on Quarterly Supplemental Report submissions as of June 24, 2024, and is subject to change. Qualified

Lending in this figure includes lending which is also Deep Impact Lending.

Figure 6 shows the portion of 2023 lending which was Qualified and Deep Impact Lending as a
percentage of Total Originations for ECIP participants, by dollar amount, across various
institution sizes (measured by assets).

  Figure 6: 2023 Qualified and Deep Impact Lending as a Percentage of Total
                          Originations by Asset Size1
      100%

        80%

        60%

        40%

        20%

         0%
                        Small (<$500M)                Medium ($500M - $2B)                     Large (>$2B)

                                       Deep Impact Lending             Qualified Lending
1 Data presented is based on Quarterly Supplemental Report submissions as of June 24, 2024, and is subject to change. Qualified

Lending in this figure includes lending which is also Deep Impact Lending.



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July 12, 2024



V.         Composition of Lending by State
At the end of 2023, ECIP participants were headquartered in 35 states, Guam, and the District of
Columbia. 7 Figure 7 below shows the percentage of total lending by ECIP participants in each
state or territory which is Qualified Lending or Deep Impact Lending for 2023. (The underlying
data for this chart can be found in Annex 2 of the 2023 Data Release.

    Figure 7: Qualified and Deep Impact Lending by Participant Headquarters
              State or Territory (as a Percent of Total Originations)1

    100%

     90%

     80%

     70%

     60%

     50%

     40%

     30%

     20%

     10%

      0%    GU
             SD
            PA
             NJ
             TX
            CO
             LA
            DCIL
             CT
             IN
            AR
            OH
            OK
            NY
            NC
            AK
             AL
            VA
            MS
            MO
            GA
            WA
             AZ
            MD
             ID
            MI
             FL
             SC
            CA
            MA
            OR
            TN
            MT
            MN
             KY
             HI
                              Deep Impact Lending          Qualified Lending          Other Lending

1 Data presented is based on Quarterly Supplemental Report submissions as of June 24, 2024, and is subject to change.




7
    Treasury does not collect loan-level data from participants. Lenders may make loans to borrowers in states or
    territories that are not their headquarters state or territory. Such loans would still be attributed to the headquarters
    state, the District of Columbia, or Guam.

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July 12, 2024



VI. Breakout of Qualified and Deep Impact Lending
Figure 8 below shows originations by ECIP participants in 2023 by the Qualified and Deep
Impact Lending categories for which data was collected. (Data is reproduced in Annex 3 of
2023 Data Release. Note that the categories are not mutually exclusive. For example, a loan
made to a Low-income Borrower in a Persistent Poverty County will be counted in both
categories. Further, the same loan may be included in both Qualified Lending and Deep Impact
Lending. For example, a loan made to a Low-income Borrower will also be counted as a loan to
an LMI Borrower since a Low-income Borrower is, by definition, also an LMI Borrower.

         Figure 8: Qualified and Deep Impact Lending by Target Category1

                                                               Credit Unions                 IDIs and Holding Companies

                                                                       Dollar Amount                         Dollar Amount
         Lending Activity Categories                 Number of                              Number of
                                                                       of Originations                       of Originations
                                                    Originations                           Originations
                                                                         ($Millions)                           ($Millions)

                                                         (A)                   (B)               (C)                (D)
                  LMI Borrowers                       372,643              $5,927              39,957             $1,067
                  Low-Income Borrowers                 260,027             $3,208              26,541              $491
    People        Other Targeted Populations           33,051              $1,103              15,253             $1,674
                  Mortgage Lending to Other
                                                        2,904               $600               2,255               $842
                  Targeted Populations
                  Small Businesses                      5,678               $240               10,743             $2,500
  Businesses
                  Underserved Businesses                 810                $108               6,435              $2,022
                  Rural Communities                    82,733              $1,515              84,984             $4,790
                  Urban Low-Income
                                                       279,938             $4,917             222,911             $7,428
                  Communities
                  Underserved Communities              335,135             $6,052             270,284            $10,297

    Places        Minority Communities                 215,184             $3,675             210,438             $6,725
                  Persistent Poverty Counties          41,456               $636               78,488             $5,727
                  Indian Reservations and
                  Native Hawaiian                       3,771                  $27             13,141              $483
                  Homelands
                  U.S. Territories                      1,182                  $76               52                $217
                  Affordable Housing                      63                   $19              188                $656
                  Deeply Affordable Housing               13                   $3                60                $187
                  Qualified Public Welfare
                  and Community                           37                   $73               35                $76
    Projects      Development Investments
                  Deep Impact Public Welfare
                  and Community                           28                   $24               29                $68
                  Development Investments
                  Community Service
                                                          76                   $73              166                $279
                  Facilities
1 Data presented is based on Quarterly Supplemental Report submissions as of June 24, 2024, and is subject to change.




