Following months of discussions, SLEHCRA and Paramount Bank have reached a Community Benefits Agreement. These meetings and discussions followed SLEHCRA’s concerns that Paramount Bank was not properly servicing the low-to-moderate and majority-Black areas surrounding their retail banking location in Hazelwood. Our review of their data showed that they were lagging their market peers in lending to LMI and majority-minority communities in their service area, which prompted the coalition to share our concerns with the FDIC. SLEHCRA and Paramount leaders discussed the bank’s publicly available lending data, why our coalition members were concerned with their performance, and ways in which Paramount Bank could better serve the community it calls home. Our conversations with the lender were respectful and productive, which has led to a signed CBA that all parties believe will help them better serve the community.

As a result of these conversations, Paramount has made numerous commitments to community leaders. These include:

• Paramount Bank has committed to increasing their mortgage lending in LMI areas to at least the level of their peers in the market.
• Paramount Bank has additionally agreed to increase lending to Black borrowers by matching their market peers in applications and originations to Black customers and in majority-Black census tracts.
• Paramount Bank will bring new products to market that are tailored to work in LMI and majority-minority areas. This will include specialized mortgage products and programs to help potential homebuyers with closing cost subsidies and other considerations for needs of borrowers in these communities.
• Paramount Bank has agreed to the formation of a community advisory committee, which will include civic, business and nonprofit leaders that live and work in the communities around the bank’s north St. Louis County retail location.
• The bank has also agreed to targeted goals for minority representation in its senior leadership and that staffing at the Hazelwood, MO location would represent the community in which it is located.

The bank has additionally made commitments to increase community engagement and collaboration with local nonprofit community organizations, maintain their Hazelwood location for the life of the agreement, and numerous other items. The CBA can be viewed at this link. We applaud the lender’s leadership team for their renewed commitment to serving the communities in north St. Louis County. Over the life of the agreement, SLEHCRA will continue to meet with the Paramount Bank and discuss progress towards the commitments outlined in the CBA.

January 11, 2022 – This past week, St. Louis Equal Housing and Community Reinvestment Alliance (SLEHCRA) and Woodstock Institute entered into a Community Benefits Agreement  (CBA) with First Mid Bank & Trust. The National Community Reinvestment Coalition (NCRC) is also supportive of the newly reached agreement. The agreement comes after SLEHCRA, NCRC, and Woodstock Institute filed comments with the Federal Reserve opposing First Mid’s proposed merger with Jefferson Bank and Trust. In October 2021, the advocates’ submitted opposition letters detailing concerns of redlining and low levels of service to Black borrowers and communities, as well as low- and moderate-income communities across the bank’s market area.  Based on these concerns, the advocates’ alleged that First Mid was failing to comply with fair lending laws and the Community Reinvestment Act (CRA).

Since first engaging with the bank and submitting the comment letter, the advocates’ have had productive dialogue with the bank about how to improve performance to communities of color and LMI communities throughout their market area. This culminates in a significant Community Benefits Agreement (CBA). Highlights of the 3-year agreement include:

• Two new service locations in St. Louis and in Champaign, IL market areas. These new locations will be located in LMI and minority communities. The bank further committed to maintaining current branches in LMI and minority communities.
• Target lending goals for mortgage applications and originations to minority borrowers, Black borrowers, minority census tracts, LMI census tracts and LMI borrowers. The bank will also offer affordable home mortgage products and programs, including FHA, VA, and USDA loans, and will hire community mortgage loan officers in markets of St. Louis and Champaign that are focused on communities of color and LMI communities.
• Target lending goals for small business loans to LMI communities, as well as increasing financing opportunities to minority and women-owned small businesses. The bank will also provide $100,000 in small business loan subsidies to small businesses in LMI and minority communities.
• An executive Community Development Officer and CRA market leaders in each market that develop and lead community development strategy, as well as create an internal Community Development Committee of bank representatives.
• The bank will also create an external Community Advisory Board composed of external partners and members representing LMI and minority communities.
• First Mid agrees to target community development loans and investments at 2% of the bank’s asset size, including providing $150,000 annually in CRA-eligible donations that will increase by 5% each year.
• Providing $50,000 annually to support financial education to LMI borrowers and communities.
• Agreements to proactively increase racial and ethnic diversity within the staff, leaders, and board of directors of the bank.
• Commemorate the civil rights history of Jefferson Bank with a $10,000 donation to the Griot Museum of Black History.

This forward-looking and substantive CBA shows that the bank is willing to be proactive in remedying concerns of CRA activists across both Missouri and Illinois. As such, advocates have dropped their request that the Federal Reserve block the proposed bank merger. Advocates believe it stands as proof that the bank is committed to taking its CRA obligations seriously.

