In addition to my duties here as CRA Officer, in my spare time I serve as treasurer and as a volunteer and foster home for an animal rescue organization.

I've come in contact with many programs that offer free vet services in low income areas. Some of these programs have found that many times low income residents can't afford vet services for animals, thus cat and dog populations in these communities can become a nuisance. Also, they found that many times low income residents will often spend any money they have on their pets, because sometimes the pet is the only friend or family or possession they have.

In short, these programs can benefit not only the animals, but also benefit the lives of low-income residents and the low income community by controlling the pet population.

My question is, if my bank donated to such a program, is this something the OCC would be likely to give credit as Community Development?

I think it certainly is a service to low income residents. You would have to deal with how the entity providing these services qualifies individuals for the service...how do they know they are low income.

Other than that, I would emphasize how it is a key need in their life and this organization is providing it, saving them money to spend on other needs. The neighborhood as a whole benefits from pet population control and the individual pet owner benefits from having pet medical services provided at low or no cost, which then improves the rest of their life and budget.

Being true to my old half empty glass type of guy, I can see an examiner team denying any credit for these services. They have a history of not being impressed with the arts and culture benefits for low and moderate income individuals. I can understand how they might put this in the arts and culture grouping...just my opinion.