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For release on delivery
3:45 p.m. EDT (12:45 p.m. PDT)
March 27, 2012

Building Sustainable Communities

Remarks by
Elizabeth A. Duke
Member
Board of Governors of the Federal Reserve System
at the
2012 National Interagency Community Reinvestment Conference
Seattle, Washington

March 27, 2012

I am pleased to participate in the ninth biennial National Interagency Community
Reinvestment Conference. Since its inception in 1996, this conference has fulfilled its
mission to train bankers and community development professionals on the requirements
of the Community Reinvestment Act (CRA) by providing cutting-edge information about
regulations, policies, and best practices in community development. In addition, it has
become a source of inspiration for CRA-related community development activities. As
this year’s agenda demonstrates, this interagency conference has grown to encompass all
aspects of community development, including discussions of community amenities that
provide both quality of life and economic resilience for low- and moderate-income
residents.
Before I begin, I would like to thank the thousands of community development
professionals I have met in the course of my work with the Federal Reserve for helping
me to understand the breadth of the work that they do. In fact, many of you are here
today. You have shown me your projects, shared your triumphs and frustrations, testified
at hearings on the future of CRA, served on our Consumer Advisory Council, and
actively participated in Federal Reserve conferences. Your counsel has given me a deeper
appreciation of the complexities involved in creating and maintaining strong
communities, particularly in times of economic stress. In my remarks today, I would like
to share some of these insights.
Background
With the enactment of CRA in 1977, Congress directed financial regulators to
assess each depository institution’s record of meeting the credit needs of its entire
community, including its community’s low- and moderate-income neighborhoods. In the

-2early years, even though CRA evaluations considered an institution’s provision of all
types of credit in lower-income communities, most were primarily focused on mortgage
credit. This was in part due to the availability of Home Mortgage Disclosure Act
(HMDA) data which made robust analysis of mortgage lending possible. In addition, the
focus of community development advocates on housing issues, including the redlining
practices that prompted CRA’s passage, eclipsed the law’s broad scope in public
perception. Only over time have community stakeholders come to appreciate the broader
context of CRA.
Today, financial institutions have become partners in community development,
bringing with them an important source of capital and financial expertise. By working
together, bankers, community development practitioners, state and local governments,
and other community stakeholders have learned a great deal, and the community
development field has matured significantly.
Places and People
At one time, policy discussions revolved around whether community development
was about people or places. I would argue that the debate is over and both sides won.
Successful community development is based on attention to both the physical
infrastructure, whether housing or commercial spaces, and the health and welfare of the
residents therein. CRA supports community development by requiring financial
institutions to identify and address the financial needs of the communities they serve.
Safe and affordable housing will always be an important concern for lowerincome Americans, but the recent recession and resulting damage to communities across
the country make it clear that communities are more than physical structures. Sustainable

-3communities--those that can weather economic downturns--not only provide decent
housing, but also have the resources to support individuals and families and to create a
dynamic business environment. For this reason, community development today is a
multidisciplinary exercise that challenges us to think holistically about how housing
relates to jobs, educational opportunities, transportation, healthcare, and other services
and amenities.
Neighborhood Stabilization
Taking a well-rounded approach is essential now, as weak national economic
conditions have caused particular hardships in lower-income communities, and have
stretched the federal, state, and local resources available to address neighborhood
stabilization and revitalization. In some areas, high rates of vacant and abandoned
properties resulting from foreclosures have depressed housing values, drained the coffers
of local governments, and created breeding grounds for crime and other social ills in what
were otherwise stable, albeit low-income, communities. The result has been a shift in
focus in community development, from building new housing to preserving or disposing
of existing housing.
In recent years, local governments and community-based organizations have
struggled to counter the effects of foreclosures on neighborhoods. Some communities
have found success by establishing land banks to manage low-value properties that might
otherwise sit vacant if left to the private market. 1 Land banks are typically public or

1

See Thomas J. Fitzpatrick IV (2010), “How Modern Land Banking Can Be Used to Solve REO
Acquisition Problems,” in REO and Vacant Properties: Strategies for Neighborhood Stabilization,
proceedings of the conference, REO and Vacant Properties: Strategies for Neighborhood Stabilization,
cosponsored by the Federal Reserve Banks of Boston and Cleveland and the Federal Reserve Board
(Washington: Federal Reserve Board of Governors), pp. 145-50,
www.federalreserve.gov/events/conferences/2010/reovpsns/downloads/reo_20100901.pdf.

