Systems and methods for assisting a bank in meeting all or a portion of
the bank's requirements under the Community Reinvestment Act (CRA) on a
tax-advantaged basis. New or existing cash value life insurance policies
on the lives of employees of the bank or an affiliate of the bank are
provided. The cash-value life insurance policies designate the bank, the
affiliate or a trust as owner and beneficiary. The assets which support
the cash value of the life insurance policies are maintained in a
separate account that is protected from general creditors of an issuer of
the life insurance policies. The assets in the separate account are used
to purchase (i) bank-eligible securities that are qualified investments,
which promote community development, as defined under the CRA or (ii)
whole loans that are CRA qualified loans, or community development loans,
as defined under the CRA. The assets in the account grow on a
tax-advantaged basis, and specific qualified investments or loans in the
separate account are attributed to the bank to satisfy the requirements
of the bank under the CRA.