For those of you that get the ABA Newsbytes, do any of you use this program ? If so, do any of you try to use them to get CRA credit?

The article to sign up was published with 1/16/19 newsbytes and they also sent a separate email in the afternoon for reference.

These programs are related to the provision of financial expertise that one would normally find at a bank. As long as the school has greater than 50% FRL participation, Title One School-wide program participation or located in an LMI geography you can qualify the activities as a CD Service. I have personally sat on a committee where we had taught upwards of 150k children during teach children to save--it's a powerful program.

How does LMI geography relate to CD services to LMI individuals? A school could be located in a LMI census tract, however the FRL participation could be < 50%.

Also, the Title One program participation and correlation to serving a majority of LMI has been debated often on BOL. A school can be designated Title One for reasons such as lack of performance of students, low attendance rates, low graduation or promotion rates, etc., none listed have to do with the income of the student body.

When determining if we will receive CD service credit for an activity at a school our examiners look for the percent of students that are eligible for free or reduced meals and not if the school is designated Title One?

As the Q&A states we are looking to help LMI individuals or geographies. After all, the basis of our philosophy is to not redline. For instance--the following statement doesn't stand to logic, "We are serving LMI geographies, but we don't serve schools located inside of the LMI geography that don't predominately educate LMI students." Why then can I go teach financial education at places of employment inside of LMI geographies without having to prove the wages earned by the recipients? I refer to this as micro redlining.

According to the CRA Q&A's under §.12(g)(2)—1: Community development includes community services targeted to low- or moderate-income individuals. What are examples of ways that an institution could determine that community services are offered to low- or moderate-income individuals?...The community service is conducted in a low- or moderate-income area and targeted to the residents of the area.

Title-one School-wide status works for CRA because the school itself is failing. According to the Code of Federal Regulations Title 34, Subtitle B, Chapter 2, Part 200, Subpart A, §200.25, "The school serves a school attendance area in which not less than 40 percent of the children are from low-income families; or not less than 40 percent of the children enrolled in the school are from low-income families." From a CRA perspective this means out of the total population in a school attendance area 40% of the students come from families earning less than 50% of the AMFI. It is reasonable to assume that if 40% of the students are low-income that at least 10% of the students come from moderate-income families.

Not only that--what Title-one School-wide indicates is that the school itself is failing the students. Students from such situations are considered at-risk-students or sometimes referred to as at-risk-youth. According to the Department of Health and Human Services at-risk-students are those who are less than likely to achieve economic self-sufficiency. Our support of students in Title-one environments only helps further prevent these students from falling behind the curve in the future. While a student body may only have 30-40% FRL rates that doesn't mean that students are being set up to economically succeed in the future. For instance, a school such as Crook County High School has a 46.83 FRL rate, is not Title-one, but only has a 48% graduation rate. Could we also argue that 52% of those students be at an economic disadvantage? Did we inadvertently redline a group of people because we inadequately identify what works, and doesn't work for CRA?

Another interesting trend in schools is people foregoing FRL or the school itself refusing assistance from Title-one because of the stigma that comes with those titles. So further, are FRL rates even a true measure of how many people are LMI?

Your examiners should be looking at whether or not a school has title-one status or not because the school is the recipient of federal and/or state grants specifically targeted to low-income people, to both help the low-income student body, but also other income-level students from slipping behind economically. We should also be aware of activities that prevent people from becoming economically disadvantaged in conjunction with bolstering up those who already are. For instance, banks are currently offering 0% interest loans to people who are affected by the government shutdown.