Qualifying Donation?

We have a group that we donate to that their main focus is helping those with intellectual disabilities. Normally this would not qualify, however, we were also provided a letter stating that 92% of their clients are considered low to moderate income and are either on or eligible for Medicaid/state assistance. So, in my opinion I would think all donations would then qualify correct?

So if yes for normal donations what about a donation of chairs etc. valued at a certain dollar amount? I threw it out but am getting a lot of push from others that I should include? Thoughts?

The donation should qualify with the letter that the majority of clients are LMI. Not sure about the inkind donation of used furniture, unless you can get an independent valuation. Hopefully, others that have done this will respond.

Historically we have donated to Habitat for Humanity (office furniture) and they gave us a receipt that was used for tax purposes and the examiners have been ok with it for CRA.

In reference to donations, if we feed homeless persons at a homeless shelter would this be considered In-kind donation?

Do you mean helping to serve lunch or dinner by volunteering - serving food or washing dishes, that sort of thing?

If so, then no, that is not a donation.

I have a situation that I'm curious to see if anyone else has been in before.

A town in our AA recently was awarded a grant from the state from CDBG funds. It was a revitalization grant. Now the town's Main Street organization (it's worth noting that in order to receive the grant from the state, the awarded town had to have an active Main Street organization) wants to raise more funds for other projects for the town. The grant funds and subsequent funds raise from Main Street will be used to reface buildings, repair roads and sidewalks, replace light fixtures, etc. Here is the kicker; the town is located in a poverty distressed middle income census tract.

The Main Street organization has come to the bank requesting funds for their projects. I am trying to determine if the bank could receive CRA credit for this kind of donation. There is no SPECIFIC purpose of the funds to be used for low- to moderate-income people. The only justifications are; (1) the grant was awarded by the state through use of CDBG funds from HUD, (2) the town is located in a poverty distressed middle income census tract. The other issue I am having trouble working through is that the main street organization is a separate entity from the town that received the grant, though they want to use the awarding of the grant as incentive to raise more funds for the town's various projects.

Wow, that was a lot.... I am just curious if anyone has any thoughts on the qualification of this kind of donation. Has anyone submitted something similar and received a positive response from the regulators? FYI, we are FRB regulated.

Thank you so much for any input you all have!!

Sounds llike revitalize/stabilize to me, I have Main Street partners for which both contributions and services qualified for CRA.

The contributions made to these Main Street partners; were they similar to the one I am looking at, or did they have a more defined purpose to serve LMI?

To get more comfortable with the project, why not add language that would address LMI needs as part of the contribution. If they want the funds, they should be willing to do this. The distressed middle income tract designation should be your ace in the whole.