Has there been any type of FFIEC memo regarding allowing CRA flood services for a large bank to count towards getting CRA credit that normally would not have counted. For example, we are a Texas bank with only Texas branches so if we are assisting the recent hurrican victims will we recieve credit. I heard Washington is broadening the definition of CRA services and loans, etc. for the hurricane, but I haven't seen anything in writing. Is there any such document out there or is this just all talk? Thanks.

Under the new Community Development you can obtain credit for activities in a "Designated Disaster Area" as declared by FEMA by providing revitalizaztion or stabilization activities "IN" the designated area. Consideration will be given by examiners for "All" activities that revitalize or stabilize a "designated area"

Beng in Texas that may not help you a lot however,If you have activities that help LMI individuals (storm victims or not)you can receive Community Development credit providing the activity qualifies under the CD guidelines such as

"Providing credit counseling, homebuyer and home-maintenance counseling, financial planning or other financial services education to promote community development and affordable housing; "

Do a search as there have been recent post regarding the community development requirements that will explain what qualifies. Check te post regarding the Q&A. It links to the Federal Register which describes the requirements in detail.

I cannot locate the post regarding the link to the Federal Register--do you know which link it is? Thanks.

Open the thread titled "OCC, FRS, & FDIC Proposed Q & A on CRA"

Call me a dummy Don, but I cannot find this thread. Help please.

Look in this CRA Forum. Right now its the 8th post down from this one. Shows 48 views and 0 replies

Thank you--I found it and read through it. I still have a question regarding the disaster areas. Would a bank receive CRA credit for their financial services/activities if the disaster areas were not located close to a bank's assessment area? Are the guidelines giving any lenient measures regarding this? We would like to assist more with the disaster relief, but we're not for sure if the examiners would give us any CRA credit for our efforts if these areas are not in our assessment area or close to our assessment area. Thanks.

Qualified community development activities have always been required to be related to the Assessment Area in some way. The activities may be outside the Assessment Area if they are in a broader area that includes the AA (e.g., MSA or county). The focus of CRA has always been to emphasize what you are doing to meet the needs of your community. I can not find any exception to this basic requirement in the revised CRA or its related questions. So I would find it very unlikely that you can get credit for aiding a disaster area that is 500 (?) miles from your community, as laudable as that may be.