Thread Options Tools
#65006 - 03/03/03 10:32 PM CRA Credit
Anonymous
Unregistered

Would we be able to claim any CRA credit when we send employees to participate in training sessions relating to CRA activities or programs? For example, we sent some of our lenders to an affordable housing lending class. Could we get service credit and investment credit (if there is a cost involved with the session)?

Return to Top
General Discussion
#65007 - 03/03/03 10:49 PM Re: CRA Credit
RebekahL CRCM Offline
Platinum Poster
RebekahL CRCM
Joined: Feb 2003
Posts: 766
Big Sky Country
I'm curious to see what replies are made also. My bank received service credit for sending representatives from community groups to a Federal Home Loan Bank grant and loan workshop, but it would be interesting to see if any banks have gotten credit for sending their own employees.
_________________________
Me, Type A? Maybe - I'm not done analyzing it yet.

Return to Top
#65008 - 03/03/03 10:51 PM Re: CRA Credit
HRH Dawnie Offline
Power Poster
HRH Dawnie
Joined: Aug 2002
Posts: 7,353
Anchorage Alaska
Yes this is something you can receive credit for. In the Bankers Tools Section of BOL I have a worksheet to use for CRA CD Services (I know there are several good ones out there so check them all out) that walks you through qualifying and documenting these services. Be sure to note who went, what was discussed (ie affordable housing) etc. Pulling information on the entity putting the program on from the web or their docs is also good back up for your submisssioin to the examiners.

As to investment credit, I've never tried to take my expenses as an investment. Some of these costs would be typical costs of doing business (ie parking etc.) and calling it an investment could be a stretch. But heck, if anyone has ever made it work, let me know

What I normally do instead is donate some money to the entity for the program. The straight donation I take as a CD investment.
_________________________
Dawn Coursey VP/CRA Queen

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

Return to Top
#65009 - 03/03/03 10:53 PM Re: CRA Credit
HRH Dawnie Offline
Power Poster
HRH Dawnie
Joined: Aug 2002
Posts: 7,353
Anchorage Alaska
Rebekah...you received credit for sending other entities to the workshop as service credit? Now that expense I'd call a donation to their entity and take as an investment, not service credit. You really didn't "service" anyone...you just footed the bill.

When your employees go it's 100% CD credit. I rack up hours and hours of this stuff every year with no questions asked by examiners.
_________________________
Dawn Coursey VP/CRA Queen

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

Return to Top
#65010 - 03/03/03 11:01 PM Re: CRA Credit
RebekahL CRCM Offline
Platinum Poster
RebekahL CRCM
Joined: Feb 2003
Posts: 766
Big Sky Country
Dawnie-

Small wonder - you are more up to speed on CD services and investments than the FDIC examiner that gave us the service credit! Oh well, I shouldn't fuss TOO much, I suppose - at least we got credit, even if it was in the wrong category!

That was 4 years ago... I'll be ready to drop a hint when the next one rolls around, whenever that is!

Thanks!
_________________________
Me, Type A? Maybe - I'm not done analyzing it yet.

Return to Top
#65011 - 03/03/03 11:09 PM Re: CRA Credit
HRH Dawnie Offline
Power Poster
HRH Dawnie
Joined: Aug 2002
Posts: 7,353
Anchorage Alaska
Heh Heh, I promise in my next career as an examiner (when they open a field office in Alaska) I'll be nicer than your guy I'll give ya both! Heck if you front your employees the cash to attend we'll make it a CD loan
_________________________
Dawn Coursey VP/CRA Queen

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

Return to Top
#65012 - 03/03/03 11:36 PM Re: CRA Credit
AnonRegulator Offline
Gold Star
AnonRegulator
Joined: Mar 2002
Posts: 451
Everywhere, USA
I hate to be the wet blanket here, but attending training like this is not something for which you should receive CRA credit. If you can badger your examiner into giving such credit, more power to you, but the activities don't fall within the definitions of things that garner investment and services credit.

By attending the training, what service did you provide to people? You may have increased your capacity to provide services, but until those services are provided, there is nothing to credit.

As for investment credit, a qualified investment must meet one of the four components of the community development definition. While your officers may be attending a seminar on affordable housing, their attendance does not provide affordable housing to LMI people, per se. Their expertise after the training may lead to loans or investments that provide affordable housing to LMI people, which would then garner you CRA credit.

As for the cost of the training, I doubt that the money went directly to provide affordable housing or community services to LMI people, economic revitalization or small business/farm lending. So the cost of the training is not a qualified investment either.

Sorry, folks. AR.

Return to Top
#65013 - 03/03/03 11:51 PM Re: CRA Credit
RebekahL CRCM Offline
Platinum Poster
RebekahL CRCM
Joined: Feb 2003
Posts: 766
Big Sky Country
Phooey, so much for the blissful ignorance defense! Wait, when I took this job I abdicated the use of that defense forever and for all time, didn't I?

Seriously though - thanks, Anon Regulator, for the reply. I'd much rather hear it here than later during an exam! I guess Dawnie is just a lucky cuss, very charming, or both!

At any rate, I appreciate the info, AR.
_________________________
Me, Type A? Maybe - I'm not done analyzing it yet.

Return to Top
#65014 - 03/04/03 12:44 AM Re: CRA Credit
HRH Dawnie Offline
Power Poster
HRH Dawnie
Joined: Aug 2002
Posts: 7,353
Anchorage Alaska
I'm going to have to agree to disagree (and suggest you submit it anyhoo).

