Community Reinvestment Act (cra)



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Community Reinvestment Act (CRA)

Public File

as of April 1, 2017

Table of Contents


Public Comments 3

Public Performance Evaluation 5

Branch Locations 5

Branch Openings and/or Closings 5

Products and Services 6

Assessment Areas 11

Consumer Loans 13

CRA Disclosure Statement 13

Home Mortgage Disclosure Act (HMDA) Disclosure Statement 13

Loan to Deposit Ratio 13

Main Office Notice 14

Branch Notice 15



Atlantic Coast Bank (“Bank”, “ACB”) is a $908M1 Florida state-chartered commercial bank headquartered in Jacksonville, FL and is classified as an Intermediate Small Bank under the Community Reinvestment Act (CRA). Atlantic Coast Bank is affiliated with Atlantic Coast Financial Corporation, a holding company publicly traded on the NASDAQ (“ACFC”). The Bank’s primary business focus is residential and commercial real estate lending.


In addition to its responsibility to comply with CRA, Atlantic Coast Bank places a high value on contributing to the financial stability of the communities within its footprint. This is supported by an assessment of community needs and opportunities; with focused attention on low- to moderate-income (LMI) individuals and geographies, housing assistance, small businesses, and community development organizations. The Bank responds to these needs via delivery systems, product offerings, lending practices, investments, and services (e.g., financial education, technical assistance).
Lending

The Bank considers its products, underwriting, and/or investor alternatives that may assist with credit issues in our markets.


Investments

The Bank makes investments in CRA qualified Mortgage Backed Securities with collateral in Clay, Duval, Nassau, and St. Johns Counties. The borrowers have a low- to moderate-income level and/or reside in a low- to moderate-income geography. In addition, Atlantic Coast Bank makes donations to assist non-profit organizations in meeting community needs (e.g., temporary/permanent housing, financial literacy, well-being needs, and skill-building).


Services

Atlantic Coast Bank’s contributions to financial education needs in its communities include, but is not limited to, participation in the following:



  • American Bankers Association’s annual Teach Children to Save Day (held each April)

  • American Bankers Association’s annual Get Smart About Credit Day (held each October).

  • YMCA “Money Monday” events to educate seniors about Financial Elder Abuse.

  • United Way of Northeast Florida Real$ense Outreach/Financial Education Volunteer Program

  • Jacksonville Habitat for Humanity Mentoring Program

  • Junior Achievement’s Youth Financial Education Program

  • ACB created “Got Credit?” program offered on a periodic basis to the surrounding community at the Normandy branch location.

  • ACB created “Home Buyer’s Round Table” offered to the surrounding community at the Normandy branch location.

Since the Bank’s most recent CRA Performance Evaluation, we have averaged over 100 hours per year in providing technical assistance to non-profit organizations (e.g., board members, committee members, treasurer, etc.).


A CRA Committee meets periodically to oversee the Bank’s CRA Performance. This committee consists of the CRA Officer, a Board Representative, and individuals assigned by Senior Management.


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