                                                                14
July 12, 2024



VII. Impact Highlights: Deep Impact Lending
This section presents highlights of Deep Impact Lending by ECIP participants. These highlights
were voluntarily submitted by participating institutions and have not been independently verified
by Treasury.

Small Business Lending
    •   In March 2023, Millennium Bank (an MDI in Des Plaines, IL) funded a business loan to
        a small business that provides fresh produce to Chicago’s Low-income and Minority
        communities. The funds were used to purchase two trucks to transport their products.
        The bank has also extended working capital lines of credit to assist them with their daily
        operational cash flow. The funding has allowed the business to grow its staff to over 15
        employees and extend services to surrounding South Side communities.
   •    In March 2023, Centric Federal Credit Union (a CDFI in Monroe, LA) provided capital
        necessary for a small construction company to expand its operations. This loan enabled
        the company to hire additional workers, allowing them to take on a greater number of
        construction projects. This strategic financial backing made possible through ECIP has
        not only empowered the construction company to pursue more ambitious projects but has
        also strengthened its financial stability, paving the way for sustained growth.
    •   Asian Bank (a CDFI and MDI in Philadelphia, PA) was able to expand its services and
        small business loans to immigrant communities. This expansion has enabled loans
        including a $60,000 loan in August 2022 to a Hispanic-owned take-out and catering
        business to pay off higher-cost seller financing on the business location and a $100,000
        loan to a Hispanic-owned restaurant to replace aging kitchen equipment in September
        2023.
    Commercial Lending
    •   In April 2023, Banesco USA (an MDI in Coral Gables, FL) closed on four loans totaling
        $5,605,295 for a leading manufacturer of flexible and industrial plastic packaging for
        FDA-regulated sectors and the general market, located in Corozal, Puerto Rico. The
        business is Hispanic-owned and is in an Urban Low-Income Community, Underserved
        Community, Minority Community, and Persistent Poverty County. The loan recipient, an
        Underserved Business, is now Corozal’s largest employer, providing jobs for 5% of the
        working population in a community with a 48% poverty rate.
    •   In June 2023, Southern Bancorp (a CDFI in Arkadelphia, AR) made a $94,000
        commercial loan to purchase a building that will house a family healthcare clinic. The
        clinic will be located in Ashley County, Arkansas, which is ranked in the bottom quartile
        for healthy counties in a state that persistently struggles with poor health outcomes.
        Proximity to healthcare is currently an obstacle for the county’s low-income residents.
        Because they cannot afford to travel long distances to access specialty services, they
        often go without. The new facility will not only serve these families but provide
        transportation as well.

