Video: Redlining the Reservation

Online Event Archive Recorded: February 20, 2024

Citizens on tribal lands live starkly different lives from Americans living in other areas, with limited quality-of-life necessities like electricity, fresh water, sanitation and heating and cooling systems for housing. Learn how tribal areas have been cut out of the financial system, and what can be done about it in our webinar “Redlining the Reservation”. Hear how changes in CRA enable CDFIs to better engage in community development, mortgage lending and small business investment on Native Lands. Attendees will hear about the latest NCRC report, and about Native CDFIs regarding the challenges and opportunities for improving conditions in tribal areas .

Webinar Slides


  • Dave Castillo, CEO, Native Community Capital CDFI
  • Bruce Mitchell, Principal Researcher, NCRC
  • Jason Richardson, Sr. Director of Research, NCRC
  • Greg Wilson, Senior Organizer, NCRC
  • Caitie Rountree, Director of Membership and Events, NCRC


NCRC video transcripts are produced by a third-party transcription service and may contain errors. They are lightly edited for style and clarity.

Rountree 00:00

Alright folks, we’re gonna go ahead and get started. Thank you so much for joining us today. I’m Caitie Rountree, Director of membership and events at NCRC. I’m going to start by doing a little bit of housekeeping just kind of the rules of the road here. And then we’ll tee up this fabulous presentation. As always, this event is covered by NCRC’s Code of Conduct. If you’re not sure what that entails, you can go to ncrc.org/conduct. And we thank you all for creating a welcoming and warm, respectful environment on this call. I see many folks are going ahead and introducing themselves. Please continue to do that. We love to hear where folks are coming from and what your interest is in the topic. As you have questions, please put those in the q&a box. Some of those might get answered during the presentation. And we’ll also have ample time for facilitated q&a at the end. Please do tag NCRC in social media about this event. And just a reminder that this event will be recorded. And we’ll send this around to all registrants afterwards. And just a little bit about NCRC. NCRC is a network of over 700 organizations dedicated to making a just economy a national priority and a local reality. We work with our members to close the racial and socio-economic wealth and opportunity divides. We do that by organizing agreements between financial institutions and our members to increase lending investments and philanthropy and neighborhoods that need it. We advocate for policies that encourage the just use of capital. We hold institutions accountable for discrimination in financial services and housing. We empower entrepreneurs and community organizations with grants loans, technical assistance and training. We invest in and around low and moderate-income neighborhoods to increase homeownership in partnership with community organizations and municipalities as well as lenders, investors and developers. We produce agenda-setting research like this one, and stories and we convene events that bring together stakeholders to advance equitable solutions, including webinars like this, and including the just economy conference taking place in April. So if you haven’t registered for that event already, we would love to see you in person in DC in just a few short weeks. I do want to say a big thank you to our speakers. My colleague, Greg Wilson, senior organizer and CRC is going to tell you a little bit more about each of those folks and about this really exciting report on “Redlining the Reservation.” So, Greg, I’ll turn it over to you.

Wilson 02:54

Thank you, Caitie. Good morning, everyone. Or good afternoon, I should say. My name is Greg Wilson. I’m Senior organizer for NCRC. And I want to welcome you again to NCRC’s “Redlining the Reservation” webinar. As you may know, multiple staffers made this groundbreaking report and webinar possible from our membership and communications teams, to our organizing departments. And most of all, our research department. What you may not know is that the redlining the reservation report came about because of an idea offered up by an NCRC member, Native Community Capital’s David Castillo. Dave’s idea was simple. Banks keep telling us they don’t have enough data to justify investing in Indian country. So we asked what does the available data tell us about investment opportunities in Indian country? Our redlining report addresses that question, and produce new literature that chronicles how the financial financial services industries are failing communities on and near tribal lands. Over the years, Dave has participated in Community Benefit Agreements, Zoom meetings, coordinated by NCRC’s organizing team. In brief, those Zoom meetings where NCRC has organizations in a bank’s footprint provide first-person testimonials to bank officials and ways their bank can improve its CRA performance. Dave has also been a panelist on a breakout session at NCRC’s annual conference last March, and he was a key resource for NCR C’s Just Economy regional summit in Denver last September when Dave met over Zoom with NCRC his research department a little over a year ago, it didn’t only took a few minutes for Jason Richardson and Bruce Mitchell to see a paper of this kind was an idea whose time had come. Redlining the reservation is a collaboration of NCC (Native Community Capital) and NCRC. It’s been a part though of groundbreaking work, applying research and data and Aspen opportunities in Indian country that’s happening on other areas as well. Casey Lazaros team at the Minneapolis Federal Reserve’s center for Indian Country development is the clearest example. Lazar and CICD staff have developed new research tools and convene data summits to define and tap and tackle harmful data gaps. Regarding Indian Country. NCRC is proud to be a part of this new era of applying research and data to spark new investments in and around tribal lands, and will continue to do so in 2024 and beyond the NCRC research team of Jason Richardson, Bruce Mitchell, Jad Edlebi, and Joseph Dean produced this report, the team is a resource for all of you NCRC members, feel free to contact us with any data or research related questions. This is a benefit of NCRC membership. And we will share the slide deck at the end of the presentation. And before the q&a. Take it away Jason.

