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No. 63 Fall 2006

PUBLISHED BY THE

A COMMUNITY DEVELOPMENT PUBLICATION

CASCADE

COMMUNITY AFFAIRS
DEPARTMENT OF THE
FEDERAL RESERVE BANK
OF PHILADELPHIA

INSIDE:
2 — Message from the
Community Affairs Officer
3 — New Markets Tax Credits
Help Revitalize Trenton
4 — Wilmington Encourages
Owners to Rehabilitate or Sell
Vacant Property
6 — How Do Those Involved
Assess Wilmington’s Redevelopment?
7 — Rural Census Tracts and
Disaster Areas Become CRAEligible
8 — Spotlight on Research:
Impact of the Community
Development Block Grant
Program
10 — New Office Buildings Are
Underway in Wilmington,
But Will Demand Match
Supply?
11 — Public-Private Partnership
Tackles Blighted Housing
12 — What Is the New Markets
Tax Credit Program?
16 — Calendar of Events

Leaders Look to Market-Rate Housing to Foster
Wilmington’s Revitalization
By Keith L. Rolland, Community Development Advisor
City leaders and developers are hopeful that
market-rate housing will
revitalize Wilmington,
Delaware’s downtown
and riverfront areas,
revive a sluggish retail
sector, and attract young
professionals who work
in the city’s expanding
array of office buildings.
Wilmington, a city of
10.8 square miles with
about 73,000 residents,
was settled by Swedish,
Christina Landing opened late last year on Wilmington’s Christina River
Dutch, and British immiand includes 63 townhouses and a 23-story apartment tower. Delaware
grants and was incorstate agencies provided infrastructure improvements for roads and sidewalks and remediation of environmentally contaminated land.
porated in 1739. Located
about 25 miles south of
and riverfront totals about $1 billion since
Philadelphia, Wilmington became a major
the mid-1990s.
shipbuilding center in the Civil War and
had thriving steel foundries and chemical
The majority of Wilmington’s market-rate
industries during World War I. During
housing has been built by the Buccini/Pollin
the past 25 years, the financial services inGroup, a privately held real-estate acquisidustry has replaced the DuPont Company
tion, development, and management comas the major employer.
pany.1 In 1999, Buccini/Pollin converted the
Nemours building into offices, retail, and 85
City officials estimate that about 1,000
extended-stay units for business travelers. In
market-rate housing units have been built
2002, it created 278 luxury apartments in the
in Wilmington since 1999 and that private
fire-damaged Delaware Trust building, now
and public investment in the downtown

...continued on page 5

1

Buccini/Pollin’s primary source of construction financing for its housing developments in Wilmington and other cities
has been Bank of America, starting with financing the firm obtained for projects in Boston from Fleet Bank (which was
acquired by Bank of America).

w w w. p h i l a d e l p h i a f e d . o r g



CASCADE

No. 63
Fall 2006

CASCADE is published four times a year by the
Federal Reserve Bank of Philadelphia’s Community Affairs Department. It is available on the
Bank’s website at www.philadelphiafed.org.
Material may be reprinted or abstracted provided
CASCADE is credited. Please send the Community Affairs Department a copy of reprints
of CASCADE articles. The views expressed
in CASCADE are not necessarily those of the
Federal Reserve Bank of Philadelphia or the
Federal Reserve System. CASCADE, which has
been published since 1984, derives its name
from White Cascade, a large mobile designed by
Alexander Calder that revolves in the Philadelphia Fed’s atrium.
Send comments and suggestions to Keith L.
Rolland at (215) 574-6569 or keith.rolland@
phil.frb.org. Send address changes and requests
for subscriptions or additional copies to Kenyatta
Burney at (215) 574-6037 or kenyatta.burney@
phil.frb.org.
COMMUNITY AFFAIRS DEPARTMENT
Kenyatta Burney
Senior Staff Assistant
(215) 574-6037
kenyatta.burney@phil.frb.org
Jeri Cohen-Bauman
Secretary
(215) 574-6458
jeri.cohen@phil.frb.org
Christy Chung Hevener
Consumer Specialist
(215) 574-6461
christy.hevener@phil.frb.org
Andrew T. Hill, Ph.D.
Economic Education Advisor
(215) 574-4392
andrew.hill@phil.frb.org
Amy B. Lempert
Community Development Advisor and Manager
(215) 574-6570
amy.lempert@phil.frb.org
Erin Mierzwa
Community Development Specialist
(215) 574-6641
erin.mierzwa@phil.frb.org
Dede Myers
Vice President and Community Affairs Officer
(215) 574-6482
dede.myers@phil.frb.org
Keith L. Rolland
Community Development Advisor
(215) 574-6569
keith.rolland@phil.frb.org
Marvin M. Smith, Ph.D.
Community Development Research Advisor
(215) 574-6393
marty.smith@phil.frb.org
John J. Wackes
Community Affairs Specialist
(215) 574-3810
john.j.wackes@phil.frb.org
Todd Zartman
Economic Education Specialist
(215) 574-6457

todd.zartman@phil.frb.org

Message From the Community
Affairs Officer
All around the Third District, we see
evidence of cities reinventing themselves. Public officials and private
citizens are working together to reverse
a downward trend started decades
ago. Earlier this summer we visited
Scranton, where a new hotel and two
parking garages were built downtown
and plans to substantially upgrade
commercial buildings on a main artery were being finalized. Some nonprofit housing developers also noted
that their efforts buying, renovating,
and selling homes for moderate-income families had spurred the private
builders to do the same. In this issue
of Cascade, we talk about efforts in two
other cities – Wilmington, Delaware,
and Trenton, New Jersey.

the NMTCs will be as valuable to
community economic development as
the low-income tax credits have been
to rental housing.

In Wilmington, the revitalization is
happening on two fronts, downtown
and along the riverfront, and there are
other efforts throughout the city. The
downtown and riverfront developments include residential and commercial buildings, some newly constructed,
some in existing structures. The citywide efforts include one to reduce the
inventory of vacant properties, both
land and buildings, and another to
provide affordable housing for lowincome families.

For that reason, Marty Smith has
reviewed a study George Galster and
co-authors conducted on the impact of
the CDBG program in 17 cities around
the country. While the authors thought
better data were needed, they did show
that after a certain threshold, a change
in housing values was identified.

In Trenton, we have stories about redevelopment using new market tax
credits (NMTCs). Although the program had a slow start, it has picked
up steam. We write about projects
using Wachovia’s and the New Jersey
Economic Development Authority’s
tax credits. While the projects are still
new, it looks like both will strengthen
Trenton by bringing jobs to the downtown. Early indications suggest that

Most urban revitalization still requires
subsidy to make a redevelopment
project possible, and often one of the
sources of funds is the federal Community Development Block Grant (CDBG)
program. While most people can see
a visual change from community development efforts, we at the Fed are
interested in measuring the economic
outcome or impact of these efforts. In
the long run, we believe we can help
community developers everywhere if
we help provide techniques and results
for measuring impact.