                                                15
July 12, 2024


    •   In September 2023, Lone Star National Bank (an MDI in Pharr, TX) originated a
        $15,115,000 investment to finance infrastructure improvements in the City of Pharr,
        Texas to promote commercial, retail, and land uses for economic development such as
        manufacturers, development of roads, residential housing, parks, retail, and a produce
        area. The investment will fund installation of wi-fi in all schools in Pharr, making wi-fi
        accessible to all citizens in Pharr, and the building of a research and library center,
        critical to educating people out of poverty.
    •   In November 2023, Self-Help Credit Union (a CDFI and MDI in Durham, NC) made a
        $796,000 commercial loan to an African American-owned childcare center to purchase a
        vacant building to expand quality care to more children.
    •   In March 2022, Ponce Bank (an MDI in Bronx, NY) closed a mortgage loan to a
        minority-owned catering and special events company. Loan proceeds will go to purchase
        a 17,765 square-foot two-story commercial building in the Bronx, New York. The
        property purchase allowed a 100% minority-owned small business employing 20 full-
        time and 16 part-time workers to consolidate its existing food service operations into one
        central headquarters in the South Bronx.
    •   In September 2022, New Omni Bank (an MDI in Alhambra, CA) funded a $1.57 million
        loan to finance the purchase of an owner-occupied child day care facility located in an
        Underserved and Urban Low-Income Community in California. The business, which is
        licensed for 80 preschool children and 16 infants, making it the third-largest facility in
        the area, had provided day care services to the local area communities since 1996. The
        borrower, a minority-owned business, plans to continue operating the facility as a child
        day care service. The loan created four new jobs, and a total of 18 jobs will be retained
        that otherwise would have been lost.
Consumer Lending
    •   In 2023, One Detroit Credit Union (a CDFI and MDI in Detroit, MI) provided loan
        capital for 72 “Refi My Ride” loans, helping Low-income Borrowers out of high-cost car
        loans.
    •   In the second quarter of 2023, Alternatives Federal Credit Union (a CDFI in Ithaca, NY)
        made $558,000 in credit-building consumer loans for 45 Low-income Borrowers (under
        80% of area median income (AMI) by county) with credit scores of 570 and under. In
        Q3 2023, AFCU made $615,749 in credit-building consumer loans for 55 Low-income
        Borrowers (under 80% AMI by county) with credit scores of 604 and under. The average
        credit score of these borrowers was 548. These loans were paired with financial
        education and credit counseling.
    •   In the fourth quarter of 2023, Texas National Bank (a CDFI and MDI in Mercedes, TX)
        originated 149 credit-building loans totaling $379,194. These loans do not require a
        credit score, allowing consumers with no or limited credit history to take part in the
        financial system and build their credit. All these loans corresponded to minority

                                                 16
July 12, 2024


        individuals who reside in Persistent Poverty Counties. Through responsible consumer
        financing done through the bank, these consumers were able to avoid costly and
        predatory lenders.
Mortgage Lending and Investments in Housing

    •   In April 2023, Locus Bank (a CDFI in Richmond, VA) provided a $8.38 million Low-
        Income Housing Tax Credit construction loan to support the acquisition and
        rehabilitation of 112 units of affordable housing, with 100 units below 50% AMI and 12
        units below 60% AMI, located in Richmond, VA, a Persistent Poverty County. In
        September 2023, Locus Bank provided a $9 million line of credit to bridge tax
        equity/grants for cost overruns related to the rehabilitation of 204 units of affordable
        housing across five different projects in Richmond.
    •   Since Latino Community Credit Union (a CDFI and MDI in Durham, NC) received its
        ECIP investment in 2022, 310 loans for a total of $8.6 million have been made in Gaston
        County, North Carolina, mostly to Latinos. This includes $3.6 million for 18 home
        mortgage loans for Latino families. The average mortgage loan size is approximately
        $200,000, and as low as $68,400. Fourteen of those home loans were in Urban,
        Underserved, and Low-Income Communities.
    •   In 2022, BOM Bank (a CDFI in Natchitoches, LA) offered a new mortgage loan program
        to benefit Bossier and Bienville parishes in Louisiana. This affordable housing program
        was promoted by bank staff visiting over 10 areas in the market to discuss the program.
        The program is limited to Low-income Borrowers with adjusted gross income of $50,000
        or less, approximately 76% of AMI. The program also required recipients to obtain
        financial advising from the bank, to increase financial literacy among participants.
    •   In August 2022, Carson Financial Holding Company (an MDI in Stilwell, OK) helped a
        single mother, Low-income Borrower in a Persistent Poverty County secure a Federal
        Home Loan Bank Homeownership Set-aside Program grant for a down payment to buy
        the home she was living in. An additional loan was provided for her to rebuild the back
        of the house and construct a new roof for the home, as the existing roof allowed rainwater
        to pour down the walls. This loan, coupled with financial counseling provided by Carson
        Financial Holding Company, helped her build credit, equity, and security in her home.
    •   In November 2022, Central Bank of Kansas City (a CDFI in Kansas City, MO) provided
        $6.8 million in financing for a 36-unit affordable housing development in Dewitt, Iowa
        that was needed to support the rural community. A total of 32 of the units are reserved
        for residents under 60% of AMI, and others are reserved for residents under 30% of AMI.
        The project was also supported by low-income housing tax credits.

Other Lending
    •   In the first quarter of 2023, First Bank (an MDI in Antlers, OK) made more than $21
        million in loans to individuals and businesses in Persistent Poverty Counties.

