Has anybody had clarity from the regulators on 'social services' as they relate to community development? Our regulators do not want to consider some of our CD activity because we wanted to categorize some items as a social service. Thoughts?

.12(h) & 563e.12(g)–1: Are
community development activities
limited to those that promote economic
development?
A1. No. Although the definition of
‘‘community development’’ includes
activities that promote economic
development by financing small
businesses or farms, the rule does not
limit community development loans
and services and qualified investments
to those activities. Community
development also includes communityor
tribal-based child care, educational,
health, or social services targeted to
low- or moderate-income persons,
affordable housing for low- or moderateincome
individuals, and activities that
revitalize or stabilize low- or moderateincome
areas

for quite a while now the definition of CD services has been funneling down to the provision of financial edcuation or services - services that related to our skills and knowledge as bankers

This is more than the definition of the service, this is the definition of Community Development. The new Q&A specifies the limitations on the services, but how about on the limitations on the CD definition?

I know of no change in the definition of CD; the primary purpose of CD still encompasses the four main areas, one of which is community services targeted to LMI individuals

I can only speak from my experience and the OCC narrowed the CD definition way down when talking about investments. If the donation was to a social service then the money had to be designated for financial education and not for the general operations of the organization. Doesn't seem that is what the reg intended.

Do you have to term it a 'social service'.

It seems to me that you could just call it a service that benefits LMI and go around the whole social service aspect. If they are hung up on the term perhaps you could call it something else to avoid the whole issue.

Seems to me anyway FWIW.