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#1737927 - 09/05/12 01:35 PM CRA Qualified Grants and Donations - CD Services
Luz Offline
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Joined: Sep 2011
Posts: 47
In the absence of to an organization with a "defined mission" of serving LMI or funding being applied to a clearly defined program, if the agency can provide statistics or written evidence of its constituency and the substantial majority of the individuals serviced are LMI, would that be enough to support a "community development purpose". I don't know if that would get me beyond the fact that the CD service must be "targeted" to LMI, but thought I would get your perspectives.

Thank you in advance!!

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#1737933 - 09/05/12 01:42 PM Re: CRA Qualified Grants and Donations - CD Services Luz
manimal Offline
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manimal
Joined: Feb 2008
Posts: 2,207
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In the past we have targeted some of our donations to specific programs within an organization. Usually we document this by stating the name of the program and a brief summary in our donation letter. Then, we ask the receiving organization to include the same information in their thank-you letter. So far, examiners have accepted it.

I hope this helps!
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#1737989 - 09/05/12 03:07 PM Re: CRA Qualified Grants and Donations - CD Services Luz
Luz Offline
Junior Member
Joined: Sep 2011
Posts: 47
Thank you for your feedback! Unfortunately, based on bank size and resources, we do not have a centralized process for corporate giving or a foundation currently. Based on this I may not always drive the decisions and therefore, may not be able to coordinate the funding of a particular programs. As you know, many organizations do service LMIs by virtue of its activities and/or location. The challenge is getting beyond the issue of "targeted" and I was hoping to accomplish this by having the organization document socioeconimic information about its constituency. Any other thoughts?

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#1738010 - 09/05/12 03:24 PM Re: CRA Qualified Grants and Donations - CD Services Luz
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,277
A helter skelter process causes more work and worse results. You don't need a foundation, but you need an up front process or the bank will be throwing money away.
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#1738043 - 09/05/12 04:18 PM Re: CRA Qualified Grants and Donations - CD Services Luz
Pale Rider Offline
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under the Lone Star
Ditto to KB's comments, in the absence of a more organized process, you can have a nonprofit provide you with the demographics of the clients they serve as evidence that they are seving primarily low-and-moderate income individuals. Many health and human service organizations will have annual reports to their funders already prepared that should meet your needs to evidence CRA credit.
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#1740245 - 09/12/12 05:55 PM Re: CRA Qualified Grants and Donations - CD Services Luz
CRAatBOK Offline

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Joined: Mar 2004
Posts: 6,172
Further South than I wanna be.
We keep what we call "master files" on each agency we are involved with either thru donations or services. The file contains info from the website, if there is any, a letter from the agency indicating who they serve and what % are LMI, and any other info we can pull together that supports that they should qualify.

It might be a pain to get it started but it will be well worth it come exam time.
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Life is not the way it's supposed to be. It's the way it is. The way you cope with it is what makes the difference.

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#1740246 - 09/12/12 05:55 PM Re: CRA Qualified Grants and Donations - CD Services Luz
CRAatBOK Offline

Power Poster
Joined: Mar 2004
Posts: 6,172
Further South than I wanna be.
We keep what we call "master files" on each agency we are involved with either thru donations or services. The file contains info from the website, if there is any, a letter from the agency indicating who they serve and what % are LMI, and any other info we can pull together that supports that they should qualify.

It might be a pain to get it started but it will be well worth it come exam time.
_________________________
Life is not the way it's supposed to be. It's the way it is. The way you cope with it is what makes the difference.

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