Skip to content
BOL Conferences
Thread Options
#2085340 - 06/27/16 03:48 PM Community Development Investment(Grant)
wblewis935 Offline
Member
Joined: Feb 2011
Posts: 53
We have a charitable contribution request from a local city who is raising funds to replaces the playground equipment at their park. It's a public park with a pavilion, basketball court, baseball and football fields, etc. The development is necessary to ensure the safety of the children as well as allowing special needs children easier access to the park.

Is this considered community development?

Return to Top
CRA
#2085349 - 06/27/16 04:26 PM Re: Community Development Investment(Grant) wblewis935
Pale Rider Offline
10K Club
Pale Rider
Joined: Aug 2002
Posts: 34,318
under the Lone Star
Based upon the facts as states in the post, my vote would be no, it is not a CD investment.
_________________________
Societies that do not find work in and of itself "pleasing to God and requisite to Man," tend to be highly corrupt.


Return to Top
#2085354 - 06/27/16 04:50 PM Re: Community Development Investment(Grant) wblewis935
wblewis935 Offline
Member
Joined: Feb 2011
Posts: 53
So what would make it CD? I guess I have a hard time distinguishing between what is and is not CD. If the park is located in a LMI tract, would that make it a CD Investment?

Return to Top
#2085376 - 06/27/16 05:38 PM Re: Community Development Investment(Grant) wblewis935
RR Jen Offline
Power Poster
RR Jen
Joined: May 2003
Posts: 3,760
Running and riding everywhere ...
If it were in a LMI tract or a distressed county, I might try it. I've ran across some examiners that would count that and others that wouldn't. I'd stress the "benefit" to the distressed/LMI individuals though.
_________________________
I don't need any more negativity in my life...be positive and helpful people or I will kick you in the shins!!!

Return to Top
#2085389 - 06/27/16 06:19 PM Re: Community Development Investment(Grant) wblewis935
CompliantOkie Offline
Gold Star
CompliantOkie
Joined: Dec 2013
Posts: 425
OOOOOOklahoma
I'm with Jen. If it's in an LMI tract, you could make the case that it enriches the lives of the kids in that tract. If it's in a mid or upper tract, I don't think you have much of a chance of it counting.

Return to Top
#2085444 - 06/27/16 07:56 PM Re: Community Development Investment(Grant) wblewis935
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
If in an LMI tract, I think this has a good chance of qualifying. It benefits the neighborhood residents and improves the area.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

Return to Top
#2085940 - 06/29/16 06:13 PM Re: Community Development Investment(Grant) wblewis935
wblewis935 Offline
Member
Joined: Feb 2011
Posts: 53
So what are your thoughts on an organization that provides Christmas gifts to kids who would not otherwise receive them. By default, these children are from LMI families, but the organization doesn't TRACK income for the kids who get the gifts. They KNOW that the kids are low income, but can't provide any documentation to prove it. I have a hard time using some sort of proxy to prove it (like free/reduced lunches in the area schools), because those aren't above 50%.... I would love to submit this for credit, but I'm not sure how the examiners will respond. Any thoughts?

Return to Top
#2086009 - 06/29/16 09:01 PM Re: Community Development Investment(Grant) wblewis935
Pale Rider Offline
10K Club
Pale Rider
Joined: Aug 2002
Posts: 34,318
under the Lone Star
It is not unusual for partnering nonprofits recommend the families and children to be the recipients of these gifts at Christmas and at the start of the school year (programs like "Stuff the Bus"). So even though the organization organizing the program of gifts has no evidence of the LMI status of the families, the partnering nonprofits have vetted the families and can provide confirmation that any family recommended has met an income test.
_________________________
Societies that do not find work in and of itself "pleasing to God and requisite to Man," tend to be highly corrupt.


Return to Top
#2086077 - 06/30/16 01:40 PM Re: Community Development Investment(Grant) wblewis935
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
Examiners understand as well that, for the most part, families are reluctant to say "we cannot afford this for our children" unless they really cannot, especially things like Christmas gifts.

I have personally obtained credit for bank participation in such programs with organizations like Salvation Army around the year end holidays to provide gifts for families in need.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

Return to Top