-4nonprofit entities, often with a limited lifespan and sunset provisions. The notion of a
land bank, as opposed to a land trust, is that properties are brought in and moved out of a
land bank’s portfolio rather than permanently preserved. While part of the land bank’s
portfolio, foreclosed properties can be physically rehabilitated, rented, sold to new
owner-occupants or responsible investors, or, in some cases, demolished. Using this kind
of mechanism, a community can gain control of vacant properties and keep them from
causing problems for the surrounding neighborhood until market conditions are more
conducive to redevelopment or sale.
Land banks are just one example of the new approaches to housing issues that are
being pursued across the country, many with the assistance of the Neighborhood
Stabilization Program (NSP) administered by the Department of Housing and Urban
Development. The NSP program offers some funding to tackle these issues, but it also
provides a structure to bring community stakeholders together to identify the best
strategies for addressing foreclosures given the particular circumstances of each
community. Whether a community decides to purchase and rehabilitate homes for resale,
demolish vacant homes, or create land banks to help control the destiny of these
properties, the collaborative problem-solving approach used by NSP is one that can make
the most of limited resources.
Neighborhood stabilization is doubtless the precursor to community development
in some communities and, in recognition of this, the federal banking agencies amended
CRA regulations to specifically recognize neighborhood stabilization activities in
designated NSP areas as appropriate for CRA consideration.2 In addition, the Federal

2

See, 75 FR 79278 (Dec 15, 2010) amending the CRA regulations by revising the term “community
development” to include loans, investments, and services that support, enable, or facilitate projects or

-5Reserve has identified and shared a number of promising practices for dealing with
foreclosed and vacant homes.3 While some cities are pioneering with land banks, others,
such as Cleveland, Detroit, and Baltimore, are using data to plan for the future in ways
that city governments wouldn’t have imagined just a few years ago. Partnering with local
foundations, universities, and community organizations, these cities are collecting
extensive property data to identify neighborhood assets and build on those strengths.4 In
Phoenix, local officials and non-profits are partnering with local realtors to match
families with affordable homes for sale.
Unemployment
The foreclosure crisis that resulted from unsustainable subprime lending has
persisted largely because of high unemployment rates. Thus, in order to be successful,
any effort to stabilize and revitalize lower-income neighborhoods will need to consider
housing through the lens of access to jobs and educational opportunities. The Federal
Reserve System currently has an initiative underway to better understand the relationship
between community development activities and successful workforce development
strategies. We anticipate that this research will provide valuable information for bankers
and their community partners as they address the needs of their communities.

activities that meet the “eligible uses” criteria in the Housing and Economic Recovery Act of 2008 and are
conducted in designated target areas identified in NSP plans approved by the Department of Housing and
Urban Development.
3
See Federal Reserve Banks of Boston and Cleveland and the Federal Reserve Board of Governors (2010),
REO and Vacant Properties: Strategies for Neighborhood Stabilization, proceedings of the conference,
REO and Vacant Properties: Strategies for Neighborhood Stabilization (Washington: Federal Reserve
Board of Governors),
www.federalreserve.gov/events/conferences/2010/reovpsns/downloads/reo_20100901.pdf.
In addition, the Federal Reserve System created a series of video reports that highlight promising
stabilization work being done in Cleveland, Detroit, and Phoenix. These videos and related data tools can
be found at www.federalreserve.gov/communitydev/neighborhoodrevitalization/stablecommunities.htm.
4
See Board of Governors of the Federal Reserve System (2011), Putting Data to Work: Data-Driven
Approaches to Strengthening Neighborhoods (Washington: Board of Governors of the Federal Reserve
System, December), www.federalreserve.gov/communitydev/files/data-driven-publication-20111212.pdf.

