Is there a list anywhere that defines what services would qualify for CRA credit?? We are trying to get some creative ideas going. We already do Habitat...

Thanks in advance!

Click here , start reading with the question at the bottom of page 11649. The following two pages will give you a list of examples of community service activities.

♥ you SF!

I don't know why the link above is not working; it worked yesterday, and I just accessed it again this morning.

Here is the link: second attempt

As a Community Development Service, your initiatives with Habitat would qualify if you provide the organization assistance on financial matters, provide credit counseling or homeowner counseling to new homeowners or you participate in an employee loan program. If a monetarily contribution (used to purchase supplies to build a home) to the organization is involved, then you should receive Investment credit. If employees are assisting in building a Habitat home, no credit would be received. That is how I understand it.

This is a link to an OCC Community Developments Fact Sheet which should give you ideas to assist you in your CD Services endeavors. http://www.occ.gov/static/community-affairs/fact-sheets/Fact_sheet_CRA_loans.pdf

Thanks!

If you have any Community Development Corporations, or a Small Business Development Center, and any of your loan officers participates on the credit committee - that counts.

Also, if you partner with a local community group or school to provide financial education programs, such as the FDIC Money Smart program to low-mod residents, all those hours of involvement count.

Community Groups such as the local Housing Authority, NeighborWorks program, Habitat for Humanity, etc., can be potential community partners for financial education.

The OCC has a lot of info at their site:

http://www.occ.treas.gov/topics/community-affairs/publications/index-ca-publications.html

It is informative for all banks not just national banks.

Does partnering with Women's shelters and food pantries count, I didn't see that on the lists I have reviewed?

If you can qualify it as provision of financial related services. Handing out foot at the food pantry won't count.

For the shelter, you will also need info on the economic status of the women. It can be done - but these days examiners want documentation, documentation, documentation.

Thanks for all the help.

Regarding the Women's Shelter and documenting the income of the clients served, utilize the internet and look at an organization's website. The organization's mission statement can give you an indication of clients served or there may be a section about how clients are referred and may include income qualifications. If a determination cannot be made, I contact the organization directly. More likely than not the organization has this data (income of clients) documented, as it is needed in order to receive federal, state, or private funding or in order to be a partner agency with an organization such as United Way.

I do the same for Community Development Loans. For example, my financial insitution orginated a operating line of credit for an organization that serves clients with chemcial dependencies. By writing to the organization I was able to get an understanding of income level of their clients.

You may find it works best to obtain all documentation prior to engaging with an organization. Have an application form for grants or services projects. Ask for documentation of client base income, client base served, etc.

These groups are used to filling out applications for grants from foundations and can provide the info you need.

An organized method of gathering and documenting information goes a long way with examiners as well.

Kaybee, I agree it is best to get all documentation prior to engaging with an organization, particularly when the subject is investment credit (i.e. - grants from foundation). However in my world (and in a good number of other financial institutions), the majority of grants go to organizations in which management serve on the board of directors or to an organization in which the financial institution hopes to gain their business. It is a fact of life. Ideally, CRA should be at the forefront, however for reasons mentioned above it often requires a great deal of effort to obtain documentation after the fact. Any suggestions to break through this cycle are appreciated.

When I was still working with CRA as a banker, we had a CRA committee that was made up of folks from different regions who helped us "deliver" in their region, from finance (for investments), and 2 directors who were very involved in the community. Those 2 directors ended up taking CRA very seriously and kept in front of the board. They supported us requiring the needed paperwork from ALL organizations, asked about income of the location of new branches, looked for opportunities, and were really our champions. They had no problem handing the application forms to the organizations - even those for which they themselves were board members. Our lives were so much easier after getting the ap forms and getting those directors involved.

At meetings we would review the applications, whether a request could come from our CRA budget or should be referred to marketing for their general budget, and sometimes what we could do to construct a service or grant to be CRA eligible, like putting a restriction on the use of funds for the organizations low/mod efforts. We also discussed new opportunities coming up, getting involved with new (to us) organizations, new branches, new regions, anything we needed to do to stay on top of CRA across our AA.

Agreed!

I wanted to share this:

I went to an Interagency CRA Officer Workshop last week and the discussion turned to women's shelters. Apparently this has been a topic at several of these workshops that have been held around the West Coast. The consensus of a couple of the Regulators (one was OCC and one was FRB) was that no matter what the previous income level of the clients of the shelter, at the point that woman (or man), entered that shelter, they most like had nothing. They fled their situation without making financial arrangements and left with only the clothes or their backs and they may have been lucky just to escape with their lives. And this fact made them, at the time, low income.

It was a surprising and refreshing commentary from the Regulators in this time of documentation; documentation; documentation.

That is refreshing, surprisingly so! It was always the theory of the banks, but nice to have it validated!

Fat chance, of course, that the Examiner sitting in your office will share the same view. But, refreshing nevertheless.

Very true. Right back to the old personal opinion problem.

Why can't I ever have reasonable examiners like that?

<---is fairly lucky as far as examiners go. I mean sheesh they could always be worse!