Mitchell 06:02

Greg, thank you so much for that introduction. My name is Bruce Mitchell, and I’m principal researcher with the NCRC research. And, you know, the title of this report redlining the reservation, what are we talking about here? I mean, after all, federal examiner’s weren’t dispatched to tribal areas, to draw maps during the 1930s to indicate where mortgage lending risk was hazardous in the parlance of the time, no. Instead, these maps were really drawn at a much earlier era during the 19th century. And they consolidated this long process, which began with the Spanish and dept. Labor debt peonage. continued under the Americans with exploitation and dispossession of lands. So these tribal areas which were established and formalized during the 19th century, offered in the most isolated remote areas of the United States. These are areas that were largely ignored by the financial services industry today. And this has set the groundwork for these making these areas vulnerable to predatory lending practices, including, as we’ll talk about a little bit later on excessive interest rates and excessive closing costs on the type of housing that Native Americans are relying upon. Next slide, please. And this map, it shows some of the areas we’ll be talking about today of Arizona and New Mexico. These areas are the tribal areas, the reservations of the two states. In the center, you see this very large area, the Navajo Nation, and in that area in orange, the Hopi reservation. This is an area that’s as large as the state of West Virginia. So these are considerable portions of these two states that are tribal lands on the topic of homeownership. Well, there’s a tremendous homeownership gap between Native Americans and non-Hispanic Whites in America. That’s a 10% gap. And Arizona is 16% gap and homeownership. Next year. Additionally, Native American house on a national level suffers from inadequate plumbing and access to fresh water 6% of Native American homes have inadequate heating 12% of Native American homes as inadequate heating within their structures. And next, and situations of overcrowding were 16% of Native American households suffer from overcrowding. So these types of problems are much more severe for Native American Housing. Next slide guys. Now, this extends over into the area also of socio-economic disadvantage, incomes and social status. Here we have a map showing concentrated disadvantage and those areas that are in dark brown. Those are the areas of the greatest concentrated disadvantage, which is almost all of the tribal areas within the two states. These are areas of very high poverty, unemployment, and reliance on public assistance. Excellent. And this has very real effects in terms of life expectancy. Native Americans, as a group have the lowest life expectancy of any racial group, the United States, it was 71.8 years and 2019 during the pandemic, the slip to 67.9 years. This is seven years lower than for non-Hispanic white Americans. So these impacts have very real costs in terms of life insurance. I can see, well Native American people. Next slide. Now in writing this report and doing this analysis, we can find had some problems with the data, one of which is the census data. It’s had problems with doing adequate counts of Native Americans, particularly in tribal areas, because of the remoteness. And also so because of the low number of Native Americans in many areas. However, we found another problem where between 2010 and 2020, the number of people identifying as Native American almost doubled in the United States going from 5.2 million to 9.7 million. So this type of change in self identification really impacts the overall socio economic status. These are statistics we have. Another problem we had was the poor data coverage and tribal areas, they often lacked full data on housing in these areas. And then there was a mismatch with our mortgage lending data and small business data and census tracts. So what we had to do was we had to develop a way of looking at the tribal areas, and then assessing those areas, which were 100% tribal areas, so that we can then use that data. So throughout the report, these are referred to as tribal lands. Next slide.

One mode of analysis, which relies on this was tackling and financial needs index. And this index, it looks at density of population, access to transportation, cellphones Internet, and also the distance to bank branches. And you can see in the two states of Arizona and New Mexico, that access is problematic in all rural areas, but it’s even worse, and the tribal areas. Next slide. And this map shows this financial needs index with bank branch locations on top of it. And this analysis that showed that, for instance, the Navajo Nation, that area that’s the size of West Virginia, 250,000 people live there, and they have five total bank branches serving that population that’s serving that area. So there’s grave need for greater financial access and services within the tribal areas.

