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#2252155 - 04/10/21 06:02 PM LMI location - not enough?
mgs41 Offline
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Joined: Jan 2007
Posts: 167
My onsite CRA examiner has indicated that activities submitted as Community Service must be targeted to LMI Individuals with documentation to show it, and the location of the activity is not applicable. For example, we donated funds to a library located in a moderate income census tract. In my mind the people using the library are from the area around the library, and therefore LMI individuals are receiving the services.

Grey area here, or am I being to liberal with my interpretation of the Q&A?

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#2252221 - 04/12/21 05:39 PM Re: LMI location - not enough? mgs41
John Burnett Offline
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John Burnett
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Posts: 40,086
Cape Cod
Documentation of the persons targeted by a service needs to be a little more concrete than "in ones mind." As subjective as the art of CRA evaluation is, it would probably be better to have form of tangible documentation from the library -- in this case -- that its primary clientele are LMI individuals.
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#2252242 - 04/12/21 07:40 PM Re: LMI location - not enough? mgs41
CompliantOkie Offline
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CompliantOkie
Joined: Dec 2013
Posts: 425
OOOOOOklahoma
Look for articles/studies that LMI individuals disproportionately utilize libraries. There's a report from the bureau from 2016 that'll help you.

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#2252245 - 04/12/21 07:45 PM Re: LMI location - not enough? mgs41
Len S Offline
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Joined: Oct 2004
Posts: 2,084
Connecticut
There's another angle to this. If you categorize the service by the library as attracting people or businesses to a low- or moderate-income tract or underserved/distressed tract, then you don't need to prove that the majority of beneficiaries are LMI persons (which is required for affordable housing, community services and economic development, but not for revitalization/stabilization). I would think a library would qualify as offering a service that does attract people (regardless of income class) to an economically depressed area.
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#2252265 - 04/12/21 10:03 PM Re: LMI location - not enough? mgs41
TMatt87 Offline
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TMatt87
Joined: May 2011
Posts: 1,984
Idaho
For our library donations, we highlight programs most libraries offer that are directed towards low income individuals; free afterschool programs for children (assuming nearby schools are >50% FRL), free access to computers for unemployed to submit job applications, etc. Always seems to work for us.
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