-6Of course, having a job is one thing. Getting to it is another. With good reason,
transportation considerations have become more common in community development
plans in recent years. More communities are taking public transportation into account
when planning residential projects. Given the high cost of owning and operating a car,
transportation options are a significant factor in a neighborhood’s overall affordability.
Demographic shifts over the last decade have resulted in the suburbanization of poverty,
and now dictate that communities work together to create transportation options,
including buses, light rail, and even car-sharing arrangements.
Even so, as the Federal Reserve Bank of Richmond has discovered in its work on
car ownership for low-income workers, public transportation is not always sufficient to
solve the transportation problems of the poor. Some jobs, such as construction work,
require that workers report to different locations. Shift workers, whether security guards,
airport baggage handlers, or hospital workers, may not have easy access to public
transportation at night. Supporting nonprofit organizations, such as Vehicles for Change,
which takes donated cars and refurbishes them for sale to low-income workers for a very
small fee, may be the most effective means for some communities to overcome the
barriers to car ownership.5
One of the more innovative solutions to this issue that I have seen was developed
by an organization in Dallas that aims to move the jobs to the workers, rather than vice
versa. Lone Star Investment Advisors LLC is a private equity fund that invests in Texas
companies located in, or willing to move to, low-income census tracts. The fund's
managers have focused on manufacturing and distribution companies that can create jobs

5

More information about Vehicles for Change is available at www.vehiclesforchange.org.

-7in the state's lower-income communities. One of the businesses in the fund’s portfolio,
PrimeSource Food Service Equipment, moved from an affluent northern Dallas suburb to
South Dallas, where the poverty rate was higher than 40 percent, relocating more than
100 employees and hiring new employees from South Dallas. I raise this example
because it demonstrates what a little imagination can do to solve the problem of
connecting people with jobs. Moreover, this double bottom-line approach to
investments--making a profit while benefitting the community--makes this kind of
activity attractive to bankers with CRA obligations and other socially-minded investors.
Community Development: An Entrepreneurial Enterprise
This innovative example serves as a reminder that successful community
development is an entrepreneurial enterprise. Thinking about community development
this way reminds me of a presentation made at a recent Federal Reserve research
conference on small business and entrepreneurship.6 Amy Wilkinson, Senior Fellow at
Harvard’s Kennedy School Center for Business and Government, has conducted research
to identify the skill sets of high-impact entrepreneurs and small business leaders. The
skills she identified are, not surprisingly, applicable to community development. They
include being able to spot opportunities that others don’t see, managing complexity,
reiterating ideas and revamping plans repeatedly, experimenting and failing wisely,
networking to create solutions, and, as Amy put it, “unleashing generosity” in ways that
create reciprocity within the network.

6

Wilkinson, Amy (2011). Keynote address, delivered at the Small Business and Entrepreneurship during
an Economic Recovery Conference, Federal Reserve Board of Governors, November 10,
www.federalreserve.gov/mediacenter/files/wilkinson-transcript-20111110.pdf.

