CRA Services Credit?

Would you consider Treasurer of the Lions Club for CRA Services Credit?

Not if it is like the Lions Club in my location. They do not have a mission of serving primarily low-to-moderate income households or individuals.

The Lions Club here also does not keep the documentation necessary to prove the majority of their clients served are low-to-moderate income as well.

Agreed. I spend a lot of time explaining that everything a bank does that is good for the community is not necessarily qualified for CRA.

Unless there is a specific program run by a group like Lions that is targeted to low/mod and documented as such, their programs do not help for CRA. The bank can still participate of course, but it is not CRA.

If the Lions (or Rotary or Soroptomist, etc.) have a Holiday drive to provide food and/or gifts to needy families, you can get CRA credit if the officer is on that committee, especially if they coordinate the fundraising and/or budget for the project.

DOCUMENT, DOCUMENT, DOCUMENT!!!!

Don't forget this aspect of the regulation (From the Q and A):

"Services must be provided as a representative of the institution. For example, if a financial institution’s director, on her own time and not as a representative of the institution, volunteers one evening a week at a local community development corporation’s financial counseling program, the institution may not consider this activity a community development service".

Absolutely. This never used to come up but I have seen banks have services disregarded for this reason in recent years.

I'd like to resurrect this topic. If the employee was serving as Treasurer of the lion's club as a representative of the bank, and the median household income was < 80% of the MFI established by the FFIEC, could you then make a case that the organization provides basic community services (health related, primarily) to a LMI geography?

Whose median jousehold income?

The median family income for the community served by the Lion's Club.

What you are asking RUKM is a mathematical impossibility. The MFI for the community served is going to be 100% of the MFI for the MSA. Perhaps I am not understanding your scenario.

The MFI is the appropriate year's HUD estimated MSA/MD/non-MSA/MD MFI. So are you saying the Lion's Club does not serve the entire community? They have a program that targets a specific census tract that makes up a portion of the MSA?

In that case, this program would have to comprise a majority of all the work that the Lion's Club did.

Is the employee acting as Treasurer only for this specific program? Or is he the Treasurer for all the Lion's Club does?

the employee is treasurer for the club, not just a particular activity that the club participates in.

Then you are back to the question of whether the Lions Club serves a majority of LMI. Typically this is not in their charter or mission statement.

Just my opinion, but I don't see how you could get service credit since the Lion's Club serves all members of the community equally, and they don't attempt to collect income data of those they help.