Section VI: Overview of Battle Bank’s CRA Strategic Plan, Effective Date and Term

The effective date of the Battle Bank CRA Plan is anticipated to be January 1, 2024, or 90 days after the granting to Battle Bank of its national bank charter. If the Bank is granted its charter prior to January 1, 2024, the goals for this short period will be to meet with at least three strategic organizations in the AA involved in community development activities to help bank leadership determine what opportunities might be available for community development. Additionally, the Bank asks that any qualifying investments made during this short period prior to January 1, 2024 be considered for the Strategic Plan period.

In developing this 2024-2026 Plan (to include any time during which the bank is open for business in 2023) and its proposed goals, a Battle Bank Organizer has met with and received input from entities representing some community partners. Other members of Battle Bank’s team have extensive experience in Eagle County and the greater Colorado market, including employment in banks that were located in Eagle County and other major markets in Colorado. From and after the Opening Date, the CRA Coordinator is charged with expanding this outreach and establishing programs to better meet community needs.

Goal Formation: 

Based on Battle Bank’s initial research, articles in local and regional press, and contacts with local community leaders, housing continues to be a clear and urgent need for LMI households in the community. Since the Eagle County economy primarily revolves around the ski resorts of Vail and Beaver Creek, most of the employment opportunities center around the hospitality industry and consist of lower wage and seasonal jobs such as ski patrol and lift operators, restaurant and retail employees, janitors and hotel staff, etc. These households are attempting to live in an area that has a high cost of living making it difficult to find affordable housing. Despite the fact that Eagle County does not contain any LMI census tracts, the individuals in need of workforce housing qualify as LMI individuals. Most resort communities suffer from this same community concern and banks within those communities can and should help provide solutions.

While workforce housing needs are clear in Eagle County, after Battle opens it will determine the best methods to support these needs in the community. To help assess these needs, Battle intends to meet with the organizations that support the LMI needs of the area and utilize surveys and other inputs from the community to ensure the Bank is actively meeting those needs.

Beyond Eagle County, Battle Bank may also participate in community development activities in the wider regional area up to and including the full state of Colorado.

Battle Bank requests that the OCC’s evaluation of the Bank’s combined CRA lending and investment performance be measured in terms of a percentage of the Bank’s average assets for each of the three years of the Strategic Plan. The average assets used for this calculation will be derived from the total average assets listed on RC-K line 9 of the Bank’s 12/31 Call Report for the previous year. The Bank will also use average balances for loans and investments for each Plan year as the method for evaluating its performance against the Plan’s goals. Additionally, while the Bank will strive to achieve its lending and investment goals within Eagle County, which is relatively small and does not contain any LMI census tracts, we ask to also include community development activities within our wider regional area – the state of Colorado. We have developed a weighting system for our strategic plan goals to align with our focus on our AA. This weighting system will count all qualifying community development activities within Eagle County at 100% and all other qualifying community development activities outside Eagle County, but in Colorado, at 85%. This will focus Battle Bank’s attention and efforts on meeting the CRA goals inside the Eagle County AA yet provide Battle Bank with a way to still meet its CRA goals by serving the needs of our broader regional area as well. For example, if Battle Bank made a $1,000,000 qualifying community development loan in Eagle County, 100% of that loan would count towards the community development goal. If a similar qualifying $1 million loan was made outside Eagle County, but in Colorado, only $850,000 would be counted towards our Plan goal.

Battle Bank has established volunteer hour goals based on a review of other strategic plans. Battle notes that some large institutions have goals as low as 0.10 hours per employee per year. Given the Bank’s national online business strategy, Battle Bank will have relatively few employees residing in Colorado and even fewer in Eagle County. At the Opening Date, Battle is forecasted to have 43 employees, but currently expects only four of them to live in Colorado and only one in Eagle County. For this reason, we are setting volunteer hour goals based on a per employee in Colorado basis. We have set total volunteer hours at 3 hours per employee in Colorado per year for a Satisfactory result, and 5 hours per employee in Colorado per year as an Outstanding goal. While we expect most of Battle Bank’s employees will reside outside Colorado, meaning their volunteer activities will not count towards the goals under this strategic plan, Battle Bank will still encourage and support employee volunteerism in their local communities so that the Battle Bank team can have a positive impact in all of the communities in which they live.


Based on the information reviewed, Battle Bank will focus on the following areas as it invests in the Bank’s Assessment Area. Battle does not expect to limit itself to the specific efforts described in this Plan, rather it believes that the following are representative of the types of qualified activities Battle intends to pursue. Battle Bank’s possible investments will include the following:

  • CRA Eligible Mortgage-Backed Securities or Municipal Bonds
  • Affordable Housing Tax Credit Investments
  • Certificate of Deposit Investments in Minority/Women Owned Institutions


Battle Bank’s potential lending opportunities will include:

  1. Community development lending and investment in workforce housing plans, projects, occupation, and organizations that support or contribute to affordable housing.

  2. Community development lending and investments that support economic development, job creation and workforce development, and community revitalization.

  3. Small Business Lending. Although Battle does not currently plan to focus on these programs nationally, Battle intends to initiate or purchase SBA 7a loans, which are geared toward small business borrowers, in our Assessment Area.

  4. We expect to provide bank financing to local small businesses for the purchase of equipment and/or real estate.

  5. We expect to participate in the down-payment assistance programs offered through Housing Eagle County. This program helps LMI families with the down payment for the purchase of a home.

