How do you distinguish a particular product or service for CRA Purposes? Is it because it has the lowest service charge, or special features or we just say this account is for low income people?

You can get credit under the service test for flexible and innovative products. You will not have income info on checking products so there is no way to test how L-T-M income customers are using the products, so you must sell the product to examiners as one that L-T-M income people benefit from. The product must have features different from the usual checking products.

This thread may have given me something else to add to my list of CRA services. A year ago, I created a new checking account that is free and has benefits with the one condition of direct deposit. Included in the definition of Direct Deposit is alimony, child support, or unemployment compensation. You think that will score points for CRA?? Dawnie?? Anyone?? Buehler???

Theory and perhaps even common sense may indicate the Low Mod benefit is valid, but you are going to have to prove it.

Unless you want to try and screen every account holder as to income classification, I don't think the examiners will buy it.

Sorry, but my experience would lead me to believe that, even if an examiner approved such a product as CRA "innovative and flexible", and listed it in your public disclosure, you're not really going to get much mileage from it. It's not going to raise you from low to high.

From my perspective, if you really want to tie a checking account product into CRA, then you can set up a low-cost account (or even free for say the first year or two) that is offered IN CONJUNCTION WITH a consumer who completes the FDIC Money Smart eduction program also (conveniently) sponsored by your bank in conjunction with local community orgranizations.

Even if the FDIC is not your CRA exam agency, if that arrangement doesn't receive some sort of kudos for CRA Service, then the FDIC would have some 'splaning to do.

Take a look at all of the FDIC press releases for the Money Smart program:

Money Smart Press Releases

I was on vacation Dave...missed your post.

You can receive credit for deposit programs that are targeted to Low and Moderate income people...or areas. But as Bonnie and Don mentioned, you've got to draw the connection for the examiners. Low cost accounts, with minimal balance requirements are a good example. So are ETA accounts. These are specific to government benefits and the Treasury can help you track the type of benefits being deposited in your bank.

I have a couple of products I take credit for. One is the ETA account, and the other is a First Account. First Accounts are a specific Treasury designation, with very specific rules to the accounts. Because of their structure you can take them as CRA services. I further only offer this account in Non-AA areas of the state that are low income, unbanked native villages. And yes...they're OUTSIDE of my assessment area, but I still get credit. Go figure

If you offer any products to population bases that might be low or moderate income...lets say in a high latino area of town that you can document as being lower income, with a targeted effort to that market...take credit for it! If you're offering jumbo CD's with 1% over standard earnings...don't mention it

I also take credit for my bank by mail services. I can document that 60% of the envelopes come from zip codes that are rural and low income so...I got the credit. We also pay the postage on those puppies

The above services did boost my service rating from high sat to outstanding. Each test has a score given to it. You could see your services score be just the ticket to bring the entire exam up to the O rating...you never know...so document the efforts, just in case!