From our experience, and my understanding of the Q&As, serving on the Board meets the provision of financial service checkbox. Then you have to determine if the organization you're on the board of has its primary purpose community development.
IV. Service on the Board of Directors of
an Organization Engaged in Community
Development Activities
Existing Q&A §l.12(i)–3 stated that
providing technical assistance to
organizations that engage in community
development activities (as defined by
the regulation) is considered a
community development service. The
Agencies proposed to modify Q&A
§l.12(i)–3 to clarify that service on the
board of directors of a community
development organization is an explicit
example of a technical assistance
activity that could be provided to
community development organizations
that would receive consideration as a
community development service.
Most commenters supported the
proposed revision. A few commenters
raised concerns that mere attendance at
a board of directors meeting was not
sufficient to merit CRA consideration.
These commenters wanted to ensure
that CRA consideration would be
provided only in recognition of active
participation.
In addition, several commenters
suggested expanding the list of technical
assistance activities to include other
professional skills offered by institution
personnel, such as information
technology support, legal assistance,
and human resources, because these
technical assistance activities are crucial
to the provision of financial services by
community development organizations.
The Agencies are adopting the
revision to Q&A §l.12(i)–3 addressing
service on the board of directors of a
community development organization
as proposed. Although the Q&A does
not expressly address commenters’
concerns that financial institutions’
representatives actively participate
when serving on community
development organizations’ boards of
directors, the Agencies note that all
community development services are
expected to provide genuine benefit to
financial institutions’ communities for
consideration in a CRA evaluation.
Further, the Agencies consider the
responsiveness of community
development services. Consideration of
the qualitative aspects of performance
recognizes that community
development activities sometimes
require special expertise or effort on the
part of the institution or provide a
benefit to the community that would not
otherwise be made available.
In addition, in response to
commenters’ suggestions, the Agencies
are adding the following example of a
technical assistance activity that might
be provided to community development
organizations: providing services
reflecting financial institution
employees’ areas of expertise at the
institution, such as human resources,
information technology, and legal
services.