So after the financial needs index, we also looked at small business lending in tribal areas between the period of 2018 and 2021. Now this is a comparison between low to moderate income areas within the two states. And what we found is that less than one center of every dollar loans, in other low to moderate income areas went to tribal areas. And that over the four years, there was an average of only five lungs, and tribal lands compared to 82 and other low to moderate income areas within the two states. Excellent. Now, one thing that occurred during the pandemic was the paycheck protection program. And this took up a lot of the small business lending across the country. During that time period, we did an analysis of the paycheck Protection Program lending, what we found is that this provide a lifeline to Native American communities that many workers in casinos, restaurants, hotels, but also in essential services like tribal government administration, and also the never Electric Company. They were highly reliant on the paycheck protection program to support jobs and continue jobs during that time period. We also found there were very low if any rates of fraud in the PPP program and Arizona and New Mexico in the tribal lands. Excellent. Now when we come to mortgage lending, the preeminent program to support mortgage lending is the HUD section 184 Guaranteed mortgage. And this is federal backing for mortgages to Native American borrowers. This program as you can see from the slide here, it started back in the mid 1990s. And it got off to a very slow start, there wasn’t much lending up until about 2004. Now that lower line there, that’s the amount of lending that’s taking place on tribal lands or tribal trust areas. There have been problems with that money. And as you can see, only 204 loans were made in 2018 and it’s across the country, in tribal tourist areas. So this is a grossly inadequate meeting of the needs. have Native American borrowers for the housing structure within tribal areas. Part of the problems with this are well, the tribal trust areas, it’s the nature of ownership of the land. These are areas that are set up side by the federal government as trust areas. So they’re jointly administered by the tribal governments and by the Bureau of Indian Affairs. And this adds to some of the administrative complexity and making these loans. Additionally, the lending there because the land can’t be owned outright. It involves long term leases, often 100 year leases being made on this land, which can be quite complex. Now to talk a little bit more about this issue of mortgage lending and also about lending for manufactured homes. Jason Richardson, our director of research will talk about that. .

Richardson 15:52

Thanks, Bruce So, first of all, let’s look across the top 10 metros in the study area, and we wanted to take a look and kind of get an idea of how important the native population was across the entire study area. And we looked at loans using the Home Mortgage Disclosure Act, and we identified loan applications where a Native American applicant or CO applicant was present, out of about 2.6 million loans across the entire area between 2018 and 2021. We counted about 48,000 with a native applicant or CO applicant, numerically they’re concentrated in Phoenix. However, they are a very small part of the overall Phoenix market. Farmington and Gallup in New Mexico were the two metros where they made up a much larger share of the of the mortgage market. Another thing we quickly found was a very different type of lending going on on tribal lands as opposed to off tribal lands off tribal lands. Manufactured Housing is a relatively small part of the market making up just 4% of home purchase loans during the study period in the two states. However, on tribal land, that was about half of all home purchase loans were for a manufactured home. The cost of these loans varies to based on what kind of housing it is. So they have the borrower’s native and if they’re on tribal land, loans are priced in something called basis points. And you can see that non-natives Buying a manufactured home off tribal land pay about 149 basis points more than the national average mortgage rate for that day that the loan closes. However, native borrowers on tribal land buying manufactured home paid 549 basis points on average. What does that mean? So recently, the average mortgage rate across the country was 6.77%. What these numbers all mean is that all tribal land and nonnative buyer of a manufactured home would get about 8.2 per six as their interest rate. Meanwhile, a native buyer on tribal land buying a manufactured home is paying 12.26% over 20 years, we’re talking about $64,000. In additional interest, the native buyer will pay for taking $100,000 loan and comparison to a nonnative buyer off tribal land. Now, one key difference in lending on versus off tribal land is that borrowers Bruce mentioned this borrower is on tribal land rarely can borrow against the land itself, they can only borrow against the manufactured home. Generally, these loans are going to depreciate over time. So it puts the native borrower on tribal land in a quandary where they’re paying more for a depreciating asset. And they’re not able to encumber the land with a loan, nor do they have fee simple ownership of that property. That’s just an example really, of how this mortgage system we have in the country is poorly suited to serving this population on tribal land. So there’s only a few lenders really doing manufactured home lending on tribal land. Two of them Vanderbilt mortgage and 21st mortgage account for about 85% of all the home purchase loans on manufactured homes made during the study period. Both of these are subsidiaries of Berkshire Hathaway. So in summation, we found Native Americans are being walled out of the traditional mortgage market. Half of home purchase loans on tribal lands are for manufactured homes. Tribal Lands receive very little small business investment, and they have a much higher degree of financial need than the rest of the country or the rest of the rural areas.

Okay with that, I’m going to ask Dave Castillo to take over and give us a lot more detail. Dave, go ahead.