Subsequently, the Richmond Fed hired
Galster to conduct a similar study in
Richmond, where the results, bolstered by better information from the
city and the Local Initiatives Support
Corporation on public- and privatesector rehabilitation efforts, demonstrated that at a threshold of $20,100
per block, improvements in several
measures, including crime reduction
and increased housing values, could be
demonstrated. After reading Marty’s
review, look for the Richmond study,
“Neighborhoods in Bloom,” at www.
richmondfed.org/community_affairs.

New Markets Tax Credits Help Revitalize Trenton
By Erin Mierzwa, Community Development Specialist
Trenton has been struggling with its
urban revitalization efforts for the
past few decades. The federal new
markets tax credit (NMTC) program has proved to be a useful tool
in recent efforts to bring back New
Jersey’s capital.
There are several factors that hinder
Trenton’s redevelopment, according to Mayor Douglas H. Palmer:
“The city is only 7.5 square miles
and the state owns one-third of the
land. Trenton is not able to obtain
the tax revenue that other major
cities are able to obtain due to the
large volume of tax-exempt property.
Highways separate the city from the
waterfront area. In addition, surface
parking lots account for much of
the available space for development
downtown.”
Despite these obstacles, the city of
Trenton has been actively promoting urban revitalization efforts,

which include developing several
mixed-use projects, renovating the
Trenton train station area, increasing the number of affordable and
market-rate housing units, and redeveloping former industrial sites
and historical buildings. Mayor
Palmer hopes these efforts will
bring more private-sector businesses downtown.
In the last two years, NMTCs have
been used for the new construction of a building at 32 East Front
Street and the rehabilitation of the
historic Roebling mansion at 222
West State Street.
32 East Front Street
The 32 East Front Street site was
originally a large surface parking
lot that was acquired by the Economic Development Corporation
of Trenton (EDCT). EDCT partially
constructed an office building at
...continued on page 13

Wachovia Moves Its
Regional Headquarters
to Trenton
Susanne Svizeny, regional president of Wachovia Bank’s central
and southern New Jersey region, recalls that last year when
Wachovia’s lease for its headquarters in Ewing Township
was expiring, the bank began to
explore opportunities to relocate
to Trenton. After evaluating several options, Wachovia moved
its headquarters to 32 East Front
Street in downtown Trenton and
signed a 10-year lease with the
building’s owner, Matrix Development Group.
Svizeny explained: “Wachovia
selected Trenton because it is an
important market for us. Economic factors did not lead to this
move, as there were comparable
alternatives in suburban areas.
Wachovia selected Trenton
because it was the right business
decision and we wanted to be
part of the economic revitalization efforts of the capital city.”
In the move, 125 Wachovia
employees were relocated to
Trenton. Svizeny noted that
“Wachovia does not have a
cafeteria in this building and
the employees are going out to
have lunch and support the local businesses.” The space that
Wachovia is leasing provides the
capacity to increase the number
of its employees in the building
to 160.

Wachovia Bank moved its regional headquarters from Ewing Township, N.J., to the top three
floors of this building, owned by Matrix Development Group, at 32 East Front Street in Trenton, N.J. (Photo provided by Jim Gerberich)



Wilmington Encourages Owners to Rehabilitate or Sell
Vacant Property
The number of privately owned
vacant properties in Wilmington has
dropped 22 percent since the city
started a vacant property registration
program nearly three years ago.
Jeff Starkey, the city’s commissioner
of licenses and inspections, said:
“The whole purpose of the program
is to get the properties reoccupied.
Left vacant, they are a blight in the
community and become havens for
negative activities. In addition, these
properties don’t contribute anything
to the city’s efforts to revitalize communities.”
Starkey said that the program, which
applies to all vacant structures, was
a major reason for the reduction of
privately held vacant properties.
Other factors involved in the reduction include the fact that the city was
just beginning to develop a database
to track the properties when the
program was launched, and some
city programs that targeted several
neighborhoods resulted in a number
of rehabilitated properties, he said.
The number of privately owned
vacant properties has been reduced
from 1,455 in November 2003 to 1,128
at the end of September 2006, according to Starkey. The 1,128 properties, which include 55 Wilmington
Housing Authority houses and three
HUD-owned houses, represent 4
percent of roughly 28,000 residential
and commercial properties in Wilmington.
How the Program Works
An owner of a building that has been
vacant for more than 45 days must
file a notarized registration statement



with contact information. The city
assesses an annual registration fee
to each vacant property that has
been vacant for at least one year.
The fee is based on the number of
years the property has been vacant
regardless of varying ownership
and ranges from $500 to over $5,000.

In 2005–06, 650 registration fee notices
were mailed to vacant property owners; owners later obtained rehabilitation or construction permits totaling
$15.2 million. Also, 275 vacant property owners paid fees totaling $535,500,
and the city issued more than 220
summonses to noncompliant owners.

The fee is billed each year in
November and owners have until
November 30 to provide proof that
their property is being rehabilitated, demolished, sold or leased, or
request an appeal or waiver. The fee
must be paid in full by January 1.

The program has withstood a legal
challenge in Delaware Supreme Court.

The city can issue a summons for
noncompliance and can recommend properties for sheriff’s sale, a
process that typically takes three to
six months, Starkey said.
Permits
In 2003–04, the first year of the
increased fee schedule, 950 registration fee notices were mailed to vacant property owners; owners later
obtained rehabilitation or construction permits totaling $9.2 million,
according to city records. Also, 36
property owners paid fees totaling
$55,000, and the city issued more
than 172 summonses to owners who
were noncompliant with program
requirements.
In 2004–05, 677 fee statements were
mailed to vacant property owners;
owners later obtained rehabilitation
or construction permits totaling
$6.8 million. In addition, 129 vacant
property owners paid fees totaling
$217,000, and the city issued more
than 400 summonses to noncompliant owners.

Award
In June, the city of Wilmington received a City Livability Award for
outstanding achievement in the vacant
property program. The award is jointly
sponsored by the U.S. Conference of
Mayors and Waste Management Inc.
City-Owned Properties
Meanwhile, the city has reduced its
own stock of vacant properties. As of
the end of July 2006, the city owned
49 vacant properties, down from 68
in 2003. These numbers include city
properties being redeveloped as green
space or low-cost housing.
In the past five years, the city has
granted or sold 218 properties to private and nonprofit developers to establish new rental and ownership housing
or neighborhood parks and gardens.
During that time, the city acquired 74
additional vacant properties because
owners failed to pay taxes or neglected
or abandoned properties.
For information, contact Jeff Starkey at
(302) 576-3031 or jstarkey@ci.wilmington.
de.us, or Cynthia Ferguson, vacant property administrator, at (302) 576-3096 or
cferguson@ci.wilmington.de.us; www.
ci.wilmington.de.us.