“Once again, we’ve shown that community advocates can and should demand better from our region’s lenders. We believe that this agreement’s provisions show a significant commitment to improving First Mid’s lending performance in communities of color, including commitments on expanded branching, loan targets, and significant dollars committed for community development. Our work with First Mid is not done, and we look forward to continue working productively to implement this CBA and increase access to financial services for all in our community,” said Elisabeth Risch, SLEHCRA Co-Chair.

“These commitments both recognize a need for change and also the historic nature of the Jefferson Bank protests. We’re especially happy to have secured a donation to the Griot Museum of Black History, which will help preserve the story of this and other civil rights struggles in our region,” added Jackie Hutchinson, SLEHCRA’s other Co-Chair.

“We’ve completed a Community Benefits Agreement with First Mid that addresses our concerns, but the sale points to a major outstanding issue: if we want more loans in African-American or other majority people of color communities, we must demand federal bank regulators raise the standards they use to grade lenders,” said Horacio Mendez, CEO of Woodstock Institute.  “This year we have several important opportunities to reform CRA on the table – national reforms planned by the federal bank regulators and the creation of an Illinois CRA stand out among them. If we raise standards for all lenders and get more high-performing loans out to more low- and moderate-income communities and predominantly Black, Latino and other communities of color, doing better can become the norm.

“We’re pleased to see this new and meaningful commitment to address concerns and I want to congratulate SLEHCRA and the Woodstock Institute for their leadership and work with First Mid to expand services, mortgage and small business lending and investments in lower-income communities and communities of color,” said Jesse Van Tol, President & CEO of NCRC.

See the full CBA here: [First Mid Community Benefits Agreement – 1-5-2022]

October 18, 2021 (St. Louis, MO) – On Monday, St. Louis Equal Housing and Community Reinvestment Alliance (SLEHCRA), Woodstock Institute and National Community Reinvestment Coalition (NCRC) submitted comment  letters opposing the proposed merger between First Mid Bank & Trust and Jefferson Bank & Trust to the Federal Reserve. The letters cited similar Community Reinvestment Act (CRA) and Fair Lending concerns with First Mid Bank & Trust’s ongoing operations in multiple markets across Illinois.

First Mid Bank & Trust is a $5.6 billion bank based in Mattoon, IL, with a growing banking presence in the St. Louis region. The bank is applying to acquire Jefferson Bank & Trust, of St. Louis, MO. Combined, the bank would be 11th largest in deposits in the St. Louis market. 

These consumer advocacy organizations have significant concerns about First Mid Bank & Trust’s recent lending activities:

• First Mid Bank & Trust shows patterns of lending to minority borrowers and communities at less than half of their peers in the multiple markets.
• The extremely low numbers of applications from Black applicants (compared to peers) indicate that the lender has not been properly attempting to market and serve the  majority-minority neighborhoods within their assessment areas.
• The St. Louis, Champaign, Decatur, and Peoria markets showed the greatest signs of potential Fair Lending issues.
• Consumer advocates point out that the branch network is heavily concentrated in predominantly white and upper income neighborhoods.
• Local advocates also note the social and cultural significance of Jefferson Bank & Trust in the civil rights history of St. Louis. That such an important part of our local civil rights history could be merged with a lender who appears to have significant Fair Lending concerns is something the local community simply cannot support.

As a result of these concerns, advocates are asking that regulators deny the merger application and conduct a thorough fair lending investigation of First Mid Bank & Trust. The comment letters were also sent to the Office of the Comptroller of the Currency and the Department of Justice. 

“Thankfully, it has become rare that we see lenders with the kinds of significant and widespread redlining and fair lending concerns that were found in First Mid Bank & Trust’s data. When coupled with the powerful history around Jefferson Banks & Trust, our coalition’s member organizations felt it was necessary to ask the Federal Reserve to block the proposed merger. We also have significant concerns that the banking regulators failed to identify these issues previously. Simply put, we cannot support First Mid’s acquisition of yet another lender in the St. Louis metropolitan area. Until the institution takes significant steps to correct its ongoing behavior, regulators should not allow their business to continue expanding,” said Elisabeth Risch, Co-Chair of SLEHCRA.

Jackie Hutchinson, representing SLEHCRA member Consumers Council of Missouri, added “This merger is not in the best interest of St. Louisans because the best indication of what we can expect from First Mid bank is reflected in their history of lending to African American borrowers in Illinois.” 