Attending the training provides me with the ability to provide services I could not provide without this training. I back that up by providing special loan programs, the service or writing and managing grants etc. to low and moderate-income people and geographies.

I could spend my time in the office and stay in ignorance of these products and services, thereby leaving the population untapped. Attending these programs is entirely CD service. Sending community groups for the training provides the same service, allowing them to reach out and help the targeted populations.

Without participants in these training forums the providers of special loan programs or grant programs would be unable to serve the needs of affordable housing. Attending, then servicing the populations with the information you picked up in training, meets the CD definition in my book. I'd argue this one day and night.

Yes it's not an investment, (unless you fund the training program) but CD Service. I would never leave these off the table!

I suppose if you can't back up what you learned with what services you provide it might not fly, but we don't go to these seminars (normally) if we're not thinking about introducing the product or service, or want to enhance our ability to provide it.

OK that's my 20cents on the deal I'll step off my soap box and go back to writing up my CD service stuff.
_________________________
Dawn Coursey VP/CRA Queen

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

Return to Top
#65015 - 03/04/03 05:01 AM Re: CRA Credit
Princess Romeo Offline

Power Poster
Princess Romeo
Joined: Jun 2001
Posts: 8,272
Where the heart is
Speaking of Community Development Service, anyone in the Los Angeles area, please take a look at this webpage, and let me know if supporting this activity would be something your bank would consider:

Cowboys in the Hood

I am also thinking that after they rennovate community centers, perhaps we can find ways to start a Money Smart education program in those community centers and churches.
_________________________
CRCM,CAMS
Regulations are a poor substitute for ethics.
Just sayin'

Return to Top
#65016 - 03/04/03 06:18 PM Re: CRA Credit
AnonRegulator Offline
Gold Star
AnonRegulator
Joined: Mar 2002
Posts: 451
Everywhere, USA
Hmmm, is the switch to the new pic just coincidental? Or is the use of the menacing cat on purpose? A ploy to intimidate a federal gummint employee?

Anyway, you are correct, Dawnie, that the services you actually provide as a result of your attending the training count for CRA. You mentioned special loan programs, writing or managing grants, presumably targeted to LMI people or areas. Those are clearly activities that will garner CRA credit.

But, again, banker attendance at the training doesn't cut it. That would be like saying you want credit for your ability to lend to LMI people, without actually doing so. CRA is about performance and actual services, not about could haves.

You mentioned sending community groups to training. That changes the scenario of the original question. If a bank pays for LMI people to attend a seminar that teaches them how to qualify, buy or maintain their house, that is a service provided to LMI people. You should get credit for that, but it has nothing to do with bankers attending some lending training. It has only to do with the actual provision of services.

You said you would argue this day and night. I don't doubt that, but won't that be a bit difficult in the land of the midnight sun? AR.

Return to Top
#65017 - 03/05/03 07:22 AM Re: CRA Credit
HRH Dawnie Offline
Power Poster
HRH Dawnie
Joined: Aug 2002
Posts: 7,353
Anchorage Alaska
Heh Heh Anon, no the kittie was just a change. I'm in training with people who want me to give them millions of bucks this week and want out (btw...I'm taking CD Service credit for the training)

I can argue all night this winter (until at least May) then we switch to all day You'll have to give in to go to sleep within the next few months!

Really now though, I need to change your mind on this. Sit back and get ready for a Dawnie attack (it's really quite friendly and there is always chocolate involved).

Lets take for instance the provision of a loan to build affordable housing. Heck all I'm giving is a loan to someone who qualifies for a loan. I'll make some money on the darned thing til it pays off. I don't pick up a hammer, don't touch the paint...so really "I" am not building the affordable housing. I'm just making some money off of my loan. But...that would of course be a CD loan. Easy as pie.

Now, I learn how to write a grant to help that entity (who is paying me interest on my loan cuz I'm a big evil bank and I didn't give it for free) and they're able to build 4 more units because of my grant. If I didn't know how to write the grant, they wouldn't build the additional 4 units. Hence, in the training (at the same arms legnth of the loan) I provide affordable housing for 4 units at least...and perhaps more. If I don't know how to write the grant, and don't learn the value of providing this service...they stay in their relatives for the winter.

For the record, my regulators aren't easy on me. They made me prove every deal I presented, but I don't present goober peas. Attending these classes, which I don't need to attend to provide standard banking services, give me the tools I need to provide MORE affordable housing than would be provided if I didn't know about the program. If I wasn't getting CD credit for the service...I'd spend more time drinking good wine at the petro club with rich oil barrons. I can approve those housing deals all day long with little to no additional effort on my part. (But then you're not encouraging me to build more homes for oil barrons are you?)
_________________________
Dawn Coursey VP/CRA Queen

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

Return to Top
#65018 - 03/05/03 07:36 AM Re: CRA Credit
HRH Dawnie Offline
Power Poster
HRH Dawnie
Joined: Aug 2002
Posts: 7,353
Anchorage Alaska
Oh Bonnie...No cowboys in Alaska, but I'm funding a similar program here

I think they'd freeze to death in those denim shirts if they tried to work in the winter around my place
_________________________
Dawn Coursey VP/CRA Queen

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

Return to Top