Leaders Look to Market-Rate Housing to Foster Wilmington’s
Revitalization
...continued from page 1

called The Residences at Rodney
Square. According to Buccini/Pollin,
apartments in both buildings are
about 90 percent leased.
Buccini/Pollin developed Christina
Landing, a nine-acre complex on
the Christina River that opened
late last year with 63 townhouses,
173 apartments in a 23-story tower,
a river walk, park, roof-top pool,
and parking. A 25-story tower with
180 condominiums is under construction. The development is near
Wilmington’s Amtrak station and
Interstate 95.
The townhouses sold in less than
four weeks for $300,000 to $450,000
and have since risen in value, surprising even some long-term Wilmingtonians. About 52 percent of the
173 apartments are leased, while 88
percent of the condominium units
are sold, Buccini/Pollin said.2
Buccini/Pollin is also developing Justison Landing, a $500 million 10-acre
project on previously industrial and
vacant land on the Christina River a
half-mile from Christina Landing. In
the next five years, Justison Landing is planned to have nearly 700
residential units (including townhouses, condominiums, loft units,
and apartments), 55,000 square feet
of retail space, 300,000 square feet of
commercial space, and several parking garages. Construction started
in June 2006 on 316 condominiums
with expected sale prices of $240,000
to $700,000 and 25 townhouses with
expected sale prices of $450,000 to
$1.5 million.

Ships
Tavern
Mews

Barclays Bank

...continued on page 12

			
2

Units that are “sold” have binding contracts
with secured escrows pending settlement,
according to Buccini/Pollin.

Key Development Sites and Landmarks in Wilmington’s Downtown and Riverfront Area.
Map provided by P.J. Hernandez of the City of Wilmington, Division of Mapping and Graphics.



How Do Those Involved Assess Wilmington’s Redevelopment?
Cascade asked six people who have had a
role in Wilmington’s revitalization for their
responses to three questions. Three other individuals shared their views when they learned
about this exercise. Edited comments from the
nine individuals appear below.
In what way(s) has Wilmington’s downtown revitalization been successful?
Michael Hare, Deputy Director, Riverfront Development Corporation of
Delaware (RDC): Public-sector investment of $200 million on the riverfront
leveraged about $650 million of private
investment that’s in the ground or committed. More than 350 acres of contaminated land that lay fallow for five decades
has been remediated and put into active
use.
Douglas Hazelton, Executive Vice President, Bank of America, Wilmington: For
a long time, there was a fairly steady level
of development by nonprofits that did
new construction and rehabilitation. The
nonprofits’ work, and the strong support
by the state and city for the RDC, served
as a catalyst that convinced for-profit
developers that there was an opportunity
for market-rate housing in Wilmington.
Michael Skipper, Vice President,
Wilmington Savings Fund Society:
Wilmington’s downtown has achieved a
stronger balance of commercial and residential space through the conversion of
upper stories of commercial buildings to
residential condominium or rental space.
The development of residential space
has provided a stabilizing influence as
commercial entities have downsized over
previous years.
What challenges remain?
Jayne Armstrong, Director, Delaware
District Office, U.S. Small Business
Administration: It will take several
years for the influx of residents to drive
the demand for business development
throughout the entire downtown area.
An analysis of what’s missing should
be conducted and then businesses that
support market-rate housing should be
*

recruited. A challenge facing our
community is nurturing the overall
entrepreneurial mindset.
Hon. James Baker, Mayor of
Wilmington: One of the challenges
is convincing Wilmingtonians that
change is possible. People within a
community often don’t believe in their
own success. We also need to improve
transportation. We started a trolley on
wheels and we’d like to connect the
city with trolley service.
Christopher F. Buccini, Managing
Partner, The Buccini/Pollin Group:
We need a critical mass of people
living here. More density will result
in more retail, which is our biggest
challenge.
Douglas Hazelton: One of the next
challenges is acquiring and rehabilitating some very poor housing stock
in some distressed parts of Wilmington. This will require government subsidy and the involvement of the public
and possibly banking sectors.
Don Meginley, President, Preservation Initiatives: One of the greatest
needs is bringing upscale retail back
to Market Street. Initial tenants will
be local boutique stores or restaurants. Rent levels must be artificially
low in some cases to attract a tenant
to take the initial risk. Also, development must happen block by block, not
building by building.
Michael Skipper: Two of the challenges to continued downtown
revitalization are the development of
a strong retail sector and the provision of affordable as well as marketrate housing in the downtown and
riverfront areas. There has been some
retail growth, primarily restaurants,
but the downtown area still provides
few entertainment options and retail
shopping is limited to small specialty
items and discount stores.
What are the lessons learned for the
benefit of those in other cities pursuing downtown revitalization?

Hon. James Baker: There must be a
will to make things happen because
rebuilding downtown is very complicated and usually painfully slow. Also,
we enabled developers to meet early
in the planning process with a group
of people from the economic development, public works, and parking
departments, the mayor’s office, RDC,
and Wilmington Renaissance Corporation. Developers meet the people they
need to work with. If there’s a problem,
we learn about it early and find a way
to make the project work.
Christopher F. Buccini: It makes sense
to build things in stages. If one stage
goes wrong, you can stop and fix it.
Michael Hare: The ability to demonstrate progress immediately is key to
sustaining a development effort. It’s
important, too, to have people in power
engaged in the process and participating in decisions on projects.*
Douglas Hazelton: In any community
undergoing downtown revitalization,
it’s desirable to have good cooperation
on the community development side
among banks, which are normally competitors. In Wilmington, there’s been
a great deal of cooperation, enabling
banks to spread the risk and have three
or four sets of eyes looking at a deal.
Doris Schnider, President, Delaware
Community Investment Corporation:
Cities trying to revitalize their downtowns ought to know that a project’s
initial success cannot be taken for
granted. The former Market Street Mall
in Wilmington, which started well, is
one such example.
Carrie White, Managing Director,
Wilmington Renaissance Corporation: A nonprofit intermediary that
wants to buy, hold, and sell properties for development needs working
capital in order to do so. Also, it’s better
to make infrastructure and aesthetic
streetscape changes in a sizable area all
at once because it has greater impact,
rather than one block at a time.

RDC’s board includes the governor of Delaware, mayor of Wilmington, New Castle County executive, Wilmington city council president, two co-chairs of the
state’s capital budget committee, and two co-chairs of the state’s joint finance committee.



