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Commitment to Fair Lending, Community Reinvestment and Diversity in the Workplace

It is the Bank’s policy to be in compliance with both the letter and the spirit of the fair lending and fair housing laws, including but not limited to the Community Reinvestment Act, the Equal Credit Opportunity Act, the Fair Lending Act and the Home Mortgage Disclosure Act, in all of its markets. Additionally, the Bank believes that increased efforts in making its banking services more available to low-to-moderate income (“LMI”) customers is consistent with its community banking philosophy and offers opportunities for increased market penetration in the communities it serves.

Management believes this effort should include developing additional lending programs intended to make credit, especially with respect to home ownership, more available to LMI customers, as well as efforts designed to help LMI residents create a path to financial success, including the establishment of greater financial literacy and positive credit history. Management also believes this effort should also include greater outreach to minority owned enterprises, including small businesses, in its communities, in an effort to offer financing to such businesses, as well as for creating a more diverse workplace.


Community Development Plan

As part of its continued efforts in furthering community development, the Bank is adopting this Community Development Program (“CDP”). This CDP is intended to serve as the strategic plan for the Bank’s community development efforts. This Plan is not intended to affect, alter or modify any of the policies, including the Bank’s Community Reinvestment Act Compliance Program (the “CRA Policy”), but rather to create an overall framework under which these policies are to be implemented.


Establishment of Community Development and CRA Officer Position

In preparing for this initiative, Midland has created the position of Community Development and CRA Officer (the “CDO”). The CDO reports directly to the Senior Vice President, Community Banking.


Management Oversight

The Senior Vice President, Community Banking, with the CDO, will provide quarterly reports as to performance under this CDP and each Regional Plan. Management will report progress to the Board on a schedule determined by the Chief Executive Officer of the Bank.


Evaluation and Continuity of Community Development Efforts in Acquisitions

A key element of the Bank’s community development program is undertaking and supporting community based initiatives on a long-term basis, where appropriate. In the context of acquisitions, the Bank will continue to evaluate the community development, CRA and fair lending programs of all acquisition prospects, and would generally expect to maintain most or all of such programs following an acquisition.


Safety and Soundness/Regulatory Compliance

Each element of this CDP is intended to be effectuated in a manner consistent with safety and soundness requirements as well as in compliance with applicable regulatory requirements, as such may be amended from time to time. As regulatory requirements change, the Bank will seek input from its regulators, community groups and other relevant parties as to how best fulfill the initiatives set forth of this CDP, and will seek to modify its community development programs accordingly.


Public Benefits Reporting

The Bank believes an important element of any community development effort is communication, both in terms of programs offered as well as goals accomplished. Towards this end, Midland will add a community development section to its website, and will post information regarding its community development plans and performance on this site.

Management also believes that the most effective way to execute the CDP is to work with community groups in each of its markets, and to provide these groups with a clear understanding of the Bank’s CDP and the progress being made under its various initiatives. As such, the CDO and the head of the respective region’s CRA/Community Development Team will meet with various community groups on a regular basis to communicate plans and progress, and to seek additional banking opportunities. While it is expected that the CDO will be the primary contact with these community groups, executive management will ensure that the CDO is not the sole point of contact available to these groups.


Actions to be Taken Under this CDP

The Bank’s management shall take reasonable measures to implement the following community development efforts:


  1. Regional Market Advisory Boards

    Each regional market president shall create an advisory board for their region by the end of 2014. Members of the community advisory board should include representation from a diverse group of successful and respected community members able to assist the Bank in achieving its corporate-wide and regionally focused strategic objectives. Regional market presidents shall also assist the CDO in seeking guidance and assistance from the Bank’s advisory board in their region with respect to adopting and implementing community development programs. Each community advisory board shall seek to meet quarterly with the Bank’s staff and executive management.

  2. Regional Market Community Development Plans

    The CDO will work directly with each of the Bank’s regional market presidents to develop and execute regionally focused community development plans (each being referred to as a “Regional Plan”). Each Regional Plan will seek to include the elements set forth on Exhibit A to this CDP, but will be tailored to the specific demographics of its respective region. Each Regional Plan is to be developed over the first year of this CDP and approved by executive management. Executive management shall insure that appropriate funding and other resources are allocated to the CDP and the Regional Plans.

    In the St. Louis region, following the closing of the Heartland Bank acquisition, the regional market president shall insure that community development and CRA programs currently in place at Heartland Bank are continued following the closing of the acquisition. During the 12 months following the closing of the acquisition the CDO and St. Louis market president shall determine what expansions or additions to these programs should be added to the Regional Plan for that region.