Castillo 20:09

Thanks, Jason. So these are the five policy recommendations in the report. And I’m gonna go through each one with some additional commentary. Next slide. Okay, so firstly, I’d like to do some level setting because I think many of the issues that affect access to capital in Indian Country are due to a difference in viewpoint, not necessarily bad, but different. And we together must decide how to address in reconcile these differences. Some of those differences are noted on the left, the graphic illustrates the question, how does homeownership for Indian Country sit in between and betwixt, these two worlds in which we coexist? You know, with regard to the value of homeownership in Indian country, it is unique from what many on this webinar might consider. on tribal lands, homes are not typically thought of simply as a bunch of sticks and bricks, formed into an asset with an appreciating monetary value. Rather, a home is not so much a structure but a place, a place where we teach our children, old ceremonies and celebrations and nurture our families. You know, few, if any, in Indian Country, build a home to flip it, and move to let’s say, Florida, home is a specific place that in many cases are considered places of origin, places given to a specific people by the Creator. This is where life began, and where it has continued for generations of our respective families and communities. And where, for a lack of access to capital, we are unable to maintain shelter from the elements. So I realized this is a bigger topic than we have time to discuss today. So let it serve simply as a backdrop for the comments. The first recommendation on your screen, sorry, next, next slide. There’s this recommendation. It’s not shameless self-promotion. It’s, it’s a reflection of the dedication of native CDFIs and our allies to do the hard work needed to build tribal economies. You know, ideally, when a Herculean effort is needed, a grand plan is devised. But there doesn’t seem to be the political will to offer tribes something like the Marshall Plan after World War Two, instead, after the Indian Wars, tribes have had to get by with paternalism, and poverty programs. Next slide. Nevertheless, what George Floyd and the pandemic revealed is at least an acknowledgment that the colonial era left a legacy that demands a response. And the work that tribes and native CDFIs do in this space is part of our response. And for those unfamiliar with tribal lands in the southwest, I think this is just another map. And it shows a significant land area that tribes make up in Arizona alone, it’s 27% of the land base, next slide.

And so that work that I was talking about, it’s that much more impressive because the various financial tools available, available to build non-Indian communities have long been withheld for use in Indian country. These are some of the homes we’ve helped build, nonetheless. Next slide. But native CDFIs across the country are adapting existing tools. You can see the LTV on this project is spectacular by even the most conservative credit standards. Next slide. The work also involves partnering with allies to forge new financial tools to rebuild tribal economies. These are some of the small businesses we’ve helped support or get established. Next slide. All of that work has been resulting in the building of an ecosystem of support for in our case, aspiring homeowners on tribal lands and native entrepreneurs. It’s complex work, but one that is ours to do. I remember reminding a distraught colleague once that we’re engaged in the process of nation rebuilding that the US colonialists with have rather have had us vanish which is a euphemism for extermination. What most of this I think what most on this webinar may feel is a relic of history. Those of us doing this work know that since the Indian Wars, a low-profile economic warfare against tribes has continued. And so nation-building under these conditions isn’t supposed to be easy, but we’re the ones to do that work together, I would say and so we ask for you to join is in that necessary community and economic renewal. Next slide. The second round of recommendation references the 2001 and 2017 studies commissioned by the Department of Treasury, and those studies and the recommendations there and should be a signal that the paternalism ends here. Next slide. That the history is extremely well understood. Next slide. As well as potential prescriptions to remedy the economic legacy of us Indian policy that historically was used as a weapon to attempt to dispossessed tribes of well, everything. Next slide. Yet, progress and engagement is possible. self-governance was taken from tribes during the Indian Wars, but sovereignty is a powerful concept at the heart of the Western ethos. And so Indian self-determination found renewed support over the last 50 years. And that is a stark rebuke to the paternalism that followed colonialism. And I think a tool that we can use going forward. Next slide, please. The policy recommendations the data analysis, the current-day data warriors and their allies at work on these issues, and those who implement the prescriptions are a vital part of the of the march towards economic justice and reconciliation. And to make it beautiful once again, which is a rough translation of what my Natl who inlaws say at the end of their prayers, because in many ways, this vision of economic justice is for us in the native CDFI. Industry, our prayer. Next slide. The last three recommendations really get to the heart of, you know, the policy discussion at hand. And I was asked two questions regarding the report that I think are really important to bring forward. The first question was, why was this report necessary? And the second was, isn’t the idea of having small undercapitalized nonprofit, native led CDFIs lead this effort asking too much? So with regard to the first question, the answer is that it is in no one’s interest to have a significant portion of land and people within the US without economic potential. We all lose. And so this study was exceedingly necessary to set a baseline. With regard to the second question, the answer is a resounding yes, it is a massive effort. And we do need partners who will look to us to lead for our combined efforts to grow both on the nonprofit, the tribal and the private sector side as well as the public sector. Because where we are today, is that neither banks nor the GSEs and even nonprofit, national and regional intermediary lending organizations, none of them are serving tribes in a way that is compliant with the historic version of the CRA. Next slide. And neither are they conforming to the statutorily mandated requirements such as the duty to serve provisions within the Hira legislation, I often comment that with regard to tribes, the GSEs are engaged in a dereliction of their duty to serve. And so the fact is that we have arrived at this point, no pun intended for native CDFIs alone to, for example, develop a thriving mortgage market on tribal lands. However, if banks continue to redline tribal lands, opt instead to offer drops in the bucket with their grantmaking. While native CDFIs attempt to boil the ocean with their limited resources, it’s going to take a long time. And meanwhile, our relatives will continue to suffer the indignity of not being able to access capital or safe, decent and affordable homes within extremely distressed local economies. Next slide. And there is much work yet to do. The timeline show on this slide shows that since 1996, when I started my career, and when the idea of stimulating mortgage lending on tribal lands was new. Since that time, there have been at least four major pieces of federal legislation necessary to better facilitate mortgage lending and community development on tribal trust lands. That’s not to mention several congressionally mandated studies and regulatory reform. Next slide. And so it is disheartening. You know, here we’re talking about the 1071 rule around reporting on small business loans and of course, we could bring into this discussion around, you know, where the reform is out of CRA but it’s disheartening because despite the significance of our community’s collective effort to address regulatory reform, banks fought us at every step of the way. Through their lobbying efforts, banks are actively attempting to delay weaken or dismantle the policy foundation needed to improve access to capital on tribal lands and other underserved communities. Next slide. This report and others like it establish a baseline. The question is, will the CRA reform the 2024 federal election cycle? are individual efforts at the community level to communicate the demand for access to capital and tribal communities? Will any of that affect the concentrated disadvantage in tribal communities? Next slide. So maybe, with regard to CRA reform, maybe we need to collectively hold our breaths until this election year is over. If we get another Biden administration, those banks who are lining up on the wrong side of this issue by calling for weakening reform, well, we’ll be coming for you. I’m just joking. Sorry. I had to get that one in. Seriously though, we’re coming to you, in a sense of partnership. Next slide. So please read the report and engage us in the solutions we so desperately need. We and our native CDFI colleagues around the country need investment capital that banks can readily supply. I will remind you that the history of underinvestment or outright fraud and abuse demands concessionary rates justified by what are regulatory goals, rich benefits to banks, Indian country and native CDFIs are a good investment, we’re simply asking you to be a part of a success story that we could write together. Next slide. If you are still unsure about where your institution may be on the question of investing in Indian Country, consider the rest of this graphic it posits to individuals from different backgrounds. Are they displaying a stoic, committed resolve to the work ahead? Or are they fearful and suspicious of each other and the outcomes? Consider a Rorschach test and decide for yourself which version you will be. As for myself, I’m the former and then I invite others of like mind to a specific discussion about the investment opportunities available. With that, I think I’ll turn it back over to Jason. Thanks, everyone.

