The bank owned a large building and the tenant has moved out. The market is not so good in the area, so management was thinking that there might be a way to use the property for a CRA purpose. The property happens to be in an upper income census tract.

I'm looking for ideas. Anyone have anything to share?

Making such a property available to a CRA qualifying not for profit will count for donations/investments. You need to show the rent you charge vs market. The difference is a donation.

Thanks for the response Kathleen. We are conducting research to identify CRA worthy NPOs in the area and will be contacting them to see if they are interested in the space.

Just found out that we are considering leasing the space to a local university. I should mention that the university is located in an upper income area; however, I've been told that they will be using the space to provide financial literacy classes. I'm not sure who these classes will be directed to: for example LMI individuals or just the general public.

I will be participating in a meeting in the next few days to find out more. Any suggestions for how we might be able to make this work for CRA credit?

Our examiner (OCC) told us to use Pell Grant recipient percentages as a proxy to determine if the majority of students at a particular college are from LMI families. If the college is holding financial literacy classes there and the Pell grant percentages are >50%, I think you could make a case for that counting.

You can check Pell grant percentages at:
The National Center for Education Statistics

The Pell grants can be found after finding the school under Financial Aid information.

Yes. Thank you for clarifying Pale.