I am not a CRA expert, so looking for some guidance. Should we be keeping records of donations that are given to charities benefiting low income people? I've always been under the assumption that CRA really applied to the availability of loans within low to moderate assessment areas.

How big is your bank? If small but approaching ISB status or already ISB or larger, yes, your bank should be tracking donations to organizations that provide services to low and moderate income individuals. Those donations are counted as investments in the community development category.

If your bank is very small you will have been examined on loan performance only unless you voluntarily provided other data to attempt an outstanding rating.

A review of the CRA Q and A at the FFIEC site will help.

http://www.ffiec.gov/cra/default.htm