Can someone help me understand what types of donations to Title 1 schools would qualify for CRA community development credit?

Easy answer all of them. The school is providing a service to LMI students (qualified through title 1). I suppose you might find a rare program for only the rich students of the school...(I doubt it) but in general, any donation (and it must be money or stuff paid for with bank money) would qualify.

Dawnie, Please give me a definition of a Title 1 school, I would like to no how to find out if we have any around my banks area. This sounds interesting. Thanks for any help you can provide.

Go to www.greatschools.net it gives you the list of schools in your area and the percentage of children receiving reduced or free lunches. We count any school that has more than 50%.

Title I (Chapter I): A federally-funded program to help educationally disadvantaged youth. Its current focus is on schoolwide improvement and stronger partnerships among educators, parents and communities. Title I funds are distributed nationally and allocated by districts to schools based on their numbers of low-income students.

Each state has a website listing their Title I schools. You could call the local school district and ask for it, or Google it for your state and see what you get. They are updated regularly (with each school year).

All Title I schools are qualified for CD credit. They receive the allocation because their percentage of LMI students is high. If you can find a title one list for your area, stating that they are title one on your donation write up is enough to cover your documentation of income qualification for any examiner. (They all know the program)

sorry for the late post, I just saw this thread.

at our most recent compliance exam (FDIC, Dallas region)they would NOT allow us to count donationions made directly to a student organization within a school where more than 50% of the students were on a free or reduced lunch program. For instance, if there was a donation made to the FFA organization, they said NO WAY....the examiner then went on to tell me that there was no way to know whether or not the students in that club were LMI, and in his opinion it was unlikely...then he informs me of how expensive it is to maintain livestock projects, blah blah blah. Of course I argued that it was only reasonable that any given club would be made up of a cross section of income levels, but they wouldn't bite. We lost on quite a few CD investments and services for his interpretation. Oh, and BTW, I attended a seminar conducted by the same group last week, and the speaker from the Dallas office said we could NOT use the free and reduced lunch schedule data.

Queenie, do you have any documentation showing that this should be accepted, so that I can deal with this the NEXT time they are here?

We had our exam this Spring and I fully utilized the free/reduced price meal percentages as well as schools receiving Title I grant money and we received credit for them. I compared the meal percentages at each school to that of our state's average percentage. I also went to the schools websites to print off where they have Title I faculty members and sent out a letter to each Superintendent in our assesment areas to reply back to me with their information on Title I funds as well as information they gather on the poverty levels at each of their schools. There were very many responses and I used them for further documentation as well. FWIW - I also printed off the Title I section of the No Child Left Behind from www.ed.gov The describes the program.

The last anon post was from me - I didn't check to see if I was logged in.

Shannon ~

thank you for your response. Did you show that a donation was made directly to the school, or to a club within the school? for some reason, the Examiner I talked to drew a distinction between the two...giving to the school = CD credit, giving to a club at the school = no credit.

Anon with the declined Title 1 FFA (what is that LOL) project

All donations to Title One schools meet the goals of CRA, which is to serve primarily LMI populations. That's basic "CRA" and easy to support since Title One requires that the majority of the students are LMI (or qualify for free or reduced lunch). But that's the school of course. (And by the way, Shannon goes through much more work than I do to justify that. I provide the states list of Title One schools within my donations package for reference with no additional follow up for examiners at the school level).

As to a club that is linked to a title one school...You don't want to hear this...but I can see their point (the FDIC examiner). The club itself would need to maintain financial data on their members to qualify if they are not the school itself. While your arguments make sense, looking at the big picture, it's possible that you coudl have a club within a Title One school that would see mostly "rich" or upper income kids participating in it. For instance, how about ski clubs? I've seen the costs of those clubs, and what I've seen is that the kids participating are mostly higher income kids. It's just too expensive for LMI students to afford, even though they go to the same school.

I'd call the clubs, just as I would any other charity, and ask how they review income qualifications for their students. If they have programs that meet the CRA goals, restrict your donations to that program specifically, otherwise make those general donations if the whole group qualifies, but do document "how" they qualified, with more than the Title One designation (which belongs to the school, not the club).

Sorry...you didn't want that answer did you?

I cite the group at the school that is benefiting from our donation if there is one. For example, if it is their vocal music program, etc. Otherwise, if it is to just buy new t-shirts for the school because they are having an annual celebration then that would benefit the school but I do mention what the proceeds are used for.

I am sure I did overkill on my documentation but since this was our first large bank exam and my first exam as CRA Admin. ever...I didn't want to leave anything to chance! I also used the same documentation regarding school bonds that the bank invests in.