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.

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