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#380379 - 07/02/05 05:36 PM Community Services - Critical Needs?
Martha Z Offline
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Joined: Mar 2005
Posts: 9
In Reg BB, one of the definitions of Community Development is "Community services targeted to low- or moderate-income individuals." Are "community services" those which meet the critical needs of the community such as food, clothing, shelter, and medical services?

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CRA
#380380 - 07/05/05 01:54 PM Re: Community Services - Critical Needs?
Rie A Offline
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Rie A
Joined: Mar 2004
Posts: 829
Maryland
That can be one of the many grey areas.

We are an FDIC bank and during our last exam we were told that donations of money or food to the local food bank would not count. I quote “It would be like giving candy to a child. Yes you made them happy today, but how did you help them financially or with housing?”

But, I have read in other FDIC bank's PEs where they received credit for food and medical services.
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#380381 - 07/06/05 08:10 PM Re: Community Services - Critical Needs?
HRH Dawnie Offline
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HRH Dawnie
Joined: Aug 2002
Posts: 7,353
Anchorage Alaska
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.
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#380382 - 07/07/05 12:05 AM Re: Community Services - Critical Needs?
CRAatBOK Offline

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Joined: Mar 2004
Posts: 6,172
Further South than I wanna be.
One caution on donating food to a food bank. It has to be the bank making the donation, not the employees. If employees or customers bring in food, which the bank collects and delivers to the food bank, it will not count. If the bank itself pays for the food and donates it, then it counts. Usually the later doen't happen. Banks will more likely give the food bank money and not raw materials.
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#380383 - 07/07/05 06:11 AM Re: Community Services - Critical Needs?
Princess Romeo Offline

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Princess Romeo
Joined: Jun 2001
Posts: 8,272
Where the heart is
For those who attended the ABA Compliance Conference and listened to Bill Fox talk about "Defensive SARS", perhaps the reason the employee stole bacon from the bank's cafeteria was to give it to the local food bank?
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#380384 - 07/07/05 05:41 PM Re: Community Services - Critical Needs?
Martha Z Offline
New Poster
Joined: Mar 2005
Posts: 9
Thank you, everyone, for your responses! I greatly appreciate your assistance! And thank you, Dawnie, for your FANTASTIC suggestions! (P.S. I LOVE your cat face - it looks like my little kitty.)

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#380385 - 07/07/05 05:54 PM Re: Community Services - Critical Needs?
HRH Dawnie Offline
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HRH Dawnie
Joined: Aug 2002
Posts: 7,353
Anchorage Alaska
KC brings up a good point. There are silly banks out there that try to take credit for the items or money their EMPLOYEES donate Any time you have a donation of an item or of money it must flow directly from the coffers of the bank! My favorite was a bank trying to take credit for both their United Way donation, AND their employees paycheck draws to United Way. Dorks

My kitty says "Meow (or HI)" to your kitty Martha

Oh and KC, I actually have donated food to the food bank several times We have one entity that handles their money a bit sloppy, but the guy running it has such a good heart and his cause is so great that we prefer to buy food instead of giving cash. We also donate quilts which I and a few gals here make which charities can sell for more money than we would have donated to them most likely. They're very popular. Then there's the annual "peach" drive here in town, where a title one school buys peaches and sells them by the crate to raise money for coats for LMI children. We buy a truck load and take it down to the food bank to distribute. So we benefit the school AND the food bank For the peach drive and the quilts we get "innovative and unique" credit, even though they're relatively small donations.
Last edited by Dawnie; 07/07/05 05:59 PM.
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Dawn Coursey VP/CRA Queen

CRA Rating is in...Oh who cares...I'm home with the baby.

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