SOme officers are members of Lions, Kiwanis, Rotary. Can we report this for CRA or do we have to drill down to specific activities, i.e. Board member of XYZ charity. Servied on soup kitchen activity during thanksgiving. I thought the activities had to be specific and that simply being a member of these types of organs. wasn't reportable for CRA consideration.

None of those organizations listed have a primary purpose of "community development" or meeting the needs of low to moderate income. They typically serve all people in need, regardless of income. That has been my experience with these organizations.

Take a look at the mission statement.

Even the specific activities you listed would not get you CD Service Test credit. They are not using your banking skills (financial in nature).

We never interpreted the service test to focus solely on banking skills. We have a number of people who serve on boards, etc. and not in a financial oversight capacity. this has not come up before. I wanted to check to make sure the def. was not more borad than I originally interpreted it to be. I agree with your first point - simply being a member and attending meetings does not fit. Thanks

By definition, serving on a board is using your banking expertise (reviewing financials...that sort of thing). So if the organization's purpose meets the definition of community development, serving on its board of directors should qualify for CD Service Test credit.

But back to the original question, I do not believe serving as a dues paying member of the Lions Club, Kiwanis, or the Rotary Club will get the bank any CRA credit. None of the specific activities these service organizations typically engage in would get the bank any CRA consideration either. It would be similar to swinging hammers at Habitat, it may be the right thing to do in your community, but it is not a service that is CRA eligible.

The regulators are being tougher about the requirement that community development service must utilize banking skills.

Community development service means a service that:
(1) Has as its primary purpose community development;
(2) Is related to the provision of financial services; and
(3) Has not been considered in the evaluation of the bank's retail banking services under Sec. 228.24(d).

For groups like Rotary, etc. you would have to demonstrate a special committee or project that met community development requirements. In and of themselves, those groups do not qualify.

I got this to qualify earlier this year, but it was very difficult. My argument was...

"One employee is a Board member and, in 2009, was directly involved in the fundraising efforts to build the XX River Walk, which is a scenic trail for walking, running, biking, and rollerblading in downtown CITY. The walk has revitalized low- and moderate-income geographies in CITY. [I provided a map showing that the walk went through low income tracts and every article I could find on the project.] Additionally, the employee’s efforts are recognized in Rotarian projects, such as providing college scholarships to “at need” students, organizing an annual blood clinic with services provided at low costs to help underinsured individuals get important health tests, hosting a Christmas party for disadvantaged children, and fundraising for a food drive for the XX Food Bank."

If you're short on services and can document the heck out of the projects, give it a try. Otherwise, don't waste your time.

I also agree that being a Board member is a better argument than a member.

***Warning....CRA novice posting ***

In order to get these services counted, should the service be performed on bank time or should the employee be considered as representing the bank?

We have a number of employees that serve on boards of local non-profits, head up fundraisers, and, yes, swing hammers, but they do so on their own time and w/o wearing their bank logo.

Typically, it is on bank time or representing the bank. However, the spin is for example: that an individual’s employment at ABC bank may prompt non-profits to solicit the employee's involvement on their Board. (Without employment at ABC Bank (high profile or leadership), they would not have been asked to serve on the Board). Additionally, even though the Board may meet "after bank hours", we consider the employee representing the bank.

Regarding swinging a hammer, examiners do not consider this type of activity for CRA Service Credit (must be financial in nature).

I know being a member of Kiwanis, Lions Club etc does not count for CRA. However if an employee is on the board of the local Kiwanis club (representing the bank) and the club asks the employee to give a financial literacy presentation at a school with greater than 50% free/reduced lunch program eligibility, would that count? Obviously we've got the LMI factor as well as the financial expertise factor met. However, I'm questioning if the employee is representing the Kiwanis AND the bank will make the service not count. Typically representing the bank is the easiest factor but this time I'm not seeing a way this will count.

I would say you have a good argument to make for qualifying this activity. More than likely, the banker was asked to give the presentation because he was a banker and had the financial expertise necessary.