Has anyone been involved with EverFi? They have software to be used as a 8 week course for High School students for financial education? They provide the software and training of the students. The Banks name is on the software, employees participate in the Launch program, training, 1 hr. presentation to students about finances and the certification event. Have any of you participated in a program like this? If so, did your examiner qualify it for CRA credit?

I have no experience with the specific product, but if your bank has the evidence the program was presented in majority low-and-moderate-income schools, you should receive service test credit. Assuming the story is told in a way acceptable to your examiners.

There are prior discussions regarding this program. "It depends".

http://www.bankersonline.com/forum/ubbth...rue#Post1833187

We recently participated in a presentation from EverFi, which BTW is a for-profit company. Can the bank receive CRA investment credit if they do financial literacy training in LMI schools in our assessment area? I guess I'm hung up on the fact that they are not a non-profit, but then again maybe it makes no difference because we are paying them do do financial literacy traning in LMI schools?

We use EverFi and the data we provided to our examiners on the students reached was highlighted in our PE for our last exam. I currently make sure I note all students served and then highlight those schools with more than 50% free or reduced lunch students as well as our state board of education % on low income students in the schools that are over 50%. Our examiners seemed to like it but we all know that can change depending on agency and even examiners.

EverFi contacted us but we declined their offer. As TryingtoComply mentioned, they are a for profit company, so I don't think the fee payed to the company would receive CD credit. Furthermore, the amount they requested to provide the services and develop the curriculum with our logo was very expensive. Personally, I would see this as a non CD "expense" (not donation). You would receive credit for teaching the classes, but you do that on your own and slap your logo on the Money Smart materials. Personally, I think it a great service, but is something a Bank could do on their own without paying thousands of dollars.

NLT - are you saying got credit for the services, or for the fee you paid to EverFi (or both)?

Out of curiosity, who is your regulator?

Thanks!

Killin Me,

We didn't report the amount we paid. Yes, it's significant, especially given we are in 16 (maybe more) high schools. We received service credit for it. Of the 16, 60-70% of them meet the LMI income threshold.

Our board does look at the expense each year and I wonder if they will continue to fund it, but because there are so many schools and students to reach, doing Money Smart isn't possible for us. Plus, we'd have to share with other banks. With EverFi, it's just us.

FDIC is our regulator.

Interesting....we were told by the FDIC that we would not receive service credit as our employees were not conducting the financial literacy training.

Wasn't there recent guidance that reversed this opinion?

If anyone has the recent guidance, please post a link. We were denied service credit during our last exam in 2013.

If your employees conducted the classes it should count.

EverFi also gives you the option to pay them to do it, in which case I don't think the hours would qualify.

Our employees did not conduct the classes. Our exam was in July 2014.

You just never can predict how these things will turn out. The examiner might not have realized that the bank did not conduct the classes directly, or perhaps has a different view on why this counts.

How was the service description worded in your examination report?

Recent new guidance allows for a bank to decide between investment credit or service credit for the services performed by a partner CDFI. I don't believe Everfi is a CDFI, so this new guidance would not apply. Sorry for the confusion.

After a discussion with an FDIC examiner on this, we decided to pass. The examiner stated that we would not get much credit for this since we are a larger bank and we have employees that can perform this type of service. It might make sense for a smaller bank with limited resources.

I went back to the information we presented to the examiners. We separated out the data from the program we have that is staff-led financial education from the EverFi financial literacy program. I created the document and just noticed today that we call it (bank name)'s Financial Literacy Program. EverFi is not branded in the information we presented to the examiners. Like I said, I created the document and did not do it that way as an attempt to get something past the examiners - that's just how we brand the program. I'm wondering now if they didn't know it was EverFi.

I know our bank looks hard at the expense so I think I might want to ask our local examiners how they look at EverFi. Our examiners might be fine with it OR they might not and just didn't know that's what the program was when I presented the data to them. If they won't count it in the future, I think my bank will be happy to save the money (once our contract is up).

Interesting discussion.