Most of our schools are Title 1 schools - so I know they automatically qualify.

Some are not Title 1 - but the majority of their students (over 50%) are on the free lunch program - does that mean they qualify as well?

First, don't rely on the term "Title One". Title One schools many times have less than 51% of students eligible for the FRL. I have seen some schools with less than 40% that otherwise are designated Title One. My examiners only look to whether a majority of the students are eligible for the FRL program.

Second, FRL is not always an acceptable proxy for the bank regulatory term "low and moderate income". There are a number of MSAs across the country in which the FRL dollar thresshold is higher than 80% of the median family income number for that same MSA. When that occurs my examiners will not accept the FRL percentage as the equivalent of LMI.

Based on your question you can see that Title One is not a good proxy for LMI. The only evidence my examiners will take is the percentage of students that are eligible for the FRL program, and only after determining that 80% of the area median family income is less than the thresshold for the FRL program.

Great info! Thank you for the clarification!

How would I find/research this information?

"Number of MSAs across the country in which the FRL dollar thresshold is higher than 80% of the median family income"

Title 1 is a good starting point, but you must go much farther to get credit.

"According to the U.S. Department of Education the purpose of Title 1 funding, “is to ensure that all children have a fair, equal, and significant opportunity to obtain a high quality education and reach, at minimum, proficiency on challenging state academic achievement standards and state academic assessments.”

The basic principles of Title 1 state that schools with large concentrations of low-income students will receive supplemental funds to assist in meeting student’s educational goals. Low-income students are determined by the number of students enrolled in the free and reduced lunch program. For an entire school to qualify for Title 1 funds, at least 40% of students must enroll in the free and reduced lunch program.

Read more: http://www.brighthub.com/education/k-12/articles/11105.aspx#ixzz1G8VcsrM3."

not as,

Is there a reason you have to rely on the Title I designation?

Sorry for not being very clear on this question.

The FRL is based on the Federal Poverty Level, as determined by the federal government every fall. The FRL number is a multiple of the FPL, usually 200%.

You can see the FPL here: http://www.coverageforall.org/pdf/FHCE_FedPovertyLevel.pdf


So we had to create a spreadsheet comparing hundreds of MSAs' median family income (and 80% of same) to the multiple of the FPL for a household of 4 (since the FPL adjusts for family size). In those MSAs for which the qualifying thresshold for the FRL program, again typically 200% of the FPL, was higher than 80% of the median family income, we could not FRL as a proxy for the definition of LMI.

Hopefully you are in one or a few MSAs and this won't be a big project. Or you could ignore doing this at all and see if they examiners do the same.

This is one case in which examiner subjectivity may play in your favor and they don't want to go down to this level of detail.

Sorry everyone for being such a newbee - as you can tell from my "name" - CRA is not my forte - I'm learning as much as I can in a very short amount of time.


Thank you for your information.


Our particular examiner was focused soley on if the school was Title 1 or not.

I have an employee who volunteers at a school that is not Title 1, but has more than 50% on the FRL program. I was wondering if that should count for CRA.

So much any more depends upon the individual examiner with CRA. In the past I have received credit for schools with a high participation in the free/reduced a lunch program that were not necessarily designated (by the bank, we didn't go that route) as Title 1. We obtained data on the lunch program at the school, how children were qualified, # of children, definitions from Dept of Agriculture, information on the program we were trying to qualify (it was a grant)and how it would benefit the children, etc.

So it is possible.

This is a full time job

How do you get that information - do the schools readily supply or is there a website I can search & query?

I've been using this one: http://www.ed-data.k12.ca.us/welcome.asp?

But the piece I guess I'm missing is how the children are qualified - what income they look at.

In the interest of time, I would ask my school contacts to provide all the info you need to present to the examiners. They know the FRL % and how it is determined. Typically, they are so appreciative of your support they will get what you need for your examiners.

There are a number of sites that will give you FRL % by district and by school.

You are so right, documenting for examiner review is time consuming.

here is a site newbsa I have used:

http://nces.ed.gov/globallocator/

you can search by individual school ......

Eligibility for the Free and Reduced Lunch Programs are based on 130%(free) and 185%(reduced) of the Federal Poverty Level. The unfortunate thing about this is that it adds in yet another comparable since the Poverty Level is broken down by Household Size. I take the average Household Size of 4(multiplied by 130/185%) and compare to 80% Median Family Income for the area. Seems to be acceptable to the examiners so far.

Here is the link to the Federal Register where the Poverty Guidelines are published.
http://www.gpo.gov/fdsys/pkg/FR-2011-01-20/pdf/2011-1237.pdf

Hope this helps!

As I am working on this for a bank, it occurs to me what a collosal waste of time it is for every bank to have to document the definitions, etc. The government sets them and it would be much more efficient to just equip the exam teams with the data - they must know it by now anyway after seeing it at bank after bank. The money saved by not spending time on this at every bank could be donated.

Amen!

I think you can count on both hands the number of MSAs in the country where the FRL percentage for a family of 4 may be greater than 80% of the area median family income for that same MSA.

*like*

I use this site (http://nces.ed.gov/ccd/bat/)to determine the FRL percentage for each school in my assessment area. I build an Excel table of all schools in each county and update the list each year.