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#2085340 - 06/27/16 03:48 PM Community Development Investment(Grant)
wblewis935 Offline
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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?

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CRA
#2085349 - 06/27/16 04:26 PM Re: Community Development Investment(Grant) wblewis935
Pale Rider Offline
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Based upon the facts as states in the post, my vote would be no, it is not a CD investment.
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#2085354 - 06/27/16 04:50 PM Re: Community Development Investment(Grant) wblewis935
wblewis935 Offline
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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?

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#2085376 - 06/27/16 05:38 PM Re: Community Development Investment(Grant) wblewis935
RR Jen Offline
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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.
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#2085389 - 06/27/16 06:19 PM Re: Community Development Investment(Grant) wblewis935
CompliantOkie Offline
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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.

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

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If in an LMI tract, I think this has a good chance of qualifying. It benefits the neighborhood residents and improves the area.
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#2085940 - 06/29/16 06:13 PM Re: Community Development Investment(Grant) wblewis935
wblewis935 Offline
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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?

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#2086009 - 06/29/16 09:01 PM Re: Community Development Investment(Grant) wblewis935
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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.
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#2086077 - 06/30/16 01:40 PM Re: Community Development Investment(Grant) wblewis935
Kathleen O. Blanchard Offline

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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.
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Kathleen O. Blanchard, CRCM "Kaybee"
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