                                                17
July 12, 2024


    •   In March 2023, the Bank of Commerce (an MDI in Greenwood, MS) provided a loan of
        $1.3 million to finance the construction and renovation of a school facility. The funding
        was used to build new classrooms to provide additional learning space for students and
        cafeteria facilities. The school serves students of LMI families. The school used this
        funding to invest in low-income, minority areas and has revitalized several vacant
        neighborhood buildings.
    •   In 2022, an ECIP investment allowed Caldwell Holding Company (a CDFI in Columbia,
        LA) to sustain growth, including opening two new branches and obtaining regulatory
        approval to expand in two additional parishes in Louisiana. One of the parishes, Lake
        Providence, had a 56.1% poverty rate and is a majority Black community.
    •   In 2023, DC Credit Union’s (a CDFI and MDI in Washington, D.C.) ECIP funding
        enabled the expansion of branch operations to locations where over 40% of the credit
        union’s members reside and commute.




                                                18
July 12, 2024



VIII. Top ECIP Participants in Various Categories of Lending
A. Top 25 ECIP Participants by Dollar Amount of Deep Impact Lending as a Percentage of
   Total Originations in 2023 (listed alphabetically): 8

            Asian Financial Corporation (PA)
            Caldwell Holding Company (LA)
            Carson Financial Holding Company Inc. (OK)
            CheckSpring Community Corporation (NY)
            Centric Federal Credit Union (LA)
            Citizens Corporation (MS)
            Commerce Bancorp Inc. (MS)
            Community First Guam Federal Credit Union (GU)
            First Antlers Bancorporation Inc. (OK)
            Grandview Bankshares, Inc. (OK)
            Homeland Bancshares Inc. (LA)
            Lone Star National Bancshares (TX)
            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 (NC)
            Sisseton -Wahpeton Federal Credit Union (SD)
            South Side Community Federal Credit Union (IL)
            South Texas Federal Credit Union (TX)
            Southeast Financial Bankstock Corporation (AR)
            Southwest Security, Inc. (MS)
            The Native American Bancorporation Co. (CO)
            TNB Bancshares (TX)
            Winnsboro Bancshares Inc. (LA)




8
  These lists do not include any ECIP participants that requested not to be included on such lists. Inclusion on these
lists is based on data as of June 24, 2024.

                                                          19
July 12, 2024


B. Top 25 ECIP Participants by Dollar Amount of Deep Impact Lending in 2023 (listed
   alphabetically): 9

            BancPlus Corporation (MS)
            Banesco USA (FL)
            BankFirst Capital Corporation (MS)
            Beneficial State Bancorp, PBC (CA)
            Caldwell Holding Company (LA)
            Centric Federal Credit Union (LA)
            Commerce Bancorp, Inc. (MS)
            ELGA Credit Union (MI)
            Grant Bancshares, Inc. (LA)
            Guaranty Capital Corporation (MS)
            Lake Trust Credit Union (MI)
            Leader Bancorp, Inc. (MA)
            Local Government Federal Credit Union (NC)
            Lone Star National Bancshares (TX)
            Millennium Bancorp, Inc. (IL)
            Ozarks Heritage Financial Group, Inc. (MO)
            Planters Holding Company (MS)
            Ponce Financial Group, Inc. (NY)
            Rio Financial Services, Inc. (TX)
            Self-Help Federal Credit Union (NC)
            Sovereign Bank (OK)
            Southern Bancorp, Inc. (AR)
            Suncoast Credit Union (FL)
            TNB Bancshares (TX)
            United Bancorporation of Alabama, Inc. (AL)




9
  These lists do not include any ECIP participants that requested not to be included on such lists. Inclusion on these
lists is based on data as of June 24, 2024.

                                                          20
July 12, 2024


C. Top ECIP Participants by Dollar Amount of Lending to Specific Targeted Communities in
   2023 (listed alphabetically): 10


