From the CRA Q and A
http://www.ffiec.gov/cra/pdf/2010-4903.pdf§ll.12(h)—6: Must there be some
immediate or direct benefit to the
institution’s assessment area(s) to
satisfy the regulations’ requirement that
qualified investments and community
development loans or services benefit an
institution’s assessment area(s) or a
broader statewide or regional area that
includes the institution’s assessment
area(s)?
A6. No. The regulations recognize that
community development organizations
and programs are efficient and effective
ways for institutions to promote
community development. These
organizations and programs often
operate on a statewide or even
multistate basis. Therefore, an
institution’s activity is considered a
community development loan or service
or a qualified investment if it supports
an organization or activity that covers
an area that is larger than, but includes,
the institution’s assessment area(s). The
institution’s assessment area(s) need not
receive an immediate or direct benefit
from the institution’s specific
participation in the broader organization
or activity, provided that the purpose,
mandate, or function of the organization
or activity includes serving geographies
or individuals located within the
institution’s assessment area(s).
In addition, a retail institution that,
considering its performance context, has
adequately addressed the community
development needs of its assessment
area(s) will receive consideration for
certain other community development
activities. These community
development activities must benefit
geographies or individuals located
somewhere within a broader statewide
or regional area that includes the
institution’s assessment area(s).
Examiners will consider these activities
even if they will not benefit the
institution’s assessment area(s).