  6. There are a variety of community support opportunities available in the Bank’s Assessment Area for investment or lending that Battle Bank will evaluate and consider as the opportunities arise. These include support services for childcare, education, workforce development and job training programs, legal services, health services, and housing services, that partially or primarily serve or assist low or moderate-income individuals or families.


There are several organizations in Colorado, and in the Eagle County community, focused on community development, affordable and workforce housing. Battle Bank will leverage current ties to the community to develop relationships with organizations that can help Battle Bank identify opportunities to best make a positive impact on the affordable and workforce housing and other needs of the LMI residents in our assessment area. The following list of organizations are ones that Battle Bank has identified as actively supporting the LMI needs in our assessment area. We have established relationships at several of these organizations and intend to expand these relationships as well as develop relationships with the organizations that we do not yet know. Our CRA coordinator will be in contact with personnel at each of these organizations to develop specific plans for Battle Bank to support their missions in our assessment area. That support may be financial or through volunteer service by our team members or even via offering financial education to the families supported by these organizations.

Colorado Housing Finance Authority (CHFA) 

Created in 1973, CHFA’s mission is to strengthen Colorado by investing in affordable housing and community development. CHFA was created by the Colorado General Assembly to address the shortage of affordable housing in the state. In addition to helping facilitate and finance affordable housing, CHFA also provides homebuyer education programs, facilitates small business loan programs, non-profit financing, and administers the Fresh Food Financing Fund. 

Impact Development Fund (IDF) 

IDF is a Colorado based CDFI that supports projects that bring together multi-faceted community stakeholders including nonprofit organizations, developers, community banks, individuals and local and state government to help overcome obstacles to ensure critical Colorado community projects can be realized.

Vail Valley Partnership (VVP) 

VVP is a regional community development organization, dedicated to the economic vitality of the Vail Valley. VVP is dedicated to ensuring local business success and fostering regional economic vitality by offering local businesses tools and resources, promoting the Vail Valley to destination guests, and initiating economic development efforts.

Vail Valley Foundation

The Vail Valley Foundation is a nonprofit organization with a mission to provide leadership in arts, athletics, and education, and address community needs to enhance the Vail valley as a place to live, work, and visit. In education, they operate YouthPower365. In athletics, they host the GoPro Mountain Games and Xfinity Birds of Prey. In arts, they operate the Gerald R. Ford Amphitheater and Vilar Performing Arts Center and host the Vail Dance Festival.

Housing Eagle County (HEC) 

HEC is the Eagle County Housing and Development Authority. They have several programs to help address the shortage of affordable and workforce housing in Eagle County.

Good Deeds 

Good Deeds supports the local deed-restricted inventory of for-sale homes available to home buyers that make Eagle County their permanent residence. The goal is to increase the number of deed-restricted units available to in the market by converting an existing open-market home into a deed-restricted home that will be preserved for a local household for the future.

The Eagle County Loan Fund

The Eagle County Loan Fund has three programs to assist the LMI community:

  1. Down Payment Assistance Program:  helps provide down payment assistance for eligible homebuyers.
  2. Rental Assistance Program: provides assistance for locally employed, full-time, year-round renters signing a new 12-month lease within Eagle County by providing them with up to two months of rental payments to the landlord.
  3. Accessory Dwelling Unit (ADU) Program: this program is designed to help increase the existing inventory or local rental properties by providing loans to property owners to finish space that may be converted to an ADU.

Volunteer Hours

Many of Battle Bank’s employees (“team members”) work remotely. Battle encourages team members to become involved in their local area and volunteer to assist with various organizations, including those mentioned above, that benefit the community. Qualified service hours may also include hours contracted to a vendor to teach financial literacy to students at a high free and reduced lunch school and/or hours contracted to a vendor to provide consumer credit counseling services. Volunteer activities that qualify for our CRA commitment include, but are not limited to:

  • Various members of the Battle Bank team are involved as board members of community non-profit organizations in the AA and greater Colorado and will continue or expand on those activities as a representative of Battle Bank;
  • Activities such as teaching and mentoring including youth on basic financial planning skills, understanding traditional banking and credit services, and starting small businesses;
  • Outreach discussions revolving around providing financial independence through education, counseling including fundamental needs such as opening a checking account, budgeting for a first home, establishing credit, or recovering from financial mistakes, either in person or through electronic media produced by Battle Bank;
  • Programs that introduce entrepreneurs and their small businesses to providers of equity capital; 
  • Providing guidance either in person or through electronic media produced by Battle Bank on financial matters to local religious and community organizations that offer services to LMI communities as a part of their charter or practice through Board membership or as an advisor;
  • and other activities supporting LMI individuals and households that are uniquely important in each local community.

The Battle team will work with the organizations noted above as well as others in the community for volunteer opportunities.

Other Activities

  • Community Development loans for activities that support affordable housing, promote economic development and job creation, provide community services to LMI individuals, or serve to revitalize and stabilize neighborhoods and the surrounding economy.
  • Single Family residential loans made or acquired by the Bank on properties in LMI census tract geographies, and/or loans to LMI borrowers.
  • Multi-Family loan originations or purchased loans on units that support affordable housing.

If during the term of this Strategic Plan there is a material change in circumstance, Battle Bank may request an amendment to this Strategic Plan as provided for in 12 CFR 25.27(h).