Richardson 32:18

Dave, that was fantastic. Thank you very much. With this, I think Caitie is going to take over and lead us through our q&a. There’s already a few questions there, Caitie?

Rountree 32:26

Yep. And the first one, I’ll just say at the top. And we’ll write this in there as well and we will share the recording and the slides for this. So if you feel like that was a lot of information to take in all at once, don’t worry, we’ve got you covered. And I’m going to ask a colleague to go ahead and, and reshare the the link to the actual report for reference. So there were a couple of questions that we answered during the presentations that we felt like were worth circling back to. And actually, if we could go all the way back, I don’t remember what slide number it was. But all the way back to the HUD section 184 slide. There was a question about what a blue line meant. And that was actually more involved than I originally thought it was. And so I’d love, for Bruce to be able to elaborate on that a little bit.

Richardson 33:20

Hold on one second. I’ll reshare.

Mitchell 33:24

Oops. Yeah, sure. Sure, Caitie, and I’ll just start in here, pull that slide up. That was that line graph showing the section 184 home lending and trouble areas and Native American lands, they have different forms of ownership of the land. In this case, that top line shows these areas that are fee simple ownership. And these are areas in which a Native American can actually hold title to the land. And you can see that wandering, there’s much greater where they can hold title to the land these areas. Correct me if I’m wrong on this, Dave, these areas really are largely outside of the study area. We’re looking at Arizona and Mexico. I think it typifies land ownership, maybe in areas like Oklahoma.

Castillo 34:12

No. So that’s part of it. Right. So what we know about the section 184 program is that banks gravitated to where it was easiest to do deals. And the law allows for loans to Native Americans anywhere so banks went to, you know, there’s plenty of folks in Phoenix, Denver, Salt Lake City, Los Angeles, who are Native American who were able to benefit from the 184 program, and also Southeast Alaska and Oklahoma where the lands are not have a different status other than trust land. So that’s what that number represents is basically where the money is needed least or I should say that banks are not serving the areas that are where the mortgages are needed most, which is on tribal trust lands on Indian reservations, and the rest of the lower 48, excluding, you know, southeast Alaska and Oklahoma. Sorry.

Mitchell 35:10

Yep. Thanks, Dave.

Rountree 35:12

And just to say one more time, the appendix of the report actually has, you want to read some more about that the appendix of the report is a good place to look. And then we also had a question about how we define concentrated disadvantage, and is whether it’s similar to the persistent poverty definition used in other contexts. So Bruce, if you could go ahead. Sure.

Mitchell 35:42

Yeah, good question. Because we use the term and refer to concentrated advantage disadvantage quite a few times in the report. And basically, this is a metric and it looks at levels of poverty, levels of unemployment, number numbers of families presented families on public assistance, also have single parent families and children who are living in these areas. And it’s a combination of those factors that come together index, it’s widely used in public health research. And that’s why we use it for this report that differs a little bit from the other index you were talking about there. So yeah. And the definition, again, of that is in the report, you can see how that was calculated, and what our results are.