Rural Census Tracts and Disaster Areas Become CRA-Eligible
By John J. Wackes, Community Affairs Specialist
Financial institutions can now get
CRA consideration for community
development activities in 35 previously ineligible rural census tracts
in Pennsylvania.
Last year, interagency rules applicable to all banks subject to CRA expanded the definition of community
development to include activities
that revitalize or stabilize distressed
and/or underserved rural areas and
designated disaster areas. The Board
of Governors of the Federal Reserve
System (FRS), the Federal Deposit
Insurance Corporation (FDIC), and
the Office of the Comptroller of
the Currency (OCC) said in a press
release: “By including distressed
and/or underserved rural areas, the
agencies intend to recognize and
encourage community development
in more rural areas.” On April 12,
2006, the Office of Thrift Supervision (OTS) revised its definition of
community development to include
distressed, underserved, and designated disaster areas, mirroring the
other agencies.
The FRS, FDIC, OCC, and OTS (the
agencies) list the distressed or underserved rural areas on the website
of the Federal Financial Institutions
Examination Council (FFIEC). As
of July 27, 2006, the list includes
three categories of census tracts in
Pennsylvania: 13 distressed tracts
in Warren and Montour counties;
nine underserved tracts in Fulton,
Juniata, and Sullivan counties; and
13 distressed and underserved tracts
in Forest and Susquehanna counties.
Most of these tracts were on the
agencies’ original list posted in 2005.
About 185,000 Pennsylvania residents live in the 35 tracts, according
to the 2000 census. The latest list of

distressed or underserved tracts
does not include any tracts in New
Jersey or Delaware.
In rural areas, the population is
less dense and poverty is more
dispersed than in urban areas. As a
result, rural census tracts tend to be
middle income, although pockets of
low- and moderate-income individuals reside within them.
Distressed Areas
The agencies use the criteria for
distress followed by the CDFI
Fund: an unemployment rate at
least one-and-a-half times greater
than the national average; a poverty rate of 20 percent or more; population loss of 10 percent or more
between decennial census years;
and net migration loss of 5 percent
or more over the five-year period
prior to the most recent census.

Underserved Areas
The agencies define underserved
areas using data from the United
States Department of Agriculture
Economic Research Service (ERS).1
In these areas, the population is so
small and distant from a population
center that the communities have
difficulty financing essential community needs. In many cases, these
tracts are removed from basic amenities like hospitals or clinics and
require water and sewer, health-care
facilities, and other infrastructure.
Distressed and underserved areas
are updated and reviewed by the
FFIEC on an annual basis. The
agencies may consider CRA-related activities in distressed and/or
Underserved geographies have one of four ERS
“urban influence codes.” More information is
available at http://www.ers.usda.gov/briefing/
rurality/urbaninf.
1

...continued on page 15

Underserved and/or Distressed Middle-Income Nonmetropolitan
Geographies in Pennsylvania
Underserved Areas

Sources: FFIEC and ESRI, Inc. of Redlands, CA.
Note: Information provided is as of July 27, 2006. Information is reviewed and updated annually
by the agencies. CRA-related activities may be considered for up to one year after geographies
are removed from the list of distressed or underserved tracts.




Measuring the Impact of the Community Development Block
Grant Program
For over 30 years, many neighborhoods across the nation have been
receiving financial assistance from
the federal government to improve
housing and other community facilities in the form of grants from the
Community Development Block
Grant (CDBG) program.
According to George Galster, Christopher Walker, Christopher Hayes,
Patrick Boxall, and Jennifer Johnson,
much research has been done on
“where and how CDBG funds have
been spent, which groups have been
the prime beneficiaries, how efficient
the plans and their implementation
have been, and what political forces
lie behind these allocations,” but
little has been done to measure the
program’s impact. Galster and his coauthors have conducted a study that
endeavors to fill this void.1
Origins of the CDBG Program
The CDBG program was established
by the Community Development Act
of 1974. The program provides for
federal funds to be allocated to local
governments to assist them in accomplishing various goals, including
“arresting the deterioration of property and neighborhood and community facilities, removing conditions
detrimental to health and safety, conserving the housing stock, improving community services, promoting
income integration and neighbor1

hood diversity through spatial
deconcentration of assisted housing
and revitalization of deteriorating
neighborhoods, and stimulating
private investments in areas with
population outmigration and stagnating tax bases.”2
Policymakers have come to expect
that recipients of federal funds
demonstrate the effectiveness of
their program expenditures. This is
true of the CDBG program as well.
Methodology
The authors make several key
formulations that shape their assessment of the CDBG program.
First, they point out that neighborhood improvements resulting from
CDBG investments can be both direct (upgrading the housing stock)
and indirect (funding a project that
would make the neighborhood attractive to private investors). Next,
they note that many community
development practitioners and
scholars maintain that “a critical
mass of improvements is needed to
trigger changes in the perception
of investment prospects in a distressed neighborhood, but that once
this critical mass [or threshold] is
achieved, the pace of neighborhood
improvements accelerates.” Further,
the authors expect that regardless of
whether the CDBG investments are
above or below the threshold, the

Marvin M. Smith, Ph.D.
Community Development
Research Advisor

neighborhood effects of the investments will depend on the general
conditions of the city and the preexisting conditions and growth plans
in the targeted neighborhoods.3
The authors devised a statistical
model to measure the relationship
between the annual CDBG expenditures per poor resident (averaged
over the 1994–96 period) in neighborhoods (identified by census tracts)
across 17 large cities and subsequent
changes in several neighborhood
indicators from 1994 to 1999.4 The
sample cities were chosen to cover all
U.S. regions and include the following: Birmingham, Boston, Charlotte,
Cleveland, Columbus (Ohio), Denver,
Fort Lauderdale, Houston, Indianapolis, Long Beach, Los Angeles,
Milwaukee, Oakland, Portland (Ore.),
Providence, Tulsa, and Washington.

“Measuring the Impact of Community Development Block Grant Spending on Urban Neighborhoods,” Housing Policy Debate 15, 4 (2004), pp. 903–34.
The authors point out that “the act did not require localities to adopt a specific mix of these activities, but rather allowed them to pick and choose those that,
in their view, best met the program’s intent.”
3
The authors include in these two categories the city’s economy, housing market, and social problems as well as the initial inventory of neighborhood assets
and liabilities (both current and projected).
4
Recognizing that not all of the effects of CDBG spending will occur in the year that the expenditures are made, the authors included a three-year lag structure
in their estimating model to account for the cumulative changes in the outcome indicators.
2



The authors adjusted the CDBG
spending for the “poor population in
the neighborhood because theoretically the impact of a given amount
of spending should differ depending on the depth of local needs and
regulatory requirements that such
spending primarily benefit low- and
moderate-income people.” They also
conducted some preliminary analysis to arrive at three indicators that
would be reasonable proxies for the
range of neighborhood outcomes
of most interest to scholars and
local policymakers. These indicators included “the home purchase
mortgage approval rate, the median
amount of the home purchase loans
originated, and the number of businesses.” The authors used data from
several governmental databases,
which they supplement with information from CDBG grantees.5
Results
Even after settling on CDBG expenditures per poor resident as the independent variable in their estimating
equations, the authors did not find
any “statistically significant, positive relationship between spending
and changes in [their] neighborhood
indicators when [they] analyzed either the full sample of census tracts
or only those with non-zero values
of CDBG spending.” It wasn’t until
the authors focused their analysis
on census tracts that had spending
above the sample-average CDBG
expenditures per census tract that
they observed statistically significant
results. They computed the annual
sample-average CDBG spending to
be $86,737 from 1994 to 1996. Thus,
the sample-average CDBG expenditures approximated a threshold
that had to be surpassed in order for
CDBG investments to yield statistically significant impacts.

While the authors are able to establish that a threshold or critical mass
of CDBG expenditures existed, they
are not able to identify it with any
precision. Therefore, they feel confident only in claiming that “below
roughly $87,000 in annual average
expenditure, significant neighborhood payoffs from CDBG are unlikely to be observed, rather than in
stating the precise level above this
amount at which sizable effects begin to ensue.”
In further analysis, the authors investigate the influence of neighborhood and city conditions on the capacity of CDBG investments to generate impacts. They chose trends in
median sales prices of single-family
homes as the best measure of the
neighborhood’s trajectory before
1994–96. The authors found that
“for all three outcome indicators, CDBG investments yielded
the highest per-dollar payoffs (as
evidenced by the size of the coefficients) in neighborhoods already
experiencing a strong upward trajectory of housing prices.”6
The authors also addressed the issue of spatial targeting of CDBG
spending. During the early years
of the CDBG program, spending
was widely dispersed by grantees.
However, an amendment to the
program in 1977 urged communities “to define areas for strategic investment … where concentration of
public resources would produce a
demonstrable difference over a ‘reasonable’ period of time.” However,
the federal effort at targeting CDBG
funds was abandoned in the early
1980s by pressure at the local level
in favor of distributing investments
more widely across urban neighborhoods. The authors indicated

that their research strongly supports
the spatial targeting of CDBG funds
so as to reach a critical mass (or
threshold) in order to demonstrably
improve neighborhood conditions.
Caveats and Future Research
Galster and coauthors point out
some caveats to their study and
suggest areas for further research.
They note that their analysis did
not include possible neighborhood
improvements that are not visible
and thus did not spur additional investment. “For example, investments
to the underground infrastructure
(water and sewer lines, for example)
may be critically important to sustaining urban services to a poor
neighborhood, but private investors
may not see them.” The authors
recommend that future research
include more comprehensive neighborhood indicators to capture the
positive effects of investments that
are not readily seen.
There were also deficiencies in the
data. The authors found that information on CDBG expenditures was
incomplete or missing for nearly all
cities. They caution that the procedures they used to allocate some
CDBG spending, while reasonable,
might have biased the measured effects toward zero. They suggest that
a replication of their analysis with
a more complete and accurate database would be instructive.7
Finally, the authors urge that future
researchers strive to verify the “notion of a threshold and, if possible,
to identify more precisely its value
and the degree to which it depends
on neighborhood and city context.”

5

The government data sources included CDBG expenditures from the U.S. Department of Housing and Urban Development, census data, Home Mortgage Disclosure Act data, and data from local administrative records of selected cities.
6
But the authors hastened to add that “even in the least hospitable contexts—highly concentrated neighborhood poverty, preexisting declines in home values,
weak city job growth—[their] estimates suggest that CDBG spending at above-threshold amounts produces significant improvements (both statistically and in
practical terms) in multiple measures of neighborhood conditions.”
7
In addition, Galster et al. reveal that data limitations precluded the use of more control variables in their study. The authors indicate that they “had no measures of other public or private investment that contemporaneously could potentially complement CDBG spending in some neighborhoods.” They hope that
future studies will develop more control variables to enrich the analysis.



New Office Buildings Are Underway in Wilmington,
But Will Demand Match Supply?
A boom in new office buildings in
the downtown and riverfront areas
of Wilmington is contributing to the
climate of revitalization in the city.
In major construction projects underway:
• The Wilmington Savings Fund
Society (WSFS) will be the lead
tenant and a minority owner in a
371,000-square-foot 16-story glass
tower being constructed by the
Buccini/Pollin Group.
• Barclays Bank plans to have about
900 jobs in a riverfront building
under construction.
• BlueCross BlueShield of Delaware
is consolidating its operations and
700-employee workforce from five
locations in New Castle County to
a 170,000-square-foot downtown
building under construction.
• The Commonwealth Group is developing The Renaissance Center,
a 150,000-square-foot office building and garage.

for seven property types in about 55
cities. It uses this assessment to rate
new commercial mortgage-backed
securities and to monitor existing
ones.
The Red-Yellow-Green reports for
the first and second quarters of 2006
listed the office market in Wilmington’s central business district (CBD)
in its highest-concern red zone, signifying “supply significantly greater
than demand or supply growth
alone very high.” In addition, the
first-quarter report listed the Wilmington suburban office market in
its highest-concern red zone, while
the subsequent report showed some
improvement, although still in the
red zone.
The second-quarter report noted
that Wilmington was one of only
three office markets nationwide
that had red scores in both its CBD
and suburban segments. It said:

“Although construction is expected
to slow and absorption to improve
in Wilmington compared to last
quarter, the degree of the remaining
supply-demand imbalance continues
to be worrisome.”
Sally Gordon, senior vice president
of Moody’s Investors Service and
author of the reports, said that data
for Wilmington’s CBD indicated a
healthy level of demand but also
excessive supply. She said that
Wilmington’s CBD is statistically a
small market and therefore the data
are relatively “volatile,” adding that
Wilmington’s real estate market score
includes “expectations” of job layoffs
resulting from Bank of America’s
acquisition of MBNA.
City officials are optimistic about
Wilmington’s ability to absorb the
additional office space. They note that
financial services employers and law
firms continue to add jobs.

About 35,000 people work in office
buildings in Wilmington, according
to city estimates. Many office jobs are
provided in Wilmington by limited-purpose and wholesale banks,*
full-service banks, other corporations,
and law firms. MBNA’s decision in
the mid-1990s to relocate 3,000 jobs
into downtown Wilmington was an
important stimulus at an early stage
of the city’s revitalization.
However, a report from Moody’s Investors Service warns that the supply
of office space in the city far exceeds
expected demand. Moody’s produces
quarterly Red-Yellow-Green™ reports
that reflect its assessment of the next
year’s expected demand and supply
*

ING Bank, also known as ING DIRECT, renovated this building, which was built in 1904
and served as the headquarters for the Delaware division of the Pennsylvania Railroad.
The building was designed by architect Frank Furness and is listed on the National Register of Historic Places. The bank has 850 employees in four buildings in Wilmington’s
downtown and riverfront areas.

Limited-purpose and wholesale banks established operations in Wilmington and other Delaware locations following passage of the Financial Center
Development Act of 1981.