-8No doubt these sound familiar. Community development is an ongoing process
of identifying and understanding the complicated interaction of people and places.
Solutions are found through the cycle of experimentation and adjustment. Successes look
easy but they mask hard work and, often, failed attempts. Transformational changes in
communities rarely happen without the involvement and support of a network that
includes residents, business owners, community organizations, financial institutions, and
local government. Sustained interaction among these stakeholders is what makes the
opportunity known and the solution successful.
The city of Rochester, New York, put these principles to work and managed to
weather the bankruptcy of the city’s largest employer. Eastman Kodak once employed
some 61,000 Rochester residents and invested significantly in the city’s educational and
cultural institutions; three decades later, it employs fewer than 7,000 people and recently
filed for bankruptcy protection.7 This is not an uncommon story, except for the fact that
Rochester managed to gain a net of 90,000 jobs during the three decades of employment
decline at Kodak.
How did Rochester manage this transition so successfully? The city recognized
early on the need to diversify its economic base and, some 20 years ago, created a
network of private and nonprofit partnerships to leverage the city’s assets, the same
universities and cultural institutions Kodak had supported. Together with local
government, this network trained entrepreneurs and supported new business ventures,
many of which are in optics and photonics. Through foresight and the collaboration of
government, private and nonprofit partners, and committed citizens, Rochester was able
7

Applebome, Peter (2012). “Despite Long Slide by Kodak, Company Town Avoids Decay,” New York
Times, January 16, www.nytimes.com/2012/01/17/nyregion/despite-long-slide-by-kodak-rochester-avoidsdecay.html.

-9to build on the Kodak legacy, effectively turning lost jobs at Kodak into new local
opportunities.
Healthy Communities
In addition to housing and employment, residents need communities that support
their health and well-being in a variety of ways. Community developers play a critical
role in supporting healthy lifestyles by planning for sidewalks, parks, and other open
spaces connecting housing and commercial areas in ways that also provide places for
people to meet and children to play. Renovation and new construction plans increasingly
adhere to standards that incorporate “green” materials and technologies not only because
they lower utility costs, which is important, but also because they improve health results,
such as asthma rates, among residents.
One of the most obvious ways to support healthy lifestyles in lower-income
neighborhoods is by making healthy food accessible. In the face of increasing rates of
obesity, low-income neighborhoods are notably underserved by grocery stores. This is
beginning to change because of programs like The Pennsylvania Fresh Food Financing
Initiative, which is supported by a partnership between The Reinvestment Fund, a
nonprofit developer, and two community organizations, The Food Trust and the Greater
Philadelphia Urban Affairs Coalition. This partnership stepped in to fill a financing need
where infrastructure costs were not met by conventional financial institutions. Their
original objective was to make fresh food available in low-income neighborhoods. But
they have achieved much more. The grocery stores the partnership helped to establish
create an anchor for other retail needs in the area. Moreover, the stores hire local workers
and train them in both the required job skills and in the workplace etiquette necessary to

- 10 succeed in any job. One of the original groceries financed under the program has also
added in-store financial services and a health clinic. As this grocery operator discovered,
access to healthcare is another critical need in many low-income communities.
In Chicago, residents have taken it upon themselves to fill the need for primary
and specialty healthcare by establishing the Lawndale Christian Health Center.
Ownership in the Center is retained by residents to ensure that it continues to meet the
needs of its neighborhood. In another example of a community facility meeting more
than one need, the Center has expanded over time to provide leadership development and
organizational capacity building services to its members in addition to health services.
Conclusion
I could go on to recite more examples of programs that respond to community
needs, but I think you get my point: Taking an entrepreneurial approach to community
development results in innovative and effective programs, making communities more
desirable places to live and more resilient in hard times. The CRA regulations encourage
banks and thrifts to invest in activities that provide affordable housing or financial
services for individuals, promote economic development, or revitalize or stabilize low- or
moderate-income areas.
At a time when the needs of these communities are so great and the resources
available to meet those needs are so scarce, it behooves financial institutions to think
broadly about their CRA obligations. By partnering with other community stakeholders,
these institutions can help address existing community needs and lay the groundwork for
stronger credit demand in the future.

- 11 I don’t want to underestimate the difficulty of the task. The recession damaged
communities of all types, but particularly lower-income neighborhoods, and economic
recovery has been stubbornly slow. Nonetheless, the commitment and innovation
demonstrated in communities all across the country is encouraging. Taking an
entrepreneurial approach to community development and thinking about the needs of
both people and places will, I believe, make for stronger, more resilient communities in
the future.