I have my first CRA exam in a month and am working to put together Community Development materials for the examiner. We are in a small rural community and will be evaluated with a modified approach combining both the previous large bank and the new intermediate small bank methods. As our assessment area does not include any low income areas, I am wondering if I should try to obtain credit for a very large donation we made to a Youth Center.
It's mission is to foster and reinforce positive values, habits and lifestyles upon which youth will be able to build their lives and communities. It's goals include providing a safe place where kids can have fun... and providing intervention in the lives of teens who are deemed to be "at risk."
The center is located in our downtown area which is the lower income area of a middle income rural town.
Do I have a chance or should I let this one go?

In the new exam process it says:

"A Satisfactory rating is based on the banks community development performance demonstrating adequate responsiveness to community development needs through loans, qualified investments and "Services" as appropriate.

I don't see the specific requirement that a CD activity has to be beneficial to LMI individuals.It says Community Services which IMO would be based on the Community Needs assessment you need to prepare.

If you can show the donation contributes to a community development NEED then IMO you have a shot at getting credit. It shouldn't hurt to try.

IMO we are going to have to go through a few exams to get a real understanding of what is going to be acceptable.

Actually we don't know yet if Donations will be acceptable as a "Service"

Susan can they show service to LMI teens? I'd still want to see that as part of the criteria. Rich children who are at risk because mommy and daddy spend too much time on the yacht still aren't going to qualify.

The CD test does state that investments (donations), services and loans are all factors. They further state that the CD loans, qualified investments and CD services need to be verified to see if they qualify as CD. I don't see them backing off on the LMI needs to focus on just any old service. I think if that were the case, you'd see it spelled out in the procedures.

If you're going to make this deal work, be sure to find that spin! I think it's crucial in early exams to be careful you don't look like you're pushing the envelope too hard (ie the rich kids). I don't see the room in the reg for it at this point. While they do address housing needs in middle income hubs, they certainly didn't back off on all needs being focused on LMI individuals. The opposite really as they expanded the housing portion to allow that in middle income areas which are rural, there are still housing needs for LMI folks, which need to be acknowledged.