Lamont Bank of St. John, a “women’s depository institution” under the CRA
The Community Reinvestment Act, as amended, (the “CRA”) defines a “women’s depository institution” (“WDI”) at 12 U.S.C. § 2907(b)(2) as:
‘(2) Women’s depository institution
The term “women’s depository institution” means a depository institution (as defined in section 1813(c) of this title)
(A) more than 50 percent of the ownership or control of which is held by 1 or more women.
(B) more than 50 percent of the net profit or loss of which accrues to 1 or more women; and
(C) a significant percentage of senior management positions of which are held by women.”
Lamont Bank of St. John, St. John, WA (the “Bank”) is clearly an insured depository institution with an FDIC Certificate #8681. Women own or control 320 shares out of a total 500 shares of Bank voting common stock equal to sixty-four (64%) of the 500 total shares of voting common stock outstanding. That same percentage applies to allocation of any net profits or loss accruing to sixty-four (64%) to women owned or controlled shares of common stock. Finally, 100% of the Bank’s employees are female, and they are:
Tiffani Organ – CEO
Roxanne Scharffer – COO
Cindy Glorfield – BSA officer
Jackie Roberts – Senior Ag Lender
Stephanie Engles – Loan officer
Christy Eriksen – Teller
Therefore, the Bank is a “women’s depository institution” under the CRA. In the CRA Interagency Questions and Answers Regarding Community Reinvestment Guidance, which were published in the Federal Register at, 81 Fed. Reg. 48506, 48532 and 48535-48536 (July 25, 2016) the federal banking agencies explained that “examples of qualified investments include, but are not limited to, investments, grants, deposits or shares in or to . . . minority and women-owned financial institutions” [See, §____.12(t)—-4] and the “CRA provides that, in assessing the CRA performance of non-minority and non-women-owned (majority owned) financial institutions, examiners may consider as a factor capital investment, loan participations, and other ventures undertaken by the institutions in cooperation with minority- or women-owned financial institutions . . . provided that these activities help meet the credit needs of local communities in which the [women-owned financial institution] are chartered.” [See, §____.21(f)—-1] (Emphasis added). Another way that a majority owned financial institution can help the Bank as an WDI is “loaning an officer or providing other technical expertise to assist a [WDI] in improving its lending policies and practices”. [See, §____.21(f)—-1] (Emphasis added)