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#2227332 - 12/13/19 02:12 PM Jointly-Made CD Donations (w/ Non-Bank Subsidiary)
Nate Offline
New Poster
Joined: May 2019
Posts: 1
Hi all!

Big fan of the forum, been a lurker for some time! With all the long-term pros that are in here, it's a bit daunting to ask!

Our institution falls under a Large Bank classification, and we have several subsidiaries under our parent corporation's umbrella. (Including a financial advisor and an insurance agency.)

For bigger donations, they're occasionally done jointly by one of our banks + <insert non-bank subsidiary here>. Would a donation made this way be entirely claimable? (Example: Bank + Insurance Agency split a donation to a qualified CD-based organization or earmarked for LMI uses.)

Do these funds qualify for CD credit in total, or only the portion by the bank? Does anyone have any insight for me?

Thanks a lot for your help,


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#2227408 - 12/13/19 10:06 PM Re: Jointly-Made CD Donations (w/ Non-Bank Subsidiary) Nate
TomS Offline
Gold Star
Joined: Jan 2004
Posts: 315
IMO you would only get credit for the portion paid by the bank. I can't see an examiner giving the bank credit for funds donated by another entity, affiliated or not.

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