  3. Affordable Mortgage Product or Program

    During the first six months of this CDP the Bank will conduct an analysis to determine appropriate affordable home mortgage products or programs. Not later than the beginning of the second year of this CDP the Bank will introduce one or more home mortgage programs specifically designed to meet the needs of qualified LMI borrowers.

  4. Affordable Home Repair Loan Product

    During the first six months of this CDP the Bank will conduct an analysis to determine the underwriting and compliance parameters of an affordable home repair loan product, and will consider offering such program as soon thereafter as is determined appropriate by senior management. The program shall have a maximum loan amount of at least $5,000.

  5. Small Business Products and Programs

    During the first year of this CDP the Bank will conduct an analysis to determine the parameters of programs or products that are designed to increase access to credit and support for LMI and minority small business owners, and seek to implement such program(s)/products(s).

  6. Banking Services and Products

    The Bank will seek to develop bank services that meet the needs of underserved populations in the manners set forth below.

    • Products that Serve Unbanked and Underbanked

      Within the first six months of this CDP the Bank will offer totally free checking and savings accounts and second chance checking accounts in each of its markets.

    • Age-Friendly Banking Services

      The Bank will consider additional products and services designed to meet the needs of the elderly.

    • Banking Services for Immigrants

      Within the first six months of this CDP the Bank will adopt policies to accept alternative forms of identification for some Bank products and services, including ITINs and consular ID cards, subject to regulatory guidance.

  7. Employment Opportunities

    The Bank will seek to develop bank services that meet the needs of underserved populations in the manners set forth below.

    • Employment

      The Bank will continue to seek minorities and women at all levels of employment, including senior management.

    • Board of Directors

      The Bank will seek to maintain a level of diversity commensurate with its present level.

    • Diversity in Employees and Leadership

      The Bank will commit to increasing the diversity of the staff and leaders of the Bank.

    • Internships

      The Bank will seek to develop an internship program intended to provide employment and teamwork experience to minority students at the high school and/or college level. The Bank will seek to utilize community groups with mentoring programs, as well as schools and church organizations, as referral sources for these internship positions.

    • CEO Program

      The Bank will seek to identify one or more schools in LMI and/or predominately minority school districts willing to adopt the Midland Institute of Entrepreneurship’s CEO leadership program and serve as the principal sponsor for the commencement of that program.

  8. Fair Lending Compliance

    The Bank will continue to maintain fair lending policies and practices that meet all legal requirements. In an effort and to seek to strengthen its existing practices, the Bank shall undertake the following:

    • Second Review of Loan Applications

      Continue to conduct a second review of all loans initially denied, including with respect to applications by minority applicants.

    • Annual Fair Lending Training

      Continue to require all employees and directors involved in lending to complete annual fair lending training. This training shall include the Fair Housing Act, the Community Reinvestment Act, the Equal Credit Opportunity Act, and the Home Mortgage Disclosure Act. The Bank shall also seek to insure that third party agents involved in the Bank’s lending activities receive appropriate training, and conduct audits as appropriate to insure compliance with all appropriate regulatory requirements.



Regional Plan Components

In addition to taking implementing and integrating the programs and other actions to be taken on a bank-wide basis under “Actions to be Taken Under this CDP”, each Regional Plan shall include the following topics. For topics deemed not applicable, reference shall be made to the criteria considered in making such determination:


  1. Service Locations

    The CDO, working with the respective regional market president, will consider whether there are opportunities to open full-service, loan production, community outreach and/or other service locations in LMI or predominately minority areas. If an opportunity to open such location exists, management shall consider whether to perform a feasibility study to determine the costs/benefits of such location.

  2. Retail and Mortgage Lending Activities

    • Target Mortgage Lending Goals
    • Budget and Plan for Minority Marketing and Advertising
    • Budget and Plan Recruitment of Loan Officers with Experience in Minority Communities
  3. Small Business Lending

    Small business lending goals that meet or exceed peer lending levels with respect to small businesses in LMI communities and to minority and women owned small businesses.

  4. Community Development Lending and Investment

    • Targets and Plan for Grants, Investments, and Loans
    • Community Development Loan Officers
    • Lines of Credit for Non-Profit and Community Organizations
    • Support Housing Counseling Agencies
  5. Community Outreach and Engagement

    • Financial Education
    • Utilization of Community Advisory Board
    • Other Outreach and Engagement Efforts (Scholarships, etc.)
  6. Multi-Lingual Materials and Services