NCRC Announces $50 Billion Community Benefits Agreement With TD Bank

TD Bank will commit $50 billion in investments, lending, philanthropy and other services for diverse and underserved communities, the National Community Reinvestment Coalition (NCRC) announced Wednesday, pursuant to a community benefits plan the organization facilitated between the bank and NCRC members. 

“TD Bank brought dedication and open minds to the meetings with NCRC members that brought us to this strong and promising agreement,” said Jesse Van Tol, President and CEO of the National Community Reinvestment Coalition President. “The deal we just signed will ensure that communities of need see tangible increases in resources and economic opportunity in their neighborhoods — as every bank merger is legally required and morally bound to do. This agreement reflects the hard work of our members and the bank’s staff in numerous ways, including TD’s commitment to opening 25 new physical bank branches in marginalized communities — the largest such pledge to date by any of the 20-plus banks that have signed onto a community benefits agreement with NCRC members. I applaud everyone involved for bringing the candid, constructive energy these deals require to our meetings and producing such a robust final package.”

To identify areas of greatest need in communities across 22 states and Washington, D.C., the bank solicited feedback from NCRC leadership and non-profit groups from both TD and First Horizon markets from the time it announced its definitive agreement to acquire First Horizon Corporation in February 2022. TD will meet annually with NCRC to discuss and measure progress on the elements of the plan. 

“Banks have an important role in providing economic opportunity and supporting changes that help low- and moderate-income (LMI), diverse and underserved communities achieve their financial goals,” said Leo Salom, President and CEO of TD Bank. “This is rooted in the belief that our business only does well when the people we serve are flourishing. Our Community Benefits Plan builds on TD Bank’s and First Horizon’s longstanding focus on our communities. We are excited to continue this focus in First Horizon markets as we move forward with combining our two organizations. Thank you to NCRC and its member organizations for their collaboration and critical insight as we developed an effective plan that addresses the priorities and needs of the communities we serve.”

Since 2016, NCRC has facilitated 27 community benefits agreements with bank groups that committed more than $620 billion for mortgage, small business and community development lending, investments and philanthropy in LMI and under-resourced communities.

In addition to TD Bank and NCRC, the following 59 NCRC member organizations that operate in the markets affected by TD’s acquisition of First Horizon endorsed the deal:

Affordable Homeownership Foundation, Inc.

Affordable Housing Centers of Pennsylvania

African American Chamber of Commerce of Montgomery County

Best of the Bess, Inc.

BLDG Memphis

Building Alabama Reinvestment 

Business Outreach Center Network, Inc.

BOC Capital Corp.

Can I Live, Inc.


Central Baptist Community Development Corporation


Coalition for Non Profit Housing and Economic Development

Coalition of African Communities – Philadelphia

Coastal Enterprises, Inc.

Community Development Alliance Capital District, NY

Community Development Network of Maryland

Community Legal Services of Mid-Florida, Inc.

Community Legal Services of Philadelphia

Community Link NC

Community Reinvestment Alliance of South Florida

Connecticut Fair Housing Center

Corporation to Develop Communities of Tampa, Inc.

Economic Action Maryland 

Georgia Advancing Communities Together, Inc.

Greater Philadelphia Hispanic Chamber of Commerce

green|spaces Chattanooga

Housing For All

HousingWorks RI

Jane Place Neighborhood Sustainability Initiative

Kingdom Community Development Corporation

Local Enterprise Assistance Fund (LEAF)

Long Island Housing Services, Inc.

Massachusetts Affordable Housing Alliance

National Association of American Veterans, Inc.

National Association of IOLTA Programs on behalf of the Arkansas Access to Justice Foundation, Legal Services Corporation of Virginia, Tennessee Bar Foundation, and The South Carolina Bar Foundation 

National Housing Resource Center

Neighborhood Housing Services of Waterbury

New Jersey Citizen Action

New Kensington CDC

Norris Square Community Alliance

Olive Hill Community Economic Development Corporation, Inc.

People for Change Coalition 

PFC Black Chamber of Commerce Inc.

PT Partners

Real Estate Education and Community Housing, Inc.

Rebuild Communities NC

Sandhills Community Action Program

Solita’s House, Inc.

Springfield Neighborhood Housing Services, Inc.

Taller Puertorriqueño

The South Carolina Association for Community Economic Development (SCACED)

Titusville Development Corporation, a CDC

Urban Impact

Urban League of Essex County

Urban League of Greater Hartford

Washington Area Community Investment Fund (Wacif)

West Boulevard Neighborhood Coalition

Westside Network

“Ceiba looks forward to working with TD Bank to meet our mutual objectives of building wealth and expanding access to financial services for low-to-moderate income families and communities of color in Philadelphia,” said Will Gonzalez, NCRC Board Member and Executive Director of Ceiba. “This CBA helps TD Bank, an institution with a big footprint in Philadelphia, enhance its capacity to make comprehensive, sustainable, and positive community development impacts in our city.”