Rountree 36:26

Awesome. All right. So I’m going to turn it over just a minute to Jason to answer a couple more questions, but I just wanted to call out. Lydia Gozman had a great comment. But I just feel like gets to some of the heart of what we’re talking about here. Just noting that, that this makes it incredibly hard for Native communities to build and pass on generational wealth. And I just felt like that comment was worth lifting up, you know, as we’re going through the data on this, that we’re talking about whole families being impacted generation to generation. So thank you, Lydia for calling that out. And, Jason, I’m going to turn it over to you to talk about manufactured home loans, how that information is counted for.

Richardson 37:15

Yeah, so that was a good question. And this is a really kind of a technical dive into home mortgage disclosure act data, manufactured home loans are collected. They also collect data now on whether or not the loan includes the land underneath the property and how the property is titled. So yeah, it does have more information in the raw data, and anonymous attendee, if you have any more questions on that, please let me know. I’m happy to take a deeper look or help you with the data if you want to take a look at it yourself. Joanne Baker, who asked the name of the companies that do manufactured home loans. In the report, we do have a list of the top lenders, there’s only two there that you really need care about. And that’s the 21st mortgage and actually forgot the other ones name off that Vanderbilt mortgage. They were 85% of all home loans on tribal land in a three-year or four-year period we looked at both of those are owned by Berkshire Hathaway. Caroline Dunn levy asked how can we those of us who advocate on redlining and the older Northeastern cities work for you can’t work with you. Contact Greg Wilson, senior organizer at NCRC. And he can talk to you more about how we work with members how we build coalitions and how we’re working with Dave and other partners and tribal tribal areas. Bernina Gray, we would insist you cite the report. You know, if you have questions about how to cite it looks like Bruce is typing an answer. You can always reach out to Bruce Mitchell and we can we can help you figure that up. There we go. Perfect. Go ahead. Yeah,

Rountree 39:07

I was gonna suggest there’s a great question about whether there are online banks serving Native communities or majority native areas. I don’t know if any of y’all have a good answer on that one.

Castillo 39:21

So there are 19 tribal Loan Banks, but many of them operate like a tribal enterprise would. But there are I mean, native CDFIs are typically not depository institutions, we typically do work online, there is something called totem which is a new type of banking institution. So I think the thing to say here is, as I kind of tried to relay in my presentation is we’re building the ecosystem that’s needed to serve tribes and tribal members living on tribal trust lands. Because, you know, we’ve just have what is I think, rightly an abject market failure that banks have decided not to serve tribal members. Instead, we have lenders of last resort, which are predatory lenders, we have just a saturation of predatory lenders, serving the Capitol needs of tribal members. And that’s not the kind of money we need. We need. We need banks to step forward and show some leadership and invest in this space. We need native CDFIs to grow and do more. We need, again, a whole ecosystem of support around this issue, and we’re building it now. Someone from NCRC reminded me the words of a modern-day philosopher who say, you know, the hungry, don’t stay hungry long, right, we will find a way. And that’s what we’re doing. And we need your help. We need the banks helps. We need the regulator’s help, we need community members speaking out. There was a question at hand here about how do you access support from your local chapter or your tribal district? So we need you to speak with your tribal leadership and make sure they’re informed on these topics. And, and everyone here on this webinar is happy to be a part of that through this study, and through local advocacy efforts. Thanks.

Richardson 41:14

A lot of folks are asking for Dave Castillo’s email in the chat. Can we can we post that? Yep. Sure.

Rountree 41:26

Yep. And then Bruce. Bill, you wanted to answer this question about a proposed rule around the HUD 184. Program? Yeah, I’ll let you frame that up. I’ll read the question out loud. “The HUD 184 program is going to going into our proposed rulemaking is NCRC. Participating in that currently, the online HMDA data does not provide HUD 184 data. So where and how did NCRC get it?”

Mitchell 41:56

Yeah, section 184 data, we could not get that data, we actually filed a FOIA request. And if someone from HUD is on the line, we would love to get that data so that we can have access and you know, write a intelligent comment for the section 184 ruling on that. But we had to rely upon prior HUD reports to get that data and only covered up to what was it 2018. So we’d love to get more recent data on that. Thank you.

Rountree 42:29

I also saw a question about what folks can do. You know, you there seems like as a voting with your dollars can be hard because alternative financial institutions, Co-Op CDFIs struggle to get to scale. I have some CRA answers in my mind. But Dave, as a CDFI. Guide, you want to take this one?