10
10

Public-Private Partnership Tackles Blighted Housing
Some 2,700 people have purchased
homes developed or financed by the
Wilmington Housing Partnership
(WHP), a public-private partnership
that seeks to increase homeownership and improve housing conditions in Wilmington.
WHP, a 501(c)(3) formed in 1989 by
the City of Wilmington, acts as a
developer or obtains financing and
facilitates development by nonprofit
and for-profit developers.
Norma Zumsteg, a vice president
of community development banking for PNC Bank, Delaware, and
a member of WHP’s board during
the last two years, observed: “WHP
changed its direction in the last few
years from acquiring properties in
very deteriorated neighborhoods
to pro-actively targeting selected
neighborhoods that were basically
healthy but had some deterioration.
The targeting was a significant step
in the right direction. WHP is having more impact and that in turn is
helping WHP obtain more housing
development financing.”

WHP is targeting five neighborhoods in its residential improvement and stabilization effort (RISE),
a five-year program that is now in
its third year. Jerry Cain, WHP’s
executive director, said that it had
been very expensive for WHP to
acquire and hold a large inventory
of properties in past years. “Now
we take the tough [properties] with
the goal of getting investors and
homeowners interested in other
properties in the area,” Cain said.
WHP has completed 40 new homes
and rehabilitated 63 homes on
Wilmington’s east side, a RISE
neighborhood east of the central
business district.
WHP primarily assists low- and
moderate-income residents, but it
also participates in some projects
that attract middle- or upper-income buyers as part of a broader
goal to promote income diversity.
For example, WHP recently bought
a vacant warehouse and adjacent
deteriorated houses located about
a quarter mile from the Justison

Landing development and is remediating the three-acre site and doing
predevelopment and design work.
The warehouse will be demolished,
and WHP will issue a request for
proposals (RFP) to for-profit developers to build about 40 new units
that will have an expected sales
price of $250,000 to $275,000.
In January 2006, WHP acquired
a convenience store that had long
been the site of illegal drug activity
and plans to issue an RFP to build
18 homes, which are expected to
have a sales price of $160,000. WHP
expects construction of the homes to
start this winter. In addition, WHP
has provided land to Habitat for
Humanity of New Castle County,
which is building 17 units.
In 2005–06, 63 WHP-assisted units
were sold to buyers and 115 units
were in various stages of production.
WHP has three employees and is
primarily funded by banks, foundations, and state and city sources.
Of the $25 million raised by WHP,
approximately 65 percent has come
from banks, Cain said. Six banks
are represented on WHP’s board of
directors.
For information, contact Jerry Cain
at (302) 576-3000 or jerry.cain@
ci.wilmington.de.us; www.
wilmingtonhousingpartnership.com.

This photo shows part of the Kirkwood
I Manor project, which consisted of 14
newly constructed units and four rehabilitated units. The average selling price of the
units in 2002 was $90,000.

11

What Is the New Markets Tax Credit Program?
The new markets tax credit (NMTC)
program, established in 2000, is
administered by the U.S. Department
of the Treasury’s Community Development Financial Institution (CDFI)
Fund. The program provides individual and corporate taxpayers with
a credit against federal income taxes
for making qualified investments
in community development entities
(CDEs).
In order to offer tax credits to its
investors, an organization must be
certified as a CDE by the CDFI Fund
and must be selected to receive an
allocation under a competitive allocation round. CDEs that receive allocations can then obtain qualified equity investments from investors who
are looking to acquire stock, capital
interest in, or make a loan to the CDE
in exchange for the tax credits. A
CDE must use substantially all of the
qualified equity investment proceeds
to make investments in low-income
communities as defined by the IRS.
In addition, a CDE must issue at least
60 percent of its tax credit allocation
within the first five years of receiving
the award.
When investors provide qualified
equity investments to CDEs, they are
able to claim a tax credit equal to 39

percent of the original investment.
The credit is claimed over a sevenyear period. The credit is 5 percent
of the initial investment amount in
the first to third year and 6 percent
of the initial investment amount in
the fourth to seventh year.
Investors may not redeem their investment with the CDE prior to the
end of the seven-year period. Early
redemption triggers a “recapture
event” by the IRS, necessitating
the investor to repay (with interest
and penalties) any benefits received
from the credits. Recapture events
are also triggered if the CDE fails
to invest substantially all of the
tax credit proceeds in low-income
communities, or if it has its CDE
designation revoked by the CDFI
Fund.
The CDFI Fund is authorized to
allocate $16 billion in tax credit
authority through 2007, which
includes $1 billion to be allocated
to CDEs with a significant mission
of redevelopment in the Hurricane
Katrina Gulf Opportunity Zone.
The fund has administered four
allocation rounds to date and has
made 233 awards totaling $12.1
billion in tax credit authority. The
CDFI Fund will allocate the re-

maining $3.9 billion of allocation
authority in 2007.
The first round of allocations was
awarded in March 2003 and, since
the program is still relatively new,
there is not enough data to measure
the impact of completed projects.
The CDFI Fund does collect transaction-level data from its allocatees
annually. The fund recently released
data pertaining to allocatees’ fiscal
year 2004 reports. According to the
CDFI Fund, through the end of the
2004 fiscal year:
• NMTCs totaling $1.1 billion
were invested in 238 projects in
38 states, including the District
of Columbia.
• Three projects have been
completed in the Third Federal
Reserve District (in Reading and
in Philadelphia, Pa., and in New
Castle, Del.), with $28.7 million
in total NMTC investments.
Since the 2004 fiscal year, several additional projects have been financed
using NMTCs in all three states in
the Third District, including two
projects in Trenton, New Jersey, that
are described in an accompanying
article.
Information about the NMTC program
may be found at www.cdfifund.gov.

Leaders Look to Market-Rate Housing to Foster Wilmington’s
Revitalization
...continued from page 5

In a critical public-sector role,
Delaware state agencies provided
infrastructure improvements for
roads and sidewalks and remediation of industrial wasteland totaling
about $50 million at Christina Landing and about $85 million at Justison
Landing.
3

Two key organizations in Wilmington’s revitalization are the Riverfront
Development Corporation of Delaware (RDC) and the Wilmington
Renaissance Corporation (WRC).3
RDC, established with primary funding from the state and some contributions from the city and New Castle

County, has acquired and remediated environmentally contaminated
land, made improvements, and sold
the land and buildings to developers.
RDC provided site assistance and
the city provided financial incentives

Development has proceeded without a master plan that specifically covers the central business district and riverfront.