“New Jersey Citizen Action applauds TD Bank for recognizing the importance of partnering with stakeholders in the communities where they do business and committing to CRA goals for their investment in affordable home-ownership, community development and small business finance for underserved, low- and moderate-income and BIPOC communities,” said Leila Amirhamzeh, CRA Director of New Jersey Citizen Action. “We look forward to working with TD Bank and all of the partners in this community benefits plan to make it a success.”

“Collaboration is critical to delivering impactful financial products and services that reach diverse communities,” said Nancy Carin, Executive Director of the Business Outreach Center Network / BOC Capital Corp. “TD Bank’s commitment to partnership with community stakeholders and CDFIs to address community needs promises to have positive impacts. BOC Network and BOC Capital look forward to the bank’s active community engagement.” 

“This Community Benefits Agreement that NCRC has worked out with TD Bank represents a valuable investment in affordable housing, homeownership opportunity, small business development, and support for Black and Brown communities,” said Bruce Dorpalen, Executive Director of the National Housing Resource Center. “Housing counseling organizations across the TD Bank footprint are ready to help implement this commitment.”

“We applaud TD Bank’s Community Benefits Plan and are encouraged to see a $1 billion commitment to CDFIs and MDIs over the next 5 years,” Gerardo Espinoza, Executive Director of Local Enterprise Assistance Fund (LEAF). “The recent COVID epidemic has evidenced a plethora of social inequities that are present in our society. In order to navigate this economic uncertainty, we need all stakeholders in our communities to participate and lend support.”

“PT Partners welcomes TD Banks’ efforts to create greater equity in banking and lending but especially in philanthropy,” said Vanessa Liles, Co-Project Director at PT Partners, “where ‘Black, Latinx, Asian, Women, 2SLGBTQ, Veteran, PWD or Native American-led organizations’ are experiencing great disparity.”

“The South Carolina Association for Community Economic Development (SCACED) recognizes the contributions of TD Bank and First Horizons to communities throughout the state of South Carolina,” said Katherine Pratt, VP of Operations for the South Carolina Association for Community Economic Development (SCACED). “We look forward to working with them through and after the merger to see even greater impact in underserved communities to increase access to capital for small businesses, increase access to affordable housing and increased support for the nonprofits working on the ground in these communities.”

Advancing TD’s and First Horizon’s Strong Track Records of Community Engagement 

The community benefits plan extends TD and First Horizon’s shared commitment to positively impact social and economic outcomes in local markets and address financial inclusion across diverse communities, including Black, Indigenous, minority, women, veteran and LGBTQ2+ individuals and their businesses, and enhancing access to safe and affordable products and services.

Mortgage Lending and Consumer Products

TD Bank will enable affordable homeownership by increasing residential mortgage loans, including first-time homebuyer, and home improvement loans to $21 billion for LMI and minority borrowers, and in LMI and majority-minority census tracts, which represents a 65% increase. In support of this goal, TD will hire additional, diverse Mortgage Loan Officers and Community Mortgage Loan Officers who reflect the communities they serve. 

The bank will also provide affordable retail products and services that are designed to meet the needs of economically vulnerable consumers across the footprint.

Accessible Banking

Consistent with TD’s goal to make banking accessible to its customers, it will open at least 25 new stores and 25 ATMs in LMI and/or majority-minority markets over the next five years. The bank also commits that all banking locations will be open at least five days a week. In addition, there will not be any merger related First Horizon store closures. 

Small Business 

The plan builds on the bank’s ongoing commitment to support the critical role small businesses play in local economies by offering an estimated $7.75 billion in lending to small businesses with under $1 million in annual revenue, with a focus on minority- and women-owned businesses and those in LMI and/or rural areas.

Community Development Loans and Investment

TD Bank will provide $17.5 billion in community development loans and other investments to support economic development activities and affordable housing projects (including rental housing) within TD and First Horizon’s markets. This represents a 21% increase over the combined TD and First Horizon previous five-year average. 

Additional Highlights

  • Giving $200 million in Community Reinvestment Act-related philanthropy through the TD Office of Charitable and Community Giving, which includes creating a $40 million TD New Horizon Foundation, with a focus on giving in Memphis, Tennessee, and other First Horizon markets over five years. 
  • Creating a Community Development Financial Institutions (CDFIs) / Minority Depository Institutions (MDIs) Impact Strategy with a total estimated impact of $1 billion.
  • Increased spending with certified diverse suppliers in the US by 50%. 
  • Engagement and support of Historically Black Colleges and Universities (HBCUs) through institutional support, recruitment of students and alumni, and financial access.

