I recall when Katrina hit New Orleans the bank made a contribution towards the relief fund and the examiners gave our bank investment credit even though it was outside our AA and outside a statewide or regional area.
This is from an OCC Bulletin from 2006 and the FDIC followed their lead: [/i] "...However, due to the unprecedented impact from hurricanes Katrina and Rita, examiners have been given additional flexibility when evaluating the geographic aspect of CRA-related activities in these designated disaster areas. Therefore, national banks located outside the designated disaster areas may receive positive CRA consideration for activities that revitalize or stabilize the designated disaster areas related to hurricanes Katrina and Rita, provided that the banks have otherwise adequately met the CRA-related needs of their local communities." [i]
There was a Joint Release issued last week: Statement on Supervisory Practices Regarding Financial Institutions and Borrowers Affected by Hurricane Harvey, however it speaks specifically of CRA consideration for community development loans, investments, or services that revitalize or stabilize federally designated disaster areas in their assessment areas or in the states or regions that include their assessment areas
Maybe they will reconsider.