A local non-profit, multi-social service and planning organization is requesting an annual fundraising donation. Will these donations be considered as CRA?

They are located in an LMI area and conduct services like:

Workforce training
Daycare services for working parents
Senior Citizen centers that include handicap persons
Subsidiary Manages an LMI Senior Citizen Apartment Building

Speaking from experience, it totally depends on your regulators! I don't mean which regulatory body you report to - I mean which crew walks in that year and what their experience with and interpretation of CRA may be. We've received credit for items that techincally don't fit inside the CRA box, then next exam we don't get credit for a slam-dunk? It's the biggest grey area IMHO. Even when you comply with the black and white sections (or at least current guidance), it seems to be up to your examiner's discretion as to whether or not it should qualify.

Sorry, that seemed to turn into a rant...

If you WANT to give this organization money, then go for it and document all of the areas that are beneficial to LMI - it seems like a promising donation, but you just never know anymore.

I know... One year they said it was ok and then they didn't. I think if we document everything I stated we have a good argumen. Either way, we are still helping a good organization.

The only issue I discussed with the branch manager is that it will be for an annual fundraising gala to celebrate the anniversary of the organization and not specifically a donation for job creation or low cost housing, etc...

Good point. Maybe see if you can contribute to their organization in general instead of for the fundraiser? Then the funds can be earmarked for the programs you mentioned above.

Money for a fundraiser gala won't count. For the services you listed, you need to be able to demonstrate documented evidence that those services are provided primarily to low/moderate income individuals.

Workforce training should be easy to prove-get information on how individuals qualify for this training (are they unemployed)

Daycare services for working parents-how do parents qualify-is it income based? Do you they pay and if they pay is it a sliding scale on income? How does the organization qualify them, how do they verify income?

Senior citizens/handicapped...again how do people qualify, there are many senior citizens and handicapped who are NOT low/moderate income. If these services are for low/mod income, how do they qualify participants?

What our regulator advised us to do in instances like this is to contact the organization in writing and have them outline what percent of the donation goes towards underwriting the gala/golf tournament/auction/fundraiser and what percent goes toward the organization's programs.