Lending to Low-income Borrowers: 11
By total dollar amount of lending as a percentage of total originations:
            1st Bergen Federal Credit Union (NJ)
            Afena Federal Credit Union (IN)
            Alternatives Federal Credit Union (NY)
            Clarity Credit Union (ID)
            Commodore Perry Federal Credit Union (OH)
            DC Federal Credit Union (DC)
            Episcopal Community Federal Credit Union (CA)
            Genesee Co-op Federal Credit Union (NY)
            Heritage Financial Credit Union (NY)
            Holy Rosary Credit Union (MO)
            Industrial Credit Union of Whatcom County (WA)
            Members Credit Union, Inc. (CT)
            New Covenant Dominion Federal Credit Union (NY)
            Newrizons Federal Credit Union (WA)
            Peninsula Community Federal Credit Union (WA)
            Self-Help Federal Credit Union (NC)
            Sisseton-Wahpeton Federal Credit Union (SD)
            SkyPoint Federal Credit Union (MD)
            South Side Community Federal Credit Union (IL)
            Turner Bancshares, Inc. (TX)
By total dollar amount of lending:
            Beneficial State Bancorp, PBC (CA)
            Central Willamette Credit Union (OR)
            Centric Federal Credit Union (LA)
            ELGA Credit Union (MI)
            Financial Partners Credit Union (CA)
            Freedom First Federal Credit Union (VA)
            Heritage Financial Credit Union (NY)
            Industrial Credit Union of Whatcom County (WA)
            Lake Trust Credit Union (MI)
            Leader Bancorp, Inc. (MA)

10
   These lists do not include any ECIP participants that requested not to be included on such lists. Inclusion on these
lists is based on data as of June 24, 2024.
11
   “Low-income Borrower” means having an income of not more than: (1) for borrowers in Metropolitan Areas,
80% of AMI; and (2) for borrowers in Non-Metropolitan Areas, the greater of 80% of AMI or 80% of the statewide
Non-Metropolitan Area median income.

                                                          21
July 12, 2024


            Leaders Credit Union (TN)
            Local Government Federal Credit Union (NC)
            Marine Federal Credit Union (NC)
            Neighbors Federal Credit Union (LA)
            Seattle Metropolitan Credit Union (WA)
            Security Credit Union (MI)
            Self-Help Federal Credit Union (NC)
            Sovereign Bank (OK)
            Suncoast Credit Union (FL)
            Texas Bay Credit Union (TX)


Lending to Other Targeted Populations: 12
By total dollar amount of lending as a percentage of total originations:
          Bright Force Holding, Inc. (TX)
          Carver Financial Corporation (GA)
          Citizens Bancshares Corporation (GA)
          Community First Guam Federal Credit Union (GU)
          Genesee Co-op Federal Credit Union (NY)
          Holy Rosary Credit Union (MO)
          Hope Federal Credit Union (MS)
          Kauai Federal Credit Union (HI)
          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)
          Self-Help Credit Union (NC)
          Self-Help Federal Credit Union (NC)
          Sisseton-Wahpeton Federal Credit Union (SD)
          Syracuse Cooperative Federal Credit Union (NY)
          TNB Bancshares (TX)
By total dollar amount of lending:
          Bright Force Holding, Inc. (TX)
          Community First Guam Federal Credit Union (GU)
          Hope Federal Credit Union (MS)

12
   “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.

                                                       22
July 12, 2024


           Lake Trust Credit Union (MI)
           Leader Bancorp, Inc. (MA)
           Leaders Credit Union (TN)
           Liberty Financial Services, Inc. (LA)
           Lone Star National Bancshares (TX)
           M&F Bancorp, Inc. (NC)
           Millennium Bancorp, Inc. (IL)
           NMB Financial Corporation (NJ)
           One World Holding, Inc. (TX)
           PCB Bancorp (CA)
           Ponce Financial Group, Inc. (NY)
           Seattle Metropolitan Credit Union (WA)
           Self-Help Credit Union (NC)
           Self-Help Federal Credit Union (NC)
           Suncoast Credit Union (FL)
           TNB Bancshares (TX)
           University Financial Corp., GBC (MN)




                                             23
July 12, 2024


D. Top ECIP Participants by Dollar Amount of Lending to Underserved Businesses in 2023
   (listed alphabetically): 13

Lending to Minority Businesses 14 (other than Hispanic-owned businesses):

By total dollar amount of lending as a percentage of total originations:
          Asian Financial Corporation (PA)
          Carver Financial Corporation (GA)
          CheckSpring Community Corporation (NY)
          IBW Financial Corporation (DC)
          Millennium Bancorp, Inc. (IL)
          One World Holding, Inc. (TX)
          The Native American Bancorporation Co. (CO)

By total dollar amount of lending:
          Asian Financial Corporation (PA)
          CheckSpring Community Corporation (NY)
          IBW Financial Corporation (DC)
          Millennium Bancorp, Inc. (IL)
          NMB Financial Corporation (NJ)
          One World Holding, Inc. (TX)
          The Native American Bancorporation Co. (CO)

Lending to Hispanic-owned businesses:

By total dollar amount of lending as a percentage of total originations:
          1st Bergen Federal Credit Union (NJ)
          Asian Financial Corporation (PA)
          Banesco USA (FL)
          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)


13
   These lists do not include any ECIP participants that requested not to be included on such lists. Inclusion on these
lists is based on data as of June 24, 2024.
14
   “Minority Business” means a business or farm that is majority owned by a Minority.

