Hello -

There is a really nice flow chart in the Compliance Tools of BOL to help determine if a donation or service hours of a FI qualify for CRA credit.

The only flow chart I find though is for a "large" bank. Is anyone aware of a flow chart available for an ISB instead?

Thank you!

I'm not what difference there would be. Either the donation or service qualifies for credit or it does not. There are not separate standards for large versus ISB or SB for these areas.

I agree. The important thing is to not just list the items but to document what type of credit they qualify for and why they qualify. Other than overlooking reportable transactions/services, that is the biggest gap I consistently come across in bank CRA data.

I am now at an ISB after spending most of my career at a CRA Large Bank. I am well familiar with tracking CRA services and what counts/what does not count. At the Large Bank, I never collected service hours. I see much about collecting hours in reading the threads - is this something that is unique to small banks, or do large banks do likewise, and I just did not. FDIC was OK with not collecting hours; we always had an "Outstanding" on our Service test during my 20 years there.

Should I mend my ways and start collecting employee hours along with the services?

I am at one of the larger banks. We have collected hours for CD services for one time events. We do not collect hours for board services, except for the President's Service Awards.

I find that at smaller banks regulators want to see hours, even for board members.

We are an ISB, and the OCC is doing a CRA exam right now. They did ask me for the number of hours each employee spent in services.

Some times they have asked for hours, sometimes not. We have a CRA Exam this fall, and based on our Data Integrity Review I anticipate they will want as much detail as I can imagine (and more)!