It is the Bank’s policy to be in compliance with both the letter and the spirit of the fair lending and fair housing laws, including but not limited to the Community Reinvestment Act, the Equal Credit Opportunity Act, the Fair Lending Act and the Home Mortgage Disclosure Act, in all of its markets. Additionally, the Bank believes that increased efforts in making its banking services more available to low-to-moderate income (“LMI”) customers is consistent with its community banking philosophy and offers opportunities for increased market penetration in the communities it serves.
Management believes this effort should include developing additional lending programs intended to make credit, especially with respect to home ownership, more available to LMI customers, as well as efforts designed to help LMI residents create a path to financial success, including the establishment of greater financial literacy and positive credit history. Management also believes this effort should also include greater outreach to minority owned enterprises, including small businesses, in its communities, in an effort to offer financing to such businesses, as well as for creating a more diverse workplace.
Community Development Plan
As part of its continued efforts in furthering community development, the Bank is adopting this Community Development Program (“CDP”). This CDP is intended to serve as the strategic plan for the Bank’s community development efforts. This Plan is not intended to affect, alter or modify any of the policies, including the Bank’s Community Reinvestment Act Compliance Program (the “CRA Policy”), but rather to create an overall framework under which these policies are to be implemented.
Establishment of Community Development and CRA Officer Position
In preparing for this initiative, Midland has created the position of Community Development and CRA Officer (the “CDO”). The CDO reports directly to the Senior Vice President, Community Banking.
The Senior Vice President, Community Banking, with the CDO, will provide quarterly reports as to performance under this CDP and each Regional Plan. Management will report progress to the Board on a schedule determined by the Chief Executive Officer of the Bank.
Evaluation and Continuity of Community Development Efforts in Acquisitions
A key element of the Bank’s community development program is undertaking and supporting community based initiatives on a long-term basis, where appropriate. In the context of acquisitions, the Bank will continue to evaluate the community development, CRA and fair lending programs of all acquisition prospects, and would generally expect to maintain most or all of such programs following an acquisition.
Safety and Soundness/Regulatory Compliance
Each element of this CDP is intended to be effectuated in a manner consistent with safety and soundness requirements as well as in compliance with applicable regulatory requirements, as such may be amended from time to time. As regulatory requirements change, the Bank will seek input from its regulators, community groups and other relevant parties as to how best fulfill the initiatives set forth of this CDP, and will seek to modify its community development programs accordingly.
The Bank believes an important element of any community development effort is communication, both in terms of programs offered as well as goals accomplished. Towards this end, Midland will add a community development section to its website, and will post information regarding its community development plans and performance on this site.
Management also believes that the most effective way to execute the CDP is to work with community groups in each of its markets, and to provide these groups with a clear understanding of the Bank’s CDP and the progress being made under its various initiatives. As such, the CDO and the head of the respective region’s CRA/Community Development Team will meet with various community groups on a regular basis to communicate plans and progress, and to seek additional banking opportunities. While it is expected that the CDO will be the primary contact with these community groups, executive management will ensure that the CDO is not the sole point of contact available to these groups.
Actions to be Taken Under this CDP
The Bank’s management shall take reasonable measures to implement the following community development efforts:
