In the absence of to an organization with a "defined mission" of serving LMI or funding being applied to a clearly defined program, if the agency can provide statistics or written evidence of its constituency and the substantial majority of the individuals serviced are LMI, would that be enough to support a "community development purpose". I don't know if that would get me beyond the fact that the CD service must be "targeted" to LMI, but thought I would get your perspectives.

Thank you in advance!!

In the past we have targeted some of our donations to specific programs within an organization. Usually we document this by stating the name of the program and a brief summary in our donation letter. Then, we ask the receiving organization to include the same information in their thank-you letter. So far, examiners have accepted it.

I hope this helps!

Thank you for your feedback! Unfortunately, based on bank size and resources, we do not have a centralized process for corporate giving or a foundation currently. Based on this I may not always drive the decisions and therefore, may not be able to coordinate the funding of a particular programs. As you know, many organizations do service LMIs by virtue of its activities and/or location. The challenge is getting beyond the issue of "targeted" and I was hoping to accomplish this by having the organization document socioeconimic information about its constituency. Any other thoughts?

A helter skelter process causes more work and worse results. You don't need a foundation, but you need an up front process or the bank will be throwing money away.

Ditto to KB's comments, in the absence of a more organized process, you can have a nonprofit provide you with the demographics of the clients they serve as evidence that they are seving primarily low-and-moderate income individuals. Many health and human service organizations will have annual reports to their funders already prepared that should meet your needs to evidence CRA credit.

We keep what we call "master files" on each agency we are involved with either thru donations or services. The file contains info from the website, if there is any, a letter from the agency indicating who they serve and what % are LMI, and any other info we can pull together that supports that they should qualify.

It might be a pain to get it started but it will be well worth it come exam time.

We keep what we call "master files" on each agency we are involved with either thru donations or services. The file contains info from the website, if there is any, a letter from the agency indicating who they serve and what % are LMI, and any other info we can pull together that supports that they should qualify.

It might be a pain to get it started but it will be well worth it come exam time.