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#1701737 - 05/21/12 06:59 PM Exclusions - Investment Test
Luz Offline
Junior Member
Joined: Sep 2011
Posts: 47
The Bank underwrote financial education workshops on behalf of an organization with a community development purpose. In addition to underwriting the workshops the bank: 1) availed staff to faciliate the workshops and 2) provided $25.00 account opening for workshop participants.

The cost of underwriting the workshops is being declared under the investment test and I was hoping to declare the remaining activities under the service test. As many of you know, however, the regulation states that activities considered under the lending or service tests may not be considered under the investment test. The federal register dated March 2010 does speak to exceptions, however.

Can anyone provide me with some clarity as to whether I should report both the investment (cost of underwriting the workshops) and service (facilitation of workshop and/or $25.00 opening deposits).

Thanks for your perspectives in advance!

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#1701755 - 05/21/12 07:20 PM Re: Exclusions - Investment Test Luz
Care4RCommunity Offline
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Joined: Apr 2012
Posts: 110
NJ
The credit under the investment test for underwriting the workshops seems pretty clear to me.

As far as the service test is concerned, my question is this:
What do you mean that you "availed staff to facilitate the workshop." Were they using their financial expertise to present the workshop? Or, were they merely doing introductions and some of the administrative tasks?

If they were using their financial expertise to impart financial knowledge then I would try to gain credit under the service test and let the examiner tell me that it can't be double counted with the investment test. If they were coordinating the event, then I wouldn't even try to obtain credit.

I also doubt that any credit would be given for the $25 at account opening.

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#1701836 - 05/21/12 08:54 PM Re: Exclusions - Investment Test Luz
Pale Rider Offline
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under the Lone Star
Do you have a hard dollar amount for this underwriting of the workshops? With hindsight, it would have been easier to document if you had made a donation to the nonprofit for the program of providing financial education and let the nonprofit pay for the cost of the workshops.
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#1701857 - 05/21/12 09:35 PM Re: Exclusions - Investment Test Pale Rider
Luz Offline
Junior Member
Joined: Sep 2011
Posts: 47
Good point! Thanks!

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#1702118 - 05/22/12 06:57 PM Re: Exclusions - Investment Test Luz
CRAatBOK Offline

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Joined: Mar 2004
Posts: 6,172
Further South than I wanna be.
I have received credit for both before. Yes, we had documetation on how the money was spent.
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Life is not the way it's supposed to be. It's the way it is. The way you cope with it is what makes the difference.

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