We have partnered with many non-profits to complete services with/for the Bank. In process of an examination and I have a couple questions.

1- In events that we partnered with, the examiner is asking how many of our employees used their expertise during the service. Lets say we had 7 employees present, they want to know how many of the 7 completed a presentation. We may have 2 there presenting but the others are there for questions if need be. That should suffice right?

2- In another service we partnered with a non-profit that conducts financial classes to your children in schools as part of their curriculum. As it is part of their curriculum the teaches conduct the classes. The materials are in the Bank's name. They are advising we cannot collect services as it is not our employees doing the presentation. Besides § __.12(i) – 2 I do not know where it states that the employee needs to do the presentation. The question I referenced seems to indicate to me that the Board member or whoever must be representing the Bank when volunteering.

Let me know your thoughts.

1. The credit given will vary by the agency acting as your primary federal regulator and may also vary by examiner. Our examiners currently would only give us credit for two services (per your example) and only if there were at least 5 clients in attendance per presenter.

2. In this example, your employees did not perform any service. I also would question what did the non profit do at these presentations? You should be able to get some recognition since the curriculum is in the bank's name. Did the bank pay for the creation of the curriculum? Might get you some investment credit.

Just my two cents.....

Thank you. The examiner said if we purchased a program already we would not get service credit. If we were a part in creating the curriculum we would. I am digging into that now. Thanks again.

In example 2 you might not get service credit unless you taught the teacher how to use it or did some other activity. However you can ask for CD credit for the cost of the purchase of the materials since it sounds like you then donated them to the school. But you also have to prove the kids were LMI. You can usually do this by looking at the number of free/reduced lunches.

Thank you Lori01.

I actually have one more question.

The examiner is asking for evidence that a majority of the participants were LMI or receive medicaid and such. This is for our elder abuse events we held at various places. Anyone have an idea how we can verify this information. The locations are in areas from the few I looked at. Shouldn't that be sufficient? If not how would you go verifying this information?

Were these events at assisted living centers? The management at the center would know the % receiving government assistance. Are the centers in LMI census tracts?

Adult Daycare. We reached to to a few to no avail but did clear most. Thanks