Castillo 42:59

So the question was, what can individuals do? Like moving their money? And what should

Rountree 43:04

What do we do to change this? What can we do to shift Shift? Shift these realities? Yeah,

Castillo 43:08

Yeah, well, there’s there’s a few different levels, right? I mean, if you’re talking at the bank level, move the money folks. Right, like make the investment. That’s really kind of the message here, if we’re talking about regulators and congressional folks, as I’ve said before, and others have said before, laws are only as strong as their enforcement. So if enforcement actions are needed, you know, that’s a question, why would a bank like, you know, suffer a fine or a class action lawsuit by, you know, avoiding complying with the law, just comply with the law, right? There’s, you have the resources, you have the people out there, there is a demand, and we’re here to kind of work together. If we’re talking about kind of the average Joe, or maybe some within an institution, I can’t tell you how many times doors have been opened for me, right, there was someone at a at a big bank, who I think had been there for a long time. And, and they saw what was going on at the bank, and they had done okay, for themselves. But it was clear that that individuals family and that individuals community had not done well. And so it kind of winked at me and said, Hey, I’m opening the door for you, you know, walk through and do what you do, because I’ve done what I can on this side of the bank. So it takes all of us. I think, for the average Joe, I think, you know, if you’re at the community level, talk to your community leadership. There’s a lot of information in this report is just part of it. If you’re in another part of the country, I saw something about the Northeast or northwest or the Great Plains or the Great Lakes region, you know, commissioned a study and do this same type of work for your area. What are your numbers show? Because, you know, information is power. I used to someone someone said, you know, in business, cash is king, but in our work data is queen, right? It’s more powerful. It can move farther across the board, and it can be very impactful. So get the data use the data out and make your case for what’s needed in your community.

Rountree 45:06

In a similar vein, there’s a specifically CRA-related question here. Are banks not required to abide by CRA requirements in these areas? Are there special rules in need of lands? And there’s going to be a before and after and TBD version of this answer. So I’ll let you give that.

Castillo 45:24

So it’s a big question. I’ve been doing this work my entire career, you know, you know, and I know, Jason, I have had different opinion on this thing, you know, cuz, you know, from a business side, I mean, you know, I’m sure a bank would just say, Look, we’re not a charity organization, right. If there’s business to be had there will be there. Right. But we’re not going to, we’re not going to bend over backwards to try to do something that doesn’t generate shareholder value. And you know, that that’s a that’s a way of thinking that it’s kind of become normalized, right? I mean, Warren Buffett, for goodness sakes, is, you know, been lionized. And yet, he’s the king of predatory lending, as it turns out in Arizona, New Mexico. So which one is it? Do we do we value kind of what Warren Buffett’s banks are doing? Or do we value the communities and what they need? It’s a shift that has happened gradually over time where corporations, you know, really look to increase shareholder value, instead of support stakeholders, which are all of us. So, yeah, CRA. That’s why the reform was necessary. That’s why tribal land areas have been included in the new CRA, because banks simply were not motivated or able to serve tribes. And and now they can. So we’re, this is this is kind of the starting point. This is the baseline data that tells us where we’re at. And the question is, where are we going to be a year from now, three years from now, five years from now? Will the CRA reform have its intended effect? Or will banks have their way in the courts and delay implementation of CRA? Meaning that the numbers will stay the same? I hope that it’s we get to the point where really CRA reform is something that’s used as a tool, and we could come together and build tribal economies and do a better job all of us. A

Wilson 47:24

Real quick, Dave? Isn’t it true, the assessment area component in the care reform does open up new opportunities now for investing in Indian country? And if I can go back one question, people ask what can they do? They can join NCRC. We have a coalition in New Mexico right now that’s bringing together Anglo-African American, Latino and Native American folks. And we’ll probably build one out in Arizona as well. But Dave, I was curious about your view of the assessment rule, or the assessment area changes to the rule change?

Castillo 47:57

Yeah, I mean, it presents tremendous opportunities. But you know, only if you take hold of it, right? If you decide that, as a banker once told me, why would I go through the brain damage of figuring out how to do a deal in Indian country when I could get what I need from the OCC by lending to African Americans and Southside Chicago, Hispanics? And Eastside LA, right? Well, you’re not quite there yet. If it’s too much brain damage for you, I say I say this, I say you could lead, you could follow or you can get out of the way. Right? If you lead, what does that mean? Leading means that you put a budget together, you hire natives, you develop financial products, and you set production goals, right? That means that you’re going to go after the business, you’re going to get the business, and you’re going to grow the business that’s leading. And that’s what we need banks to do. If, if the bank is not going to lead, then they should follow right? There, say, This is too much for us, we’re going to invest in organizations are almost exclusively focused on certain Native Americans on tribal tar sands or exclusively focused, and we’re gonna follow their lead. And if you’re not going to do either of those, well, then get out of the way. Right and stop promoting, you know, don’t don’t put up a Black Lives Matter and, you know, honor Native American peoples day because you’re not honoring it. Right? By not investing is if you’re going to honor that day, and the people that make the investment.

