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#2099351 - 09/20/16 02:35 PM Employees Serving on Boards - How to take credit
Norman Paperman Offline
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Norman Paperman
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48.934476, -114.343735
We have a number of employees serving on boards of good CD organizations. They are using their respective technical knowledge to assist these organizations, but most have been members of these boards since before their time with this institution.

What is the best way for the bank to receive credit for the good work that our employees are doing. Can it be as simple as allowing those employees time away from work (paid) to assist the boards and including that statement in our documentation?

Thank you.
_________________________
Maybe you just wanna fly the plane yourself. Well good luck pressing take off, then auto pilot, then land.


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#2099371 - 09/20/16 03:34 PM Re: Employees Serving on Boards - How to take credit Norman Paperman
Darth HMDA, CRCM, CAMS Offline
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CA
Basically, yes. Track hours, get a statement on what assistance they are providing, and information on the organization. The more documentation the better - demonstrate the organizations have a clear CD purpose.
_________________________
The opinions expressed are mine, do not represent the opinions of my employer, and they are not to be taken as legal advice.

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#2099417 - 09/20/16 04:41 PM Re: Employees Serving on Boards - How to take credit Norman Paperman
Tennismom Offline
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Tennismom
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From the Q and A https://www.gpo.gov/fdsys/pkg/FR-2016-07-25/pdf/2016-16693.pdf


§ll.24(e)—2: In evaluating community development services, what quantitative and qualitative factors do examiners review?
A2. The community development services criteria are important factors in the evaluation of a large institution’s service test performance. According to the regulation, the Agencies evaluate the extent to which the financial institution provides community development services as well as the innovativeness and responsiveness of such services. Examiners consider both quantitative and qualitative aspects of community development services during the evaluation. Examiners assess quantitative factors to determine the extent to which community development services are offered and used. The review is not limited to a single quantitative factor. For example, quantitative factors may include the number of
• low- or moderate-income participants;
• organizations served;
• sessions sponsored; or
• financial institution staff hours devoted.

Examiners will also consider qualitative factors by assessing the degree to which community development services are innovative or responsive to community needs.

See Q&As §ll.21(a)—4 and §ll.21(a)—
3. These performance criteria recognize that community development services sometimes require special expertise and effort on the part of the institution and provide benefit to the community that would not otherwise be possible. Such an assessment will depend on the impact of a particular activity on community needs and the benefits received by a community. See Q&A §ll.28(b)—1. For example, a financial institution employee’s unique expertise and service on the board of a community organization may demonstrate these qualitative factors when the employee’s ongoing engagement significantly improves the products, services or operations of the community development organization.

Examiners will consider any relevant information provided by the institution and from third parties that documents the extent, innovativeness, and responsiveness of community development services.

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#2099455 - 09/20/16 06:10 PM Re: Employees Serving on Boards - How to take credit Norman Paperman
Kathleen O. Blanchard Offline

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Be very careful with situations where employees serve on Boards on their own, such as how you describe. The Q & A also states:

"§ ll.12(i)—2: Are personal charitable activities provided by an institution’s employees or directors outside the ordinary course of their
employment considered community development services?

A2. No. Services must be provided as a representative of the institution. For example, if a financial institution’s director, on her own time and not as a representative of the institution, volunteers one evening a week at a local community development corporation’s
financial counseling program, the institution may not consider this activity a community development service. "

There are cases where such services were discounted because the services were not provided as a representive of the bank. So, it is not just a matter of getting a list of what everyone is doing. Take a look at the most valuable services and have the bank get involved and designate that employee as the bank's contact with that organization, reporting back to the bank on activities within the organization, identifying other ways the bank could assist the organization, etc.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#2099506 - 09/20/16 07:32 PM Re: Employees Serving on Boards - How to take credit Kathleen O. Blanchard
Norman Paperman Offline
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Norman Paperman
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48.934476, -114.343735
Originally Posted By Kathleen B


There are cases where such services were discounted because the services were not provided as a representive of the bank. So, it is not just a matter of getting a list of what everyone is doing. Take a look at the most valuable services and have the bank get involved and designate that employee as the bank's contact with that organization, reporting back to the bank on activities within the organization, identifying other ways the bank could assist the organization, etc.


This is where I was going. So it's not enough to simply tell these employees, "feel free to do this on bank time". We need to get behind these organizations as well.
_________________________
Maybe you just wanna fly the plane yourself. Well good luck pressing take off, then auto pilot, then land.


CRCM

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#2099515 - 09/20/16 07:45 PM Re: Employees Serving on Boards - How to take credit Norman Paperman
Pale Rider Offline
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We have the volunteer positively state they are serving as a rep of the bank and not volunteering on a personal basis.
_________________________
Societies that do not find work in and of itself "pleasing to God and requisite to Man," tend to be highly corrupt.


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#2099535 - 09/20/16 08:11 PM Re: Employees Serving on Boards - How to take credit Norman Paperman
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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It is much safer to be able to demonstrate a link with the bank. That is why I say for the ones that are most important to your rating; you don't necessarily need to do that with every organization listed. Put your effort where the most value is, and the most opportunity.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#2099577 - 09/20/16 09:41 PM Re: Employees Serving on Boards - How to take credit Norman Paperman
CompliantOkie Online
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OOOOOOklahoma
Agree with Kathleen. We'll show a link by doing a donation to the organization along with the employee stating that they are representing the bank while serving on the Board. If we have a service and donation or loan to the same org we highlight that we're involved in more than 1 way.

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#2100026 - 09/22/16 08:11 PM Re: Employees Serving on Boards - How to take credit Norman Paperman
Ryan Yager Offline
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Joined: Apr 2014
Posts: 21
IL
Is there anywhere to find good examples of what other banks have provided during exams and best ways to present the information?

For example. Our bank sponsors a bowling night for a CD qualified organization. To participate employees must collect donations. Let's say we have 30 employees each collecting donations to the CD organization. According to the Q&A providing technical assistance to a CD organization can include, "Assisting in fundraising, including soliciting or arranging investments.". So do I report this as 30 employees each providing a CD service, for a total of 30 services?

Usually, I report someone who serves on a board as just 1 service for the year. But what if someone isn't on a board and this employee participates in 5 fundraising events throughout the year for this CD organization. Is that 1 service or 5 services?

A competitor of ours that is the same size bank was credited with 20 times the number of services of use and I don't know how they did it.

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#2100074 - 09/23/16 01:15 PM Re: Employees Serving on Boards - How to take credit Norman Paperman
Pale Rider Offline
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under the Lone Star
My guess is that internal forms and reporting systems are going to be proprietary and not shared.

Reporting 30 services for one event with multiple volunteers is hyper aggressive in my opinion. It is a one-off event and should only be reported that way. You could report the number of employees, the number of hours served in raising donations, the amount raised by the employees, but I would not be comfortable reporting 30 services.

In the same way, I am not comfortable in reporting the different activities a board member engages as separate CD services. (S) He is a board member and most likely is expected to engage in various activities. Ongoing CD services like being on a board or committee is considered by many examiners as a higher quality CD service than one-off services like financial education or fundraising activities. So think quality as well as quantity.

Again, this is all personal opinion.
_________________________
Societies that do not find work in and of itself "pleasing to God and requisite to Man," tend to be highly corrupt.


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