Pure donation vs. those with advertising benefit

Occasionally my bank (ISB) sponsors community events or organization fundraisers targeting LMI persons or federally designated distressed census tracts (non-MSA). Often the donation has an advertising benefit such as the bank's name on the event program, mention in the event advertising, or tickets to the event fundraising dinner. I've posed questions to our regulator about whether we will receive CRA credit for these activities, but didn't get much of an answer due to the subjective element. What are other banks experiencing out of their recent exams?

You should find out how much of your donation is actually going to benefit the organization and document that. You need details like "x dollars covered the cost of the dinner while x dollars went to the program benefiting the organization's clients".

Being mentioned in the advertising does not disqualify the qualification.

Despite the fact that there is nothing in the reg that says that your donation is disqualified if you receive advertising from it, our examiner will not count it if anything in what we give him says we received advertising (name on shirts, banner, ad in program, etc.). I think we have a particularly tough examiner.

Work with your nonprofit to support a program, then tell them if they want to provide your local leadership with a table at an annual event or recognize your bank in some way that would be fine, but you financial support is for the program only.

Don't get two invoices, one for the programmatic support and one for the event sponsorship. And ask that the invioce only reference the progromamatic support, not the event.

Yes, what I usually do is just request a letter from the organization stating that they will be using all our funds for direct services. Or we send a letter that requests that they only use our funds for direct services.