Summary of the Community Benefits Plan Between the National Community Reinvestment Coalition and TD Bank

TD Bank will lend, invest or donate more than $50 billion nationally, focusing on low- to moderate-income (LMI) borrowers, LMI communities, and communities of color over a five-year period from 2023 through 2027. TD Bank plans to grow its presence in low-income communities, with the largest commitment to new branches in LMI communities in any NCRC CBA to date.

Mortgage Lending to the Underserved

Community Benefits Plan Commitment: $21 billion over 5 years

If lending to a specific group (Black, Asian, Latinx, Native American, Hawaiian/Pacific Islander), or in any assessment area reported within the bank’s combined footprint currently lagging peer banks, is not progressing in pace with target after two years, TD Bank will meet with community representatives to discuss ways to increase lending to the particular group. In order to achieve its targets, TD Bank will continue to offer a Special Purpose Credit Program (SPCP) mortgage product in Black and Hispanic census tracts in markets in both the TD Bank and First Horizon Bank footprint. In addition, TD Bank will increase its number of loan officers in LMI and majority-minority communities.

Small Business Lending

Community Benefits Plan Commitment: $7.75 billion over 5 years

TD Bank will seek to develop a small business SPCP for small businesses that are 51% or more and registered as WBE, MBE and Veteran businesses, with a goal to include availability in targeted regions throughout the TD Bank footprint, including Philadelphia, New York, Charlotte, North Carolina, and Memphis, Tennessee, and to include expanded credit policies to ensure that minority-owned businesses and women-owned businesses are given equitable access to credit.

Community Development Lending and Investment

Community Benefits Plan Commitment: $17.5 billion over 5 years

TD’s community development lending and investment commitment will include approximately $11.6 billion in commercial lending and credit enhancements to support community development activities, and approximately $5.9 billion in tax credit investment to develop, facilitate, or preserve affordable housing and make other impactful community investments. TD will create a coordinated Community Development Financial Institutions / Minority Depository Institutions Impact Strategy with a total estimated impact of approximately $1 billion over the plan term.

Philanthropy & Community Service

Community Benefits Plan Commitment: $200 million over 5 years

TD Bank will invest approximately $200 million in CRA-related philanthropy through the TD Office of Charitable and Community Giving. Part of this commitment will be a $40 million commitment for the TD New Horizon Foundation, with a focus on Memphis, Tennessee, and other legacy First Horizon markets.

TD’s Charitable Distribution policies prioritize diverse-led and diverse-serving organizations and programs, as well as those benefiting LMI communities, and TD aims to direct at least 75% of its philanthropic support provided over the next 5 years to Black, Latinx, Asian, Women, 2SLGBTQ, Veteran, PWD or Native American-led organizations.

Branch Distribution

TD Bank plans to open the greater of 25 new branches or 25% of all new branches in LMI and/or majority-minority markets over the next 5 years across the combined TD/First Horizon footprint.

Additional Areas of Focus

TD Bank will develop an outreach plan for both Philadelphia and Memphis, to include local Community Advisory Councils that will meet quarterly for the first two plan years.

In addition, TD Bank will seek to develop a US Native American strategy through collaboration with Canadian counterparts that have successfully implemented a strategy for engagement with and support of Indigenous Peoples in Canada. This strategy will include an annual consultation with representatives from the Native CDFI Network and Native American focused community groups to learn more about the unique and specific community development needs of Native American communities within the combined TD/FHN footprint and assess how TD may be a resource.

Staff & Supplier Diversity

TD Bank commits to increasing spending with certified diverse suppliers in the US by 50% over the plan term. After the acquisition is closed, TD will work with First Horizon to establish the baseline of the combined certified diverse spend and supplier count and will seek out new certified diverse suppliers across the newly expanded footprint and will seek to add 75 new certified diverse suppliers in the US over the term of the plan.

Statewide Increases

The intended outcome of this plan is to increase lending across the TD Bank – First Horizon combined footprint. If mortgage lending to a specific group (Black, Asian, Latinx, Native American, Hawaiian/Pacific Islander), or in any market reported within the bank’s combined footprint currently lagging its peer banks is not progressing in pace with target after two years, the TD Bank will meet with community representatives to discuss ways to bridge that gap.

Plan Implementation & Accountability

TD Bank will create a Community Advisory Board (CAB) comprised of members representing a diverse cross-section of community groups in the combined TD Bank-First Horizon Bank footprint. The CAB will meet on a semi-annual basis, and at least one meeting annually will be attended by the TD Bank, NA CEO. Annual assessment of progress on CBP targets will be reported to NCRC. For the five-year term of the CBP, TD will report annually to the NCRC on progress against the elements of the plan, unless specified otherwise.

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