“Analysis of First Mid’s mortgage lending shows a multi-year pattern and practice of blocking black borrowers from becoming homeowners. In majority Black neighborhoods of 7 counties that the bank serves, they originated an appalling 2 mortgages over a 3-year period. And in the St. Louis region First Mid originated 940 mortgages over 3 years … 16 of which were to Black borrowers. At the same time, their regulator (Office of the Comptroller of the Currency) gave the bank an ‘Outstanding’ rating on their Community Reinvestment Act (CRA) Lending Test. What, exactly, does it take to fail? We’re hoping the Department of Justice can help us answer that question,” added Horacio Mendez, president and CEO of Woodstock Institute.

“Bank mergers are a privilege, not a right, and they are supposed to benefit the public, not just the banks,” said Jesse Van Tol, President and CEO of NCRC. “In this case there is alarming data that shows First Mid failed to lend to Black borrowers and Black communities in multiple markets. That’s a pattern that regulators shouldn’t ignore or condone. Banks are supposed to meet the credit needs of the communities where they do business. The data suggests First Mid Bank & Trust does not meet those requirements, and therefore, this merger should be denied.”

View SLEHCRA and NCRC Comment Letter Here [PDF]

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Annually, SLEHCRA releases a Report to the Community that highlight community reinvestment trends in the St. Louis region. SLEHCRA surveys community members and banks to gather this information. The report seeks to publicize what financial products, services, and investments have changed during the last year, and what needs and opportunities still exist within the community.

Download the 2020 Report to the Community here!

September 24, 2020 –  A new NCRC report shows that there is a higher prevalence of COVID-19 risk factors in historically “redlined” neighborhoods. This paper is one of the first of its kind to examine historical redlining in cities across the nation on numerous present-day neighborhood health outcomes, including St. Louis.

As the COVID-19 crisis unfolded in St. Louis, the maps of the infections looked very familiar to those of us who work to promote integrated and inclusive communities. Unsurprisingly, it was having a greater toll on the city’s majority-Black neighborhoods, where maps already showed elevated rates of asthma and lead poisoning. These are obviously health issues that could make the virus more lethal. The infection maps also followed other maps, but not ones that would seem to be connected at first glance — ones showing low to non-existent residential mortgage activity. For advocates that work to expand equitable capital access and an end to modern day redlining, it wasn’t surprising, as we have long been acutely aware of the connections between health and housing.

Home Purchase Loans In St. Louis (2018 – 2019)

Read more of this St. Louis perspective of the report’s findings by Glenn Burleigh, EHOC’s Community Engagement Specialist here.

The National Community Reinvestment Coalition (NCRC) and the St. Louis Equal Housing and Community Reinvestment Alliance (SLEHCRA) have urged the Federal Deposit Insurance Corporation (FDIC) to require Edward Jones Bank to meet Community Reinvestment Act (CRA) assessment requirements in the St. Louis area.

NCRC and SLEHCRA made the recommendation in separate comment letters to the FDIC in response to Jones Financial Companies, L.L.L.P. ‘s application for depository insurance for their newly formed Edward Jones Bank. 

NCRC and SLEHCRA identified the lack of a St. Louis assessment area as part of a troubling trend in regulation of banks that receive Industrial Loan Charters (ILC). While Jones Financial will continue to be headquartered in St. Louis County, Missouri, Edward Jones Bank will be headquartered in Salt Lake CIty and its deposit insurance application indicated that its charitable giving and community development lending from the newly chartered bank would be directed to Salt Lake County, Utah. 

The supply of capital for CRA projects in the St. Louis region greatly lags the demand for such support. The same thing cannot be said about the Salt Lake City area, which is a “CRA hotspot” with a large number of banks competing for the same community development opportunities. 

The NCRC and SLEHCRA comment letters to the FDIC addressed concerns about the sudden reemergence of the industrial loan charter (‘ILC’) and evidence that suggests these institutions are held to a lower standard for community reinvestment.

“While we recognize that Edward Jones Bank will technically hold its deposits in an office in Salt Lake City, Edward Jones’ real home is in St. Louis, where it keeps its headquarters and where it is a significant employer,” said Jesse Van Tol, CEO of NCRC. “We support the efforts of the local groups in St. Louis that are working to promote economic opportunity in their communities. The FDIC should make sure that Edward Jones Bank is held accountable to support reinvestment in its home city. The Ferguson Commission Report determined that the St. Louis metro area was one of the most racially-segregated regions in the United States, noting that African-American homeownership rates in St. Louis County were almost thirty percentage points below the rate for white households, which underscores the need for financial institutions in St. Louis to support reinvestment in the community.” 

