#62: What exactly is the BLS and how does it relate to the CRA?
Sep 8, 2022 ·
3m 41s
![#62: What exactly is the BLS and how does it relate to the CRA?](https://d3wo5wojvuv7l.cloudfront.net/t_square_limited_480/images.spreaker.com/original/0e4492d72f8d61997abcd9cdd4724efa.jpg)
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Hi, it's Linda with CRA today and the CRA Hub. I thought I'd hop back here and give you a quick tip. So many of you have asked "what exactly...
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Hi, it's Linda with CRA today and the CRA Hub. I thought I'd hop back here and give you a quick tip. So many of you have asked "what exactly is BLS (hint, it is the Bureau of Labor Statistics) and how should I use it to support my CRA program?" Well this month in the CRA Hub, we're focusing on CRA exam prep. As you know, it's really important to make sure that we are crossing our T's and dotting our I's and making sure that all of our community development activities are properly documented.
Well, this is where the website bls.gov comes in. This website will help you substantiate the creation or retentions of jobs for low and moderate income people. The BLS website is where you can go to create the documentation or the proof, to show your examiners during an exam to substantiate community development loans and activities, as applicable.
So let’s take a $1.5M community development loan that your bank originated to a restaurant to expand to a new location. You would first document that the borrower is considered a small business and then you will need to document and prove that the majority of the jobs created as a result of your financing would in fact be jobs for low and moderate income individuals.
Given my description so far, you may know you are working towards documenting this community development loan under the economic development hook, right?
So after you document all other aspects of the community development loan and you are down to documenting the creation of jobs for LMI individuals.
So you go to BLS.gov and you search for jobs that typically would be found in a restaurant, like cooks, waiters, bartenders. I tend to keep two or three, as an example is my backup files for examiners. And then you can drill down to the different geographies within Bureau of Labor Statistics (BLS). So I recommend getting as close as you can to the geographic location of the business that you are documenting the community development loan for aka “follow the money” to the community development impact.
Here is the link to the screen share overview of BLS.gov: https://www.loom.com/share/2ae5b997547343a2b33ce9413db17598
You would take these representative jobs and compare the salaries against area median income to make sure these annual salaries fall below the thresholds for a moderate-income person in the area for which the loans proceeds are applied.
I hope this helps you as you continue to mine for community development loans and then also document your CD loans. I often say, if it’s not properly document, it didn’t really happen! The “art of the CRA” as I say is to properly document all of your activities to support an efficient review by your examiners and this “pre-work” if you will will also allow you to defend your position with confidence.
CRA Today provides Community Reinvestment Act Training, Professional Development, and a new Certification for CRA professionals. We Help You Master the CRA, Get Exam-Ready, and Reinvest for the Greater Good.
Want to learn the CRA basics? Sign up for CRA Essentials Live! A live webinar with Linda Ezuka that shares everything you need to create a solid foundation for your CRA journey. https://hub.cratoday.com/freewebinar
Ready to take a deeper dive into the CRA? Join your fellow CRA enthusiasts in the CRA Hub as we navigate regulatory change, study core CRA concepts and connect as community development professionals across the nation.
https://cratoday.com/hub/
CRA Today Website: https://cratoday.com/
Linda Ezuka, LinkedIn: https://www.linkedin.com/in/linda-ezuka-cra-today/
Copyright © 2022 by CRA Today LLC
(No claim to original U.S. government material)
All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.
This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.
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Well, this is where the website bls.gov comes in. This website will help you substantiate the creation or retentions of jobs for low and moderate income people. The BLS website is where you can go to create the documentation or the proof, to show your examiners during an exam to substantiate community development loans and activities, as applicable.
So let’s take a $1.5M community development loan that your bank originated to a restaurant to expand to a new location. You would first document that the borrower is considered a small business and then you will need to document and prove that the majority of the jobs created as a result of your financing would in fact be jobs for low and moderate income individuals.
Given my description so far, you may know you are working towards documenting this community development loan under the economic development hook, right?
So after you document all other aspects of the community development loan and you are down to documenting the creation of jobs for LMI individuals.
So you go to BLS.gov and you search for jobs that typically would be found in a restaurant, like cooks, waiters, bartenders. I tend to keep two or three, as an example is my backup files for examiners. And then you can drill down to the different geographies within Bureau of Labor Statistics (BLS). So I recommend getting as close as you can to the geographic location of the business that you are documenting the community development loan for aka “follow the money” to the community development impact.
Here is the link to the screen share overview of BLS.gov: https://www.loom.com/share/2ae5b997547343a2b33ce9413db17598
You would take these representative jobs and compare the salaries against area median income to make sure these annual salaries fall below the thresholds for a moderate-income person in the area for which the loans proceeds are applied.
I hope this helps you as you continue to mine for community development loans and then also document your CD loans. I often say, if it’s not properly document, it didn’t really happen! The “art of the CRA” as I say is to properly document all of your activities to support an efficient review by your examiners and this “pre-work” if you will will also allow you to defend your position with confidence.
CRA Today provides Community Reinvestment Act Training, Professional Development, and a new Certification for CRA professionals. We Help You Master the CRA, Get Exam-Ready, and Reinvest for the Greater Good.
Want to learn the CRA basics? Sign up for CRA Essentials Live! A live webinar with Linda Ezuka that shares everything you need to create a solid foundation for your CRA journey. https://hub.cratoday.com/freewebinar
Ready to take a deeper dive into the CRA? Join your fellow CRA enthusiasts in the CRA Hub as we navigate regulatory change, study core CRA concepts and connect as community development professionals across the nation.
https://cratoday.com/hub/
CRA Today Website: https://cratoday.com/
Linda Ezuka, LinkedIn: https://www.linkedin.com/in/linda-ezuka-cra-today/
Copyright © 2022 by CRA Today LLC
(No claim to original U.S. government material)
All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.
This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.
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Author | Linda Lewis Ezuka |
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