Introduction to Investor CRA in ProLinkAIM
The Investor CRA functionality provides tracking and management of Community Reinvestment Act (CRA) allocations for investors of Syndicated Funds. CRA requires depository institutions to invest in their communities to help meet their credit needs.
You can match potential investors with the lower tier deals your organization is syndicating. Once your organization commits to funding a lower tier deal, finding investors to support the investment is key. This is usually based upon criteria such as the assessment areas of the investors and the physical locations of the lower tier deals. For investor CRA, equity provided by the investors is eligible to be allocated for CRA.
If you have a specific investor looking to invest in a deal with specific location criteria, you can use the Investor CRA functionality to search for the lower tier deals that match the investor's footprint.
The List CRA Investors data view lists all entities with a primary role of Investor. You can view basic entity-level information through this data view. However, you cannot create a new record through this data view. To add a new investor, use the Entities data view.
All values in the grid are displayed from the corresponding Edit Entity screen.
Clicking a row opens the Edit CRA Investor screen for the Investor record.
On the Main tab, you can assign an exam period for the investor.
The Total Target Investment is the sum of the Target Investment for all the assessment areas for the CRA investor. This total is from the Target Investment field on all the investor CRA areas listed on the Footprint tab. To see a value here, values must be populated for CRA Assessment Areas listed on the Footprint tab.
The Total Investor Allocation is displayed from the Totals row, Allocation Amount column, on the Allocations tab. To see a value here, allocations must be made (in any status) through the Allocations tab.
The Allocations tab lists all allocation matches that have been made for the investor, regardless of the allocation status.
No fund is displayed in the Fund column if there is no Syndicated Fund on a proposed or finalized ownership schedule for the lower tier deal.
The Commitment column displays the amount of commitment the investor has made to the associated fund. This is a read-only field on the Edit CRA Allocation screen that is populated from the fund's Equity Schedule (Commitments grid). If the investor is not yet associated to the fund, then no commitment amount is displayed.
The Remaining Allocation amount is the Commitment amount minus the sum of all allocations for the investor/fund. It includes any other allocation matches that might have been made to that investor, through the same Syndicated Fund, to another lower tier deal.
Find a CRA Allocation Match
The Find CRA Matches popup is used to create and track allocation records for an investor. The popup lists a row for each potential lower tier deal match for the investor. Only the first 100 results are displayed. You can filter the results if more than 100 exist.
Lower tier deals that meet the following criteria are returned in the results:
There is no Syndicated Fund as an owner on a proposed or finalized ownership schedule for the lower tier deal.
There is a Syndicated Fund as an owner on a proposed ownership schedule for the lower tier deal.
A Syndicated Fund is an owner on a finalized schedule for the lower tier deal and there is remaining CRA equity for the deal/fund.
If an Allocation record already exists for the investor/fund/deal combination, then the lower tier deal will not be displayed in the results.
If the Syndicated Fund is an owner on a lower tier deal in more than one ownership schedule, only one result will be displayed.
The Remaining Deal CRA is the Upper Tier Equity amount minus the sum of all allocations made for the deal.
The Upper Tier Equity is the sum of lower tier equity (Adjusted Capital Amount plus Warehouse Capital Charges) plus Load Amount (Total Lower Tier Equity divided by [100 minus Total Load Percentage] times Load Percentage).
To find an allocation match:
Navigate to the CRA Investors data view.
The List CRA Investors screen opens.
Click the row of the investor.
The Edit CRA Investor screen opens.
Click the Allocations tab.
Click New above the Allocations grid.
The Find CRA Matches popup opens.
If needed, select filters to narrow the results, and click Search. You can search for matches based on the following specific criteria:
Deal/Fund—Syndicated Funds and lower tier deals where the text matches the name of the deal or fund.
State—Lower tier deals with at least one property in the selected state.
County—Lower tier deals with at least one property in the selected county. You must select a state first.
Investor is Owner—Lower tier deals where the investor is already an owner of the associated Syndicated Fund.
Is in CRA Footprint—Lower tier deals where at least one property is located in one of the investor's assessment areas.
Select the applicable match. You can select only one row at a time.
Click Add Selected and Close.
The system creates an allocation record for the investor/deal combination.
Edit the CRA Allocation
You can assign an allocation amount through the Edit CRA Allocation screen.
Section | Description |
|---|---|
Fund Information | This section is populated only when the lower tier deal has a Syndicated Fund as an owner in either a proposed or finalized ownership schedule. The values are displayed from the Syndicated Fund record. You can click the hyperlink of the Fund Name to navigate to the Fund Overview screen. |
Deal Information | The values are displayed from the lower tier deal record. You can click the hyperlink of the Deal Name to navigate to the Deal Overview screen. |
Investor Information | The Total Fund Commitment is the sum of Equity Commitment that the investor has made to the fund. The Priority is displayed from Edit CRA Investor Assessment Area for the assessment area. |
Allocation Information | The Allocation Amount can be any amount, even if it exceeds the Total Fund Commitment that the investor made to the fund, or the Upper Tier Equity that the fund made to the lower tier deal. The system displays a warning If an allocation amount is populated that causes the sum of all the allocations for all investors on the fund (across all lower tier deals for the fund) to exceed the sum of the Commitment amounts for all investors on fund. This warning is fund specific for all investors and will be displayed on all Allocation records for all investors with this Syndicated Fund. The system displays a warning if an allocation amount is populated that causes the sum of all the allocations for the lower tier deal (across investors) to exceed the Upper Tier Equity that the Syndicated Fund has with all its lower tier deals. This warning is not deal specific and will be displayed on all allocations for the fund. The Status on an Allocation record cannot be set to Finalized until the investor is an owner in a finalized ownership schedule for the Syndicated Fund. The Remaining Deal CRA is the Upper Tier Equity for the fund/deal minus the sum of all Allocation Amounts across investors for the fund/deal. |
Create and Track Side Letters
You can create and track side letters that need to be sent. The Side Letter tab displays all side letters created for the allocation.
To create a new side letter:
Navigate to the CRA Investors data view.
The List CRA Investors screen opens.
Click the row of the allocation.
The Edit CRA Allocation screen opens.
Click the Side Letters tab.
Click New above the CRA Letters grid.
The Edit Side Letter screen opens.
Enter or select the Date of the letter.
Select the Status of the letter.
Click Save.
The Footprint tab displays all the footprints (assessment areas) that have been added for the investor. You can add footprints manually or through the CRA Footprint Import utility.
To add a footprint manually:
Navigate to the CRA Investors data view.
The List CRA Investors screen opens.
Click the row of the investor.
The Edit CRA Investor screen opens.
Click the Footprint tab.
Click New above the Investor CRA Areas grid.
The Edit CRA Investor Assessment Area screen opens.
Select the Priority.
Select the State.
Select the County.
Complete the optional fields as needed.
Click Save.
Edit the CRA Investor Assessment Area
You can view and edit the footprint for an investor through the Edit CRA Investor Assessment Area screen.
The header shows the investor name with the Total Target Investment and Total Target Allocation totals.
After an allocation record exists for an assessment area, you cannot delete the assessment area. To delete an assessment area, first delete the allocation record(s).