                                                          24
July 12, 2024


           Hope Federal Credit Union (MS)
           Rio Financial Services, Inc. (TX)
           TNB Bancshares (TX)
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)
          FSB Bancshares, Inc. (OK)
          Grandview Bankshares, Inc. (OK)
          IBW Financial Corporation (DC)
          Lone Star National Bancshares (TX)
          New Omni Bank, NA (CA)
          TNB Bancshares (TX)

By total dollar amount of lending:
          BankFirst Capital Corporation (MS)
          Beneficial State Bancorp, PBC (CA)
          Lone Star National Bancshares (TX)
          New Omni Bank, NA (CA)
          Planters Holding Company (MS)
          Southern Bancorp, Inc. (AR)
          TNB Bancshares (TX)

Lending to businesses majority owned by Low-Income Borrowers:

By total dollar amount of lending as a percentage of total originations:
          Asian Financial Corporation (PA)
          Carver Financial Corporation (GA)
          CheckSpring Community Corporation (NY)
          Hope Federal Credit Union (MS)
          Millennium Bancorp, Inc. (IL)
          NMB Financial Corporation (NJ)
          Turner Bancshares, Inc. (TX)

By total dollar amount of lending:
          Asian Financial Corporation (PA)
          BankFirst Capital Corporation (MS)
          CheckSpring Community Corporation (NY)
          Millennium Bancorp, Inc. (IL)
          NMB Financial Corporation (NJ)
          Planters Holding Company (MS)
          Turner Bancshares, Inc. (TX)


                                                25
July 12, 2024


E. Top ECIP Participants by Dollar Amount of Place-Based Lending in 2023 (listed
   alphabetically): 15

Lending to Persistent Poverty Counties: 16
By total dollar amount of lending as a percentage of total originations:
          Asian Financial Corporation (PA)
          Caldwell Holding Company (LA)
          Carson Financial Holding Company, Inc. (OK)
          Centric Federal Credit Union (LA)
          Pyramid Financial Corporation (MS)
          South Texas Federal Credit Union (TX)
          TNB Bancshares (TX)
By total dollar amount of lending:
          BancPlus Corporation (MS)
          Banesco USA (FL)
          Guaranty Capital Corporation (MS)
          Lone Star National Bancshares (TX)
          Planters Holding Company (MS)
          Ponce Financial Group, Inc. (NY)
          TNB Bancshares (TX)

Lending to U.S. Territories: 17
By total dollar amount of lending as a percentage of total originations:
          Banesco USA (FL)
          Community First Guam Federal Credit Union (GU)
          Lower East Side People’s Federal Credit Union (NY)
          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)
          Lower East Side People’s Federal Credit Union (NY)


15
   These lists do not include any ECIP participants that requested not to be included on such lists. Inclusion on these
lists is based on data as of June 24, 2024.
16
   “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 five-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.
17
   “U.S. Territories” means Puerto Rico, Guam, American Samoa, the U.S. Virgin Islands, and the Northern Mariana
Islands.

                                                          26
July 12, 2024


            Marine Federal Credit Union (NC)
            Suncoast Credit Union (FL)


Lending to Indian Reservations and Native Hawaiian Homelands: 18
By total dollar amount of lending as a percentage of total originations:
          Carson Financial Holding Company, Inc. (OK)
          First Antlers Bancorporation, Inc. (OK)
          Grandview Bancshares, Inc. (OK)
          Lewis Clark Credit Union (ID)
          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)
          FSB Bancshares, Inc. (OK)
          Grandview Bancshares, Inc. (OK)
          Ozarks Heritage Financial Group, Inc. (MO)
          Security Bancshares Corporation (OK)
          The Native American Bancorporation Co. (CO)




18
  “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 includes: 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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