CRA Credit Strategy Memo
Draft a legal memo for a fintech serving globally mobile African students analyzing the viability of using CRA credits to support college towns through student lending programs.
Referred by:
8B Education Investments, a social impact fintech focused on serving globally mobile African students, is seeking assistance exploring how Community Reinvestment Act (CRA) credits can be utilized by financial institutions to support local college towns facing economic decline due to decreased student enrollment. The focus would be on enabling local lending to foreign students, with the proceeds going directly to colleges and universities with an aim to clarify that CRA credit should be based on the use of funds—supporting local institutions and economies—rather than the nationality of the borrower. They would greatly appreciate a memo that provides legal analysis, policy background, and strategic guidance that can be shared with CRA officers at banks to encourage adoption of this approach.