To qualify as CRA CD service, an activity has to be provided by someone as a representative of the bank. That would seem to exclude activities done as part of an elected office from consideration. Is that correct? The activity might be CD purpose-worthy, but at what point does the connection to the bank role end and the personal/public role take over? I thought perhaps being elected as opposed to appointed or volunteering might be one way to explain this.

I disagree. Serving in a public office would mean that you're representing a constituency or government entity, not the bank. Also, the service would have to relate to the provision of financial services. Not many elected public offices would meet this requirement.

I would have to know more about the position to have a valid opinion. For instance, if we're talking about a Senate position, I'd agree with grmasterb and say "no" I wouldn't try to take credit for that. It's an elected position, with salary or reimbursement, and it's not really representing the bank's CD efforts in any way.

But if we're talking about something more simple, say a Housing and Neighborhood Development Committee position at a local muni or even on a statewide level, I would (and do) take credit for those hours. This is not a paid position, and the person fulfilling the position is representing the bank or banking community on the committee. In addition, it can easily be linked to provision of financial services, so it's pretty easy to write up.

So what type of position are you talking about?

Sorry - that's what I was stating, that it would not be considered based on the representation of constituency factor. In this case there were qualifying activities (within a particular school district).

Another case I've encountered is a local government appointment to an economic development group dealing with small business funding. Same thing? Or do the lines blur more when a lender participates in local development efforts? How do you train staff on this topic so they undersand the distinction?

It sounds like you have it figured out As long as they're representing the bank, or banking, I'd take credit for the time. (within the CD qualified activities listing of course).

In the case of the gov appointment (the HAND commission I discussed is also a gov appointment) I'd take credit for that. I wouldn't factor in your activities in local development at all. We're all "interested" in local development aren't we? The position might even allow for a heads up on CD activities in reguards to development, which is good for the bank and the community.

How do I train staff? Hummmmm I don't Ok you didn't want to hear that answer. These types of service activities are so very case by case that I review each on an individual basis for qualification. We have all activities reported, and weed out the goober. This increased our CD activities by about 50% overall in hours served. If you try to train staff on this issue, they'll see only the most black and white picture, when this is all about the grey.