A donation was made to purchase equipment (i.e. - vests, taser, etc.) for a police department serving a city in which all census tracts are considered distressed and underserved.

Would such a donation be considered "CRA related"? Or does the underserved/distressed geographies only come into play in the lending test?

Don't tas me bro!

Just kidding, lol. I am curious to hear the others' answers to this as well.

Our examiners told us that it still has to benefit LMI's in these underserved/distressed tracks to be CRA

So, you might could spin it somehow but I don't really see it???

Any other thoughts?

are these tracts and the city in the list of rural underserved?

No. Middle-Income Nonmetropolitan Distressed or Underserved Geographies.

bummer, you should present it as additional information at exam time, but don't expect much since it is middle income

Pale Rider,

Where can I obtain the list of "rural underserved" geographies?

Have you gotten the "Don't Taze Me Bro!" bumper sticker from billoreilly.com? Good for a laugh

LOL, not yet, but I did hear the "Don't Taze Me Bro" song, lolol.

PR, they don't have to be rural. If they have been designated as distressed then they can qualify depending one what the loan/investment/service is.

Riz, this won't be LMI because they are middle income, that was the purpose of the change in definition. However, the activity must still be CD.

There can be things to benefit low to moderate income individuals even though the non profit or whatever is in a middle income census tract...If I donate to ABC that is located in an upper income census tract but ABC's business is assisting low to moderate income familiess or individuals then I'm getting credit for it
And if its a middle income census tract thats also distressed or underserved and what I'm donating to is to benefit low to moderate income individuals, I'm getting credit for that too

That's what I meant...I guess I should have been more clear...

Now I am confused.

A donation for bulletproof vests for police who serve in an area of MI Distressed and Underserved Geographies would not receive CRA Investment credit because the donation is not earmarked to: construct or repair house; offer community services; or economic development or redevelopment. Correct?

What if I changed the scenario to a donation to a hospital and the donation is earmarked for mobile health center. The hospital is located in the Moderate Income Distressed and Underserved Geographies and the mobile health center would be traveling in the same geographies. CRA Investment Credit or No?

Thanks.

Rizzo, Gotcha.

Tennismom, You may be able to make a case for it because it is for safety in an area that possibly cannot afford to pay for the items. We would present it as "you can build all the houses and get all the jobs, but if the people don't have police protection then they are not going to live or work there". It is worth a shot. (so to speak)

For the second one, I am not sure there is a such thing as a moderate income distressed or underserved geography. There are middle income distressed or underserved geographies. The reason the category was establishes is that there are middle income census tracts that didn't qualify for CRA CD credit but were distressed and underserved. So a category was created to allow banks to take credit for serving these areas.

I hope that makes it clear.

As far as the hospital, if it is in a moderate income CT and serving mostly LMI people then it would probably count. If it was in a Middle Income Distressed and Underserved Geog. then it would probably count too.

My bad.

In all scenarios presented it should have said "Middle Income Distressed and Underserved Geographies".

Thanks

Don't frown, Tennismom!!! There's a 3 day weekend on the horizon!!!

Only wish that weekend was starting right now.