12

to ING Bank (which has 850 employees in four buildings), Barclays Bank,
and AAA Mid-Atlantic Inc. (which
relocated 400 jobs from Philadelphia).
RDC also facilitated development of
a riverfront market, two restaurants,
a river walk, and Chase Center on
the Riverfront.
WRC, a privately funded nonprofit,
has marketed the city’s downtown
and created a subsidiary to oversee
the redevelopment of the six-block
lower Market Street area, now
known as the Ships Tavern district.
The district was envisioned as a
neighborhood with retail on the
ground floor and housing on the
upper floors. Development of the district began six years ago and is being
done in stages.
In the first phase, known as Ships
Tavern Mews, Struever Bros. Eccles &
Rouse Inc. of Baltimore used historic
preservation tax credits in a $25 million project in the 200 block of North
Market Street to develop 86 upper-

floor apartments and 30,000 square
feet of ground-floor retail space.
The apartments are fully occupied
and the retail space is one-third to
one-half full, according to Carrie
E. White, WRC’s managing director. The National Trust for Historic
Preservation (NTHP) presented a
preservation award to the project’s
leaders in the fall of 2005.
In the district’s second phase, Preservation Initiatives of Philadelphia
is developing 40 residential units
and approximately 15,000 square
feet of retail space. Donald Meginley, the company’s president, said
that CityScape Capital Group LLC,
based in El Segundo, California,
will use both historic and new markets tax credits to provide a major
equity infusion in the project.
The city is working with the NTHP
to develop a Main Street program
that will try to get vacant retail
stores occupied and upgrade the
level of retail products and services

offered. The city is also converting
part of Market Street from a pedestrian-only thoroughfare to a twoway street. Meanwhile, Joseph G.
DiPinto, a Delaware state representative for the past 19 years, recently
became director of the Wilmington
Office of Economic Development.
The sense of recent interviews and
site visits is that Wilmington now
needs to recruit retail businesses
and create more entertainment
venues for people living in the city’s
market-rate housing while also
improving housing conditions and
creating job opportunities for the
city’s low-income residents.4
Wilmington has some advantages
compared to other cities as it faces
these challenges. It is a city of manageable scale, and there is a wellestablished tradition in which the
state, city, and business sectors work
together in close partnerships on
major development issues.

4

Census data show that in 1999 Wilmington’s poverty rate was 21.3 percent (compared to 9.2 percent statewide) and median family income was $35,116 (vs.
$55,257 statewide). Similarly, Wilmington’s homeownership rate in 2000 was 50.1 percent (vs. 72.3 percent statewide) while the city’s unemployment rate in
2005 was 6.3 percent (vs. 4.2 percent statewide).

New Markets Tax Credits Help Revitalize Trenton
the site, formerly known as Liberty
Commons, but failed to complete the
project. When construction stopped,
EDCT requested proposals from
developers to complete construction
and provide permanent financing.
Matrix Development Group, a private
for-profit real-estate development
company, successfully bid on this
project and acquired the site in the
summer of 2005, assuming all debt
and outstanding loans from EDCT’s
partially constructed building. Ma-

trix completed all major construction of the building by the end of
2005.
The $14.1 million project includes
three major funding sources:
• A $5.3 million, 10-year loan at
3 percent from the New Jersey
Economic Development Authority (NJEDA). The first seven
years are interest-only and the
final three years are amortized
based on a 25-year schedule.
NJEDA is providing the loan

•

•

...continued from page 3

from an NJEDA loan fund capitalized with NMTCs.1
A $6.7 million, 10-year permanent loan at a market interest rate
based on a 25-year amortization
schedule from Wachovia Bank.
The first year of the loan is interest-only to allow for construction,
lease-up, and stable operations,
followed by nine years with principal and interest payments.
$2.1 million in equity provided by
Matrix Development Group.
...continued on page 14

1

NJEDA was awarded a $125 million tax credit allocation in the second round and used $42 million of this allocation to create a loan fund that provides interest-only loans at 3 percent with at least seven-year terms to projects in economically distressed areas. To establish this loan fund, NJEDA sold approximately
$42 million in tax credits to an investor who, in exchange, provided NJEDA with an equity investment of $11 million. NJEDA contributed an additional $31 million in equity so that the total loan fund was equal to $42 million. The investor is claiming $16.38 million in tax credits over seven years. This project uses $5.3
million of the $42 million loan fund.

13

New Markets Tax Credits Help Revitalize Trenton
Donald Epstein, the chief financial
officer at Matrix, described the significance of NMTCs to this project:
“[They] allowed us to consolidate
previous debt on the project in a
very tight time frame and make
the deal work. We may have been
able to use sources of funding other
than NMTCs for this project, but
we would not have been able to
pull together the necessary amount

cable and designing the Brooklyn
Bridge, built several mansions
along West State Street during the
late 19th and early 20th centuries.
Located in Trenton’s State House
historic district, this is the only
remaining Roebling mansion.
The building was vacant for over
30 years, during which time a local
developer attempted to demolish
it. The city acquired the
building from the developer
in 1998 through eminent
domain. It remained vacant
for seven more years. In
2003, the Trenton Historical
Society’s Preservation Committee named the building
one of the “10 most endangered buildings” in Trenton.
Mayor Palmer knew this
building was an important
landmark and wanted to see
it rehabilitated. For several
years, Bill Dressel, executive
director of the New Jersey
State League of Municipalities, had
been looking for a larger building in the area and had hoped to
move closer to the State House. The
league acquired the building from
the city of Trenton in June 2005 for
$165,000.

This drawing illustrates how the historic Roebling Mansion, located on 222 West State Street in Trenton, N.J.,
will look when construction is completed by the end
of 2006. The original building is represented on the left
side of the drawing and the new wing is on the right.

of funding from all the different
sources we would have needed to
use in the time we had available.”
In January 2006, Wachovia relocated
its regional headquarters from Ewing
Township to Trenton and moved into
the top three floors of this five-story
building. Matrix is planning to lease
the office and retail space on the first
two floors to other private-sector
companies.
Roebling Mansion
New markets tax credits were also a
significant source of funding in the
restoration of the Ferdinand W. Roebling mansion. The Roebling family,
known for developing wire-rope
2

The $6.2 million project includes
four major funding sources:
• A $3.6 million loan from Wachovia using its NMTC allocation.2 The construction period
interest floats at market rate.
Upon construction completion,
lease-up, and stable operations,
the permanent loan will have a
73-month term with a 25-year

•

•

•

...continued from page 13

amortization, and the interest
rate will be reduced to 2.5 percent below the market’s forward
rate. In addition, Wachovia is
providing an 18-month marketrate bridge loan of $1,350,000.
A $1.39 million market-rate loan
from NJEDA, which takes out the
$1,350,000 bridge loan from Wachovia and a $40,000 predevelopment loan from NJEDA. The
loan has a 73-month term and is
based on a 25-year amortization
schedule.
A $750,000 capital preservation
grant from the New Jersey Historic Trust.
$420,000 in equity provided by
the New Jersey State League of
Municipalities.

Dressel emphasized that in order to
make this project work, the league
had to simultaneously coordinate all
funding sources, including NMTCs.
He also described the importance
of the partnerships: “In projects like
this one, it is extremely important to
establish meaningful relationships
with lending institutions that are not
only knowledgeable of the various
financial tools available but also have
appreciation for the redevelopment
of historical buildings. In this project,
the lenders looked beyond the terms
of the banking transaction and
focused on the significance of this
redevelopment effort for the city of
Trenton, the state of New Jersey, and
the historical community.”
Dressel said that the league will
maintain the historical integrity of
the building by restoring much of the
exterior and first floor, including the
library, staircase, foyer, front hallway,

Wachovia has been awarded a total of $383 million in tax credit authority in three of the four rounds of NMTC awards. In this project, Wachovia is using $3.6
million in tax credit authority, which will generate $1.4 million in tax credits to Wachovia over seven years. The tax credits are used to offset the interest income
lost from the below-market interest rate provided to the project, as well as the operational costs of administering the program.

