We've received a request to sponsor two high school students to FCCLA (think Home Ec back in the day) National Conference. The district shows 50-59% free/reduced lunch. The high school only shows 30-39% free/reduced lunch. There is no indication in the application documents that the 2 representatives come from LMI families. My thought is that this would be a bank side donation, but I would appreciate any insight others may have for similar situations.

The numbers presented are confusing. The 50-59% - are you saying free is 50% and 59% is free plus reduced?

That is a side issue anyway. I don't think you can use the district numbers if you know the school.

When you say "bank side donation", are you saying the sponsorship wouldn't count as CRA eligible?

I don't think using the district numbers would work if the donation does not benefit the entire district. Sounds like it will not count for CRA.

If the school can attest that the two students are from LMI families, then you should be able to include as a CRA Investment (donation.)

Otherwise - it's a nice thing the bank is doing but no CRA brownie points for it.

Yes, like any scholarship for CRA purposes, the recipients must be low/moerate income and you need to know how the school determined that.

agree with Romeo and KB. Have the school provide documentation showing that the recipients were LMI. If not, this would not count for CD. Good luck!

Thank you everyone for your insight. I also thought it would only qualify if the school provided documentation that the sponsored students were LMI, which they were unable to do.

The Oklahoma State Department of Education no longer issues an exact figure for free or reduced lunch eligibility. It is instead reported as a range in tens. 50-59% is the eligibility for free or reduced lunch for the whole school district. 30-39% is the percentage of free or reduced lunch eligibility for that district's high school only. In visiting with the teacher, FCCLA membership is available only to high school students at their school. That is why I put the 30-39% number out there.

If we are unable to make a donation based on CRA eligibility, we refer the request to the branch manager for consideration as a donation from their branch budget.

Again, thank you for your help. I greatly appreciate it!

There is a stigma attached to self-identifying as being "poor". The wide variance between elementary and middle schools versus high schools in the same district seems to bear this out.

There is a movement to stop having children apply for the free and reduced lunch programs and simply provide meals to all students.

Not sure how the OCC will handle districts and states deciding not to make this program income eligible as far as determining CRA eligibility. I think the FDIC is more lenient in accepting the "Title One" designation as a proxy for LMI.