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#138997 - 12/12/03 03:40 AM CRA Service Credit
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,277
I just wanted to share that I think I have gone over the CRA edge. My group decided to adopt a family for Christmas rather than a grab bag or Pollyanna, etc.. A number of other departments decided to do the same thing and some individual employees are also adopting families. The local charities are loving us. Then I thought...we might get CRA credit, these are all low income families! I think Santa will leave coal in my stocking, but I will write it up just the same!
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#138998 - 12/12/03 04:41 AM Re: CRA Service Credit
Don_Narup Offline

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Joined: Jul 2001
Posts: 3,708
Las Vegas Nevada
Noble work but IMO charity is not counted as a CRA activity
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#138999 - 12/12/03 04:51 AM Re: CRA Service Credit
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,277
I have a new view on CRA. If there is a glimmer of credit, I write it up. The worst that happens is they say no. If I don't write it up, they never get a chance to say yes. There is not much difference in our giving a grant to the local soup kitchen, or the local Catholic Charities or Salvation Army - where we get the connection to these families - than doing it family by family. We could give the grant and let the charity do the work or we could go direct at the request of the charity. Never say never when it comes to CRA. I learned that from Dawnie. I could even call it a program.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#139000 - 12/12/03 05:50 AM Re: CRA Service Credit
Princess Romeo Offline

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Princess Romeo
Joined: Jun 2001
Posts: 8,272
Where the heart is
Kaybee - Here's what you do: When you give the family their gifts, ask them if they would like to have a special "Money Smart" training program just for them. Even if they are interested in only one chapter, you can get CRA credit!
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#139001 - 12/12/03 09:59 AM Re: CRA Service Credit (or Grant!)
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,277
I decided how I am going to do this....I am going to write it up with my grants as a grant supplement. And you can see I woke up quite early thinking about this. The local groups we give grants to asked for our help...financially or by directly purchasing clothing etc. for their families in need that they support. Many employees offered to participate personally along with the bank. So, I am putting it with the grant info. It would have come out of the groups budgets otherwise. We are already doing financial counselling with several of these groups and that of course is with the service info.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#139002 - 12/12/03 03:51 PM Re: CRA Service Credit (or Grant!)
Pale Rider Offline
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Joined: Aug 2002
Posts: 34,318
under the Lone Star
A point of clarification: you aren't trying to get credit for the bank by using contributions of employees, are you ?
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#139003 - 12/12/03 06:12 PM Re: CRA Service Credit (or Grant!)
Anonymous
Unregistered

While very worthwhile and commendable, IMO, this would never ever be service credit. What technical assistance or financial education would you be providing by purchasing items for a LMI family? This may be a CD investment/donation, but as Don inferred, ONLY if the funds are being provided by the bank, not individual employees. If "your group" adopts a family and everyone personally donates, even though your contribution may be in the name of ABC Dept at XYZ Bank, you can not present that for consideration because the bank did not make the donation - the employees did.

And while I agree that you should present the "maybe" or borderline services and donations to the examiners for consideration, submitting activities and donations that clearly do not qualify will leave your examiners with an impression that the bank does not fully understand the regulation.

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