“Edward Jones is deeply rooted in the St. Louis community, so they should see the significant opportunities our region has to invest in community development and meet the credit needs of neighborhoods,” said SLEHCRA’s Co-Chair, Elisabeth Risch. “We have affordable housing projects that need capital and mortgage loan funds that need investments, likely at better rates and with a greater impact than any CRA hotspot. To overcome the decades of systemic racism and redlining still felt in St. Louis, we need companies like Edward Jones to step up and invest in communities they already call home.” 

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View SLEHCRA’s Comment Letter here. [PDF]

In light of the health and economic crisis that has come with the emergence of the COVID- 19 pandemic, the St. Louis Equal Housing and Community Reinvestment Alliance (SLEHCRA) and allies are calling on local financial institutions to take steps necessary to avoid COVID-related foreclosures and evictions. While actions taken at a federal level will help many impacted borrowers, SLEHCRA member organizations believe that all impacted borrowers should be given aid and understanding in such unprecedented times.

SLEHCRA and our allies call on all banks and lenders to immediately institute the following practices and policies to protect consumers impacted by COVID-19: 

• Moratorium on all foreclosures and foreclosure-related evictions
• Moratorium on all evictions of properties secured by mortgage loans
• Moratorium on consumer and business credit payments – including mortgages, car, student, and personal loans, and credit cards.
• Maintain lines of credit for businesses. 
• Offer payment accommodations for all loans.
• No documentation requirement of hardship related to COVID-19 in order to qualify customers for assistance. 
• Suspend credit bureau reporting of unpaid payments.
• Upon consumer request, report credit accounts with a natural disaster reporting code in order to neutralize information that normally would have negative impact.
• No late fees for borrowers impacted by COVID-19. 
• Waive ATM, overdraft, late payment, and other fees on all accounts.

Banks and lenders must communicate these policies and practices directly to consumers and to the larger community. We call on financial institutions to inform consumers through as many communication means as possible, including email, phone, and text messages, as well as a public announcement 

Federal banking regulators encourage banks to work with customers impacted by COVID-19 to offer loan modifications and not report those as negative activity. See the interagency statement on loan modifications. Additionally, banks can receive CRA credit for working with customers and communities affected by COVID-19, particularly those that are low- and moderate-income. See the joint statement from the OCC, FDIC, and Federal Reserve.  

Following the guidance of government agencies like the FHFA and HUD, individual financial institutions and lenders can act now to develop responses that provide options, protect consumers, and keep families in their homes.

These calls to action are supported by the following organizations: 

• Annie Rice, 8th Ward Alderwoman
• ArchCity Defenders
• Community Action Agency of St. Louis County (CAASTLC)
• Consumers Council of Missouri 
• Dutchtown South Community Corporation
• Empower Missouri
• Forward Through Ferguson 
• International Institute Community Development Corporation 
• Justine PETERSEN
• Legal Services of Eastern Missouri 
• Lisa Clancy, St. Louis County Council Chairwoman
• Metropolitan St. Louis Equal Housing and Opportunity Council (EHOC)
• Moorish Science Temple of America, #5
• NAACP O’Fallon IL 
• North County Churches Uniting for Racial Harmony and Justice 
• Old North St. Louis Restoration Group 
• Ready, Aim, Advocate! Committee 
• St. Louis Association of Community Organizations (SLACO)  
• St. Francis Community Services 
• Team TIF 
• Urban League of Metropolitan St. Louis

Additionally, SLEHCRA member organizations are working to spread information about already-announced programs to help impacted homeowners and small businesses. SLEHCRA members are gathering information about how and where emergency loan forbearance and other programs can be accessed.  SLEHCRA will continue to update the document as new information is released and additional consumer and small business lending and aid become available. View SLEHCRA’s COVID-19 Resources and Guidance online here. 

SLEHCRA Releases Latest Report to the Community

The St. Louis Equal Housing and Community Reinvestment Alliance (SLEHCRA) works to increase investment in low- and moderate-income communities (LMI), regardless of race, and in minority communities, regardless of income. We do this by ensuring that banks are meeting their obligations under the Community Reinvestment Act and fair lending laws. SLEHCRA’s Report to the Community is an annual update on changes to the St. Louis region’s financial services offerings and community development investment.

Policy Issues

In 2018, SLEHCRA engaged in policy advocacy in the St. Louis metro area as well as across the country on various issues related to fair lending and the Community Reinvestment Act. One of the major issues was the #TreasureCRA campaign. This focused on bringing national awareness to the importance of CRA in the wake of the Office of the Comptroller of the Currency (OCC) inviting public comment letters on an advance notice of proposed rulemaking that would weaken instead of strengthen CRA. The campaign involved social media awareness using the hashtag #TreasureCRA, passing local CRA Resolutions, as well as submitting public comment letters.

