Has anyone worked with their local Junior Achievement using a JA Day for CRA credit? Thanks.

What would be your CRA "hook"?

In our case it is usually done as financial literacy in Title 1 schools.

Yes, and received CRA service credit for the banking/economics related courses we taught in Title 1 schools.

Title 1 is not the same as greater than 50% eligible for free and reduced lunch. School leaders usually don't get that distinction.

Although with nearly 50 million people on food stamps there are a plethora of schools with a majority of students that are classed as economically disadvantaged.

You are right, sorry, I used sloppy short hand. We also verified that the Title 1 schools are majority free or reduced lunch and that that equated to low or moderate income for our MSA's.

Financial Literacy in predominately free/reduced lunch schools will garner CRA credit, regardless of whether a bank does this on its own or in partnership with another organization.

Thanks all, that's where we are heading.

If you are an OCC bank be careful about the way you qualify the school. They have told us that we can only use the % of students qualifying for the free lunch program and not the reduced. They used to make us verify the the majority of the schools students were at less than 200% of the poverty rate so this is much easier, even if it doesn't match what the other agencies do.

So am I mistaken in thinking that teaching financial literacy to an elementary or middle school kid (qualified as majority LMI) would count for CRA credit? I guess in the long-run it will help them to perhaps ascend out of poverty, but can we get credit for helping the kid? I thought we were supposed to be serving the parents?

Admittedly a new CRA guy here.

Norman, it does count - you just have to document it.

We are FDIC regulated - Based on exam last year they allow % of free AND reduced lunch students (which apparently differs from the OCC). The website they recommended I use is:

http://www.publicschoolreview.com/

Good Luck!

Financial literacy training for schools is a very common CRA service, nowhere does it say just adults. Just document how you determined that the school was LMI. Examiners are not consistent in what they want re determining LMI, even within an agency, unfortunately. You might want to check with your region so that you spend your time appropriately.

Interesting. I guess we will pursue this route. One of the schools is in our area and has 51% of students receiving free lunch with 60% of the total enrollment receiving free or reduced.

We use the free/reduced lunch numbers as a proxy for LMI with success in all of our AA's.

I would argue that teaching children about financial literacy is more beneficial than teaching adults. I always tell my CRA people to get to the kids before they have a chance to make the mistakes that the parents make. It's rare that you will have adults paying attention and making changes in a financial literacy presentation but the kids are much easier to engage.

I'm never left surprised with the things I learn on a weekly basis doing this job.

This makes complete sense, and I hadn't considered it before.

There are a certain number of MSAs around the country, and they change from year to year, in which the dollar limit for reduced lunch is higher when compared to less than 80% of the median family income for that MSA. That is why you must always be careful when using FRL as a proxy for LMI. Hence, the OCC's concern about making blanket statements that the FRL program is a proxy for LMI. It is not.

Heretofore, this has impacted me in the Texas cities of Odessa, Abilene and Wichita Falls. It is frequent to find these MSAs in California and Florida as well.

Our last exam the FDIC was finicky about multiple bank participants at the same event. With students, it may be the same grade, but different home rooms, or at the JA event different team members interacting with different students or serving different roles.

Has anyone has success getting credit for sending a team to JA events?
Do you get credit by the grade or classroom when you do financial literacy sessions at schools?
Do you get credit for multiple lessons to the same grade at the same school?

I know the examiners use discretion, but I am trying to maximize our effectiveness and need some help!!

IF you are using your financial expertise, or providing workforce development--then that is as far as your examiner should be made aware of about the event, and the qualitative elements like hours, and amount of students served.

1. JA only qualifies if the students are from an LMI School, or benefactors of a nonprofit that predominately serves LMI people.
2. You get credit by each activity performed. 1 person = 1 activity no matter the students or hours served per day. All the other pieces are qualitative elements that build weight to the activity itself.

Remember, schools qualify if they:
1. Have a majority of students on FRL; or
2. The school is in an LMI, middle-income distressed, or underserved census tract; or
3. The school is a recipient of the Title-one school wide program.

Remember, schools are considered nonprofits if government run--so the Q&As about services to nonprofits apply here.

Additionally, if a daycare is also from an LMI area, and they go to JA then that would qualify as well.

Document! Document! Document!

I was recently at a meeting put on by the Fed that included the FDIC and OCC for CRA. Based upon the comments made by the different examiners, the OCC's bar appears set a lot higher in comparisons to the other's agencies. The other agencies seemed willing to work with institutions. The OCC basically said you had to condition just about everything to make sure they were only used only in your area especially in the low to moderate income census tracts. And you better be able to prove you had those conditions. So for JA, document everything about the schools.

At my old shop, we regularly sent teams to JA events and always received credit. We usually presented a number of students taught per bank employee.