14

entrance, and a large stained-glass
window. A new wing is being added
to the side and back of the building
to provide additional office space.
The league plans to move its headquarters to the former Roebling mansion when construction is completed
and will occupy approximately 7,500
square feet of the 15,000-square-foot
building. The remaining space will
be leased as offices.

For information, contact Russell Tepper
of Matrix Development Group at (732)
521-2900 or rtepper@matrixcompanies.
com; Bill Dressell of New Jersey State
League of Municipalities at (609)
695-3481, ext. 22 or bdressel@njslom.
com; Ed Covington of Wachovia Bank
at (215) 670-4344 or ed.covington@
wachovia.com; or Preston Pinkett, III,
of the New Jersey Economic Development Authority at (609) 777-4898 or
customercare@njeda.com.

Many historic aspects of the Roebling Mansion
in Trenton, N.J., such as the steel artwork over
the front door, will be preserved.

Rural Census Tracts and Disaster Areas Become CRA-Eligible
...continued from page 7

underserved geographies for up to
one year after the geographies are
removed from the list.
A Community Affairs Department
analysis of FDIC-insured financial institutions in Pennsylvania shows that
101 bank branches, or about 2 percent
of the total number of bank branches
in Pennsylvania, are located in distressed and/or underserved nonmetropolitan middle-income tracts.
Twenty-four financial institutions
operate the 101 branches.
Designated Disaster Areas
The agencies will also consider community development activities that
revitalize or stabilize designated
disaster areas, which are major
disasters designated by the federal
government, such as major disaster
declarations administered by the
Federal Emergency Management
Agency (FEMA). The Interagency
Community Reinvestment Act (CRA)
Questions and Answers Reflecting

2005 Regulation Changes (dated
March 2, 2006) provides guidance
on CRA-related community development activities in designated
disaster areas. Sections .12(g)(4)(ii)-1
and .12(g)(4)(ii)-2 define designated
disaster area and explain how revitalization or stabilization activities
are considered.2
The FRS, the OCC, the OTS, and the
FDIC have separately issued guidance for banks on obtaining CRA
consideration in Hurricane Katrina
and Hurricane Rita disaster areas.
Financial institutions regulated by
the FRS, OCC, OTS, and the FDIC located outside the Hurricane Katrina
and Hurricane Rita disaster areas
will receive consideration for activities that revitalize or stabilize the
areas, provided that the banks have
otherwise adequately met the needs
of their assessment areas. Financial
institutions with questions on this
issue should check with their regulatory agency for further guidance.

For a complete listing of middle-income
nonmetroplitan distressed or underserved
geographies, see the FFIEC website at
www.ffiec.gov/cra/examinations.htm
To see the Federal Register notice about
the CRA amendments, go to www.
gpoaccess.gov/fr. Indicate 2005 (vol.
70), p. 44256, 12 CFR Part 25. For the
interagency press release on the amendments, go to www.federalreserve.gov and
select news and events, all press releases,
and the release for July 19, 2005. The
Interagency Community Reinvestment
Act (CRA) Questions and Answers
Reflecting 2005 Regulation Changes may
be seen at www.ffiec.gov.
FEMA keeps an online list of all disaster
areas at www.fema.gov. For information
on CRA consideration in Hurricane
Katrina and Hurricane Rita disaster
areas, see the FRS Community Affairs
Letter No. CA-06-5 available online
at www.federalreserve.gov/boarddocs/
caletters/2006/0605/caltr0605.htm, or
the OTS Memorandum available online
at www.ots.treas.gov/docs/2/25232.pdf.

The Interagency Questions and Answers document said: “The Agencies generally will consider an activity to revitalize or stabilize a designated disaster area if it
helps to attract new, or retain existing, businesses or residents and is related to disaster recovery. An activity will be presumed to revitalize or stabilize the area if
the activity is consistent with a bona fide government revitalization or stabilization plan or disaster recovery plan. The Agencies generally will consider all activities relating to disaster recovery that revitalize or stabilize a designated disaster area, but will give greater weight to those activities that are most responsive to
community needs, including the needs of low- or moderate-income individuals or neighborhoods.”
2

15

Calendar of Events
Community Development Financing in Rural Pennsylvania
October 26, 2006, in Harrisburg, Pa.; November 14, 2006, in Beaver Falls, Pa.; and November 16, 2006, in DuBois, Pa.
These events – designed for banks, nonprofits, developers, and government agencies – include analysis of community and
economic development project financing from the perspectives of lenders and borrowers, CRA amendments, and new opportunities for bank and nonprofit involvement in state initiatives.
For information, see www.philadelphiafed.org/cca/conferences.html or contact Kenyatta Burney at (215) 574-6037 or kenyatta.burney@phil.frb.org.
Financial Education for Trainers from Houses of Worship
Two train-the-trainer events will be held in Philadelphia: from 9 a.m. to 1 p.m. on Saturday, Nov. 4 at Triumph Baptist
Church, 1648-52 Hunting Park Avenue near 16th Street; and on Saturday, Nov. 18 at White Rock Baptist Church, 5240
Chestnut Street.
These events are designed for church representatives who will train others in their congregations on personal finance subjects, such as credit, saving, and investment.
For information, see www.philadelphiafed.org/cca/conferences.html or contact Kenyatta Burney at (215) 574-6037 or
kenyatta.burney@phil.frb.org.
Homes Within Reach Conference
November 28–29, 2006, Harrisburg Hilton, Harrisburg, Pa.
This conference is organized by the Housing Alliance of Pennsylvania.
For information, contact info@housingalliancepa.org or (215) 576-7044; www.housingalliancepa.org.
Financing Community Development: Learning from the Past, Looking to the Future
2007 Federal Reserve System Research Conference
March 29–30, 2007, The Capital Hilton, Washington, D.C.
The Community Affairs officers of the Federal Reserve System are jointly sponsoring their fifth biennial research conference to encourage objective research into the factors governing the availability of credit and capital to individuals and
businesses within the changing financial services environment.
American Planning Association National Conference
April 14–18, 2007, Pennsylvania Convention Center, Philadelphia
For information, contact conference@planning.org or call (312) 786-6397; www.planning.org.
Congress for the New Urbanism XV: New Urbanism and the Old City
This event will be attended by architects, planners, government officials, and developers who are interested in improving
the quality of the built environment. Some of the leading architects and planners around the world are expected to attend.
May 17–20, 2007, Loews Philadelphia Hotel
For information, contact Sandrine Milanello at sandrinem@cnu.org; www.cnu.org.
CASCADE

Federal Reserve Bank of Philadelphia
100 N. 6th Street
Philadelphia, PA 19106-1574
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