I'm sorry Rie, but your examiner is on crack. Donations of money and food to a local food bank are not even questionable...they're EASY SLAM DUNK CRA donations. They are CRA CD Investments, not Services, and are not limited to providing financial services to the individuals or area. Honestly, what a bunch of goober. I wouldn't accept it, but then again, 99.9% of the examiners out there would never have questioned the donation. I would have fought that one.
Martha, short answer is "Yes" but there are other services that are provided in a LMI community which would also be considered. Let me give you a few of mine and see what you think:
Donation to the opera. Tickets will be provided, as well as transportation to Title 1 schools in the community so students can attend the opening of the 2005 season. Donation was $5M and is CRA CD.
Donation to a Economic Dev Council to provide counseling to small businesses in rural Alaska, definately CRA CD.
Donation to a non-profit that fly's accountants to rural communities to provide tax prep work to LMI residents. CRA CD
Donation to the food bank
Always CRA CD
Donation to the YMCA to renovate their swimming pool. YMCA is in a LMI community and Renissance Zone...CRA CD.
Donation to a non-profit traveling the arctic to teach snowmachine safety in rural villages. Again, CRA CD (the rural areas are mostly LMI).
Donation to a title 1 school to cover a field trip to see a dinasour named Sue
. CRA CD.
So, "services" can be anything that benefits and improves the lifes of LMI residents or business growth. IF we're talking donations, they can be vast in their nature, but must provide services primarily to LMI folks. If we're talking Services (CD Services the bank claims credit for) then we're more defined, leaning on the provision of "Financial Services" to LMI folks.