Rountree 49:21

Um, this is a great segue for next couple of questions. I’m going to group these together with that framework, who is leading who’s leading the way? And I’m seeing that question both what banks are leading who’s doing well. And then also, on the policy side, are there any specific house reps or senators, that you were seeing some traction and some leadership from in the spaces?

Castillo 49:46

Yeah, I mean, here in Arizona and New Mexico, we have strong delegation. Certainly the Biden administration has been making good progress. I mean, even the federal agencies like USDA Rural Development We’ve got the HUD 184. But USDA has just been tremendous in terms of rural development, piloting some new initiatives, through special legislation. Also, on the congressional side, there’s some movement to create a new home owner downpayment program niche nationally that would also serve tribes. Let’s see on the on the business front, or I should say, the nonprofit for I mean, there are native CDFIs all over the country, native and native, who have really innovative approaches. And there are more new ideas coming. So you don’t have to look any farther, you know, plug into the network that exists on the private sector side and the banking side, like I said, I mean, you know, folks in the in the compliance community on the CRA side, they are some of those people who are from our communities, they do understand, but it’s really hard to, you know, and I was at the bank myself, right, I used to be the person that would pound my fist on the table. And when I worked on the advocacy side for tribes, but once I got to the bank, I mean, I knew who was signing my paycheck. But you still got to try to advocate. So there are partners and allies everywhere and CRC, again, great on the research side and the advocacy side, I would definitely support membership there. You know, the allies and the folks doing good work. Southwest Native Assets coalition I saw was listed there. They’re doing small dollar debt consolidation lending in, in New Mexico and Arizona. I mean, there again, we’re building the ecosystem. So there is a lot of success stories out there. I think what this report shows is, how much farther we need to go.

Rountree 51:44

Yeah. Thanks, Dave. And I think we have time for one, maybe two, to more questions. And I’m looking to try to prioritize really quick because there’s too many good ones. Why don’t we do this? Because panelists can see this too. Can we do a lightning round? Each of y’all take one last question that you want to answer? Yeah, crack those knuckles, Jason. And 60-second answers.

Richardson 52:21

Dave, are you familiar already working with the Elista? Corporation?

Castillo 52:28

Yeah, there’s a few national groups out there. That’s one out of Colorado. I think there’s a national association NEDA CDFIs. And there are regional groups as well, whether it’s the Southern California Tribal Chairman’s Association, InterTribal Council of Arizona, their inter-tribal organization, not one that I will mention that I think deserves a lot of consideration for doing new, interesting and exciting things is the ability of tribes in Northwest Indians, and the 89 Economic Development Corporation on the small business lending side, their way out ahead. So there are some really good tribal organizations, native led that are innovating on these issues. And I’d really suggest wherever whatever region you’re in, you look up, who’s in your region, and, and we all know each other. So we’re just like two degrees of separation from each other. Anyway, thanks.

Richardson 53:22

I see one that I’ll take. Rebecca Saunders asked, Can you talk about success stories, areas of positive change?

And, yeah, I’m just gonna go ahead and say that you guys are hearing that ringing, right. That’s my, that’s my teenager calling me. Hold on a second. Let me just mute this. Oh, my goodness. So we’re professional, I promise. Yeah, I tell you, what’s positive for me is the growth in data that we’re seeing. Hunter data has gotten better over the last few years and has a much better job of letting us pull out Native American borrowers in a variety of ways. And section 1071 data is coming up as well, in a couple of years, so that’ll be really interesting.

Rountree 54:12

All right. One last question. Bruce.

Mitchell 54:17

I see some controversy in the chat just about the use of Indian Country. Yeah, let me just clarify that a little bit. This is a formal term that the federal government utilizes to send federal regulations, EPA,  executive orders, so we’re using a formal term that’s utilized by the federal government to define these areas.

Rountree 54:40

Yeah. Greg?

Castillo 54:43

Greg, you said something about a question.


Yeah, there was a there was a gentleman from the source in New Mexico who asked about the checkerboard


Yeah, so it checkerboard means land. fractionation which it’s kind of complicated, but the reason And the way that the analysis was done was to take into consideration, you know, houses that are Native American versus, or areas that were primarily Native American. And then all the way there was like four gradations. So the checkerboard areas are an interesting relic of colonialism and expansion and analysis to better consideration for sure. Thanks.

Rountree 55:30

Awesome. Well, thank you guys very much, David, particularly appreciate I appreciate your partnership in this report. Yeah. Jason Bruce, the work that you all do to make sure that data drives the movement for economic justice is just incredible. And the work that then the rest of all of us on this webinar are able to do because of that data is just incredibly important. And finally, Greg, you have chilla cheer leading this effort for a long time and yeah, just really grateful for you working to make sure that we all follow directions and keep moving forward. So and thank you to our attendees. Once again, we’ll share the slides and the recording of this. Please be on the lookout for that soon and fill out a survey so that we are able to continue to improve our content and make sure that it meets your needs. Thanks again. Have a good one.

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