Financial Education

Nearly all banks engaged in some kind of financial education outreach. This included partnering with community groups or participating in relevant programs to provide funding for financial education. Or, banks often provide employees to teach financial education classes. Banks detailed efforts like partnering with local school districts, funding Money Smart Month efforts, and holding various financial education classes and lunch & learns.

Home Loan Products

Of the banks responding to the survey, 16 (70%) reported offering an affordable home purchase loan product targeted to the LMI community, nine of which offered a portfolio loan. Some features of the various products include: Lower down payments Lower credit score requirements, including alternative credit considerations Assistance with down payment or closing costs Homebuyer and credit building classes

Read the full report: SLEHCRA Report to the Community 2018

ST. LOUIS, Mo. – Simmons Bank and the St. Louis Equal Housing and Community Reinvestment Alliance (SLEHCRA) have announced a Community Benefits Partnership to serve the needs of low-to-moderate-income (LMI) and minority communities within the St. Louis, Missouri, region.

“Simmons is committed to serving the needs of low-to-moderate-income and minority communities throughout our footprint,” said George A. Makris, Jr., chairman and CEO of Simmons First National Corporation, parent company of Simmons Bank. “We chose to work with SLEHCRA because of their extensive knowledge of the needs in St. Louis. Working together, we believe we can create opportunities for economic development and enhanced quality of life by expanding access to financial products for individuals and families in this region.”

This announcement follows Reliance Bank’s merger into Simmons Bank, which expanded Simmons Bank’s presence in the St. Louis region from three branch locations to 25 earlier this month.

“Simmons recognized the outstanding work that Reliance Bank had done partnering with SLEHCRA and is committed to community development excellence in St. Louis now that we’ve joined together,” said Allan D. Ivie, IV, St. Louis president of corporate banking and community affairs for Simmons Bank.

“SLEHCRA is thrilled to enter into another Community Benefits Agreement with a forward-thinking lender. These agreements build positive relationships between consumers and lenders, and these relationships help achieve sustainable growth for lenders who understand the value of working in low- and moderate-income neighborhoods and communities of color. By working together, we are building a stronger St. Louis region,” said Jackie Hutchinson, SLEHCRA co-chair and board president of the Consumers Council of Missouri.

“When two groups come together with the same goal, in this case to help ensure equal credit opportunities for minority and low- and moderate-income borrowers, we believe real change can happen,” said Makris. “Simmons and SLEHCRA are laser-focused on this goal, and we have worked together to come up with specific volunteerism and giving plans that we believe will help us get there.”

The three-year partnership agreement will begin May 1, 2019. As a part of the plan, Simmons Bank has committed to:

• Adding one new retail service location in an LMI census tract or census tract with a predominantly minority population in the St. Louis region.
• Hiring a full-time, dedicated CRA mortgage lender in the St. Louis market.
• Offering residential lending, small business lending, and checking and savings products and services that have special appeal to LMI and minority individuals.
• Origination goals for small business loans.
• Contributing a total of $15 million in qualifying community development investments within the St. Louis market. As a part of this commitment and the commitment to leadership in the Gateway Neighborhood Mortgage program, Simmons plans to make an investment of $500,000 in the Gateway Neighborhood Mortgage loan fund.
• Funding contributions of $60,000 annually in CRA charitable giving in the St. Louis market.
• Engaging in financial literacy activities and targeted technical assistance with nonprofit organizations.

Read the full Partnership Agreement here.

About Simmons Bank

Simmons Bank is an Arkansas state-chartered bank that began as a community bank in 1903. Through the decades, Simmons has developed a full suite of financial products and services designed to meet the needs of individual consumers and business customers alike. Simmons has grown steadily to approximately $16.5 billion in assets (as of Dec. 31, 2018) and today operates approximately 200 branch locations throughout Arkansas, Colorado, Kansas, Missouri, Oklahoma, Tennessee and Texas. Simmons is the subsidiary bank for Simmons First National Corporation (NASDAQ: SFNC), a publicly traded bank holding company headquartered in Pine Bluff, Arkansas. For more information, visit http://www.simmonsbank.com/.

About SLEHCRA

The St. Louis Equal Housing and Community Reinvestment Alliance (SLEHCRA) is a coalition of nonprofit and community organizations in the St. Louis metropolitan area. SLEHCRA works to increase investment in minority communities, regardless of income, and in low- and moderate-income communities, regardless of race, by ensuring that banks are meeting their obligations under the Community Reinvestment Act and fair lending laws. Additional information is available at www.slehcra.org.

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