We are an intermediate-small CRA bank regulated by the FDIC. Most of our community development investments historically have come from school bonds where the majority of students are low/moderate income. Does anyone know if a school bond that initially started with majority low/mod income students and received CRA credit at a previous exam will continue to get credit at future exams if the student population has since shifted to less than 50% low/mod income students? The trend in our assessment areas (and statewide) is that most schools are no longer considered primarily low/moderate income, so I am having a harder time finding qualified investments. Explaining that is going to be part of my performance context, but I am also trying to shoot for an actual dollar amount target based on peer bank performance.

We're an ISB regulated by the OCC so your exam may vary. But we have gotten credit for prior period investments for schools that qualified for CRA consideration at the time the investment was made. Remember though you only get "credit" for the amount of the bond outstanding at the time of the exam.

If at the time you made the decision the need was there, and subsequently, the need has been reduced, you SHOULD still get credit. However, as with all community development issues, your mileage may vary as this portion of the exam procedures is nothing but subjective.

We are still waiting to hear from the FDIC about how they intend to modernize CRA, but both other agencies have said that they understand that finding qualified investments is getting harder, and the idea of allowing banks to invest outside their assessment area(s), in CRA deserts is common to both the Fed proposal and the OCC "Final" rule.