We have an upcoming CRA exam. Trying to get all the "qualified investment" credit we can. Last year we conducted two institution-wide collection efforts. We collected canned goods at Christmas and donated several thousand pounds of canned & boxed food supplies to local food banks. Last summer, we also collected school supplies and donated to local schools serving significant student populations from low-income families. Has anyone had any experience at how to quantify from a monetary standpoint the value of such donations?

Were the canned goods and supplies donated by customers or bank employees or a mix? I ask because during our last exam (OCC 2014) we were told donation drives that solicited donations from customers (or the public) would be included as service credit rather than investment credit. The only way we were able to receive investment credit is if the bank actually spent money on buying supplies or food. So I wrote up all the donation drives we did and counted employee hours and presented them for service consideration.

Bank employees. Not customers. But the bank didn't buy the supplies, the individual employees did. Sounds like we might be in the same boat - service credit rather than investment credit.

Yes, service rather than investment credit. The bank must provide the funds or goods in order to get investment credit. You can do both.

Thanks for the reminder! We have "back to school drives" in several locations.

Ok, I am going to play devil’s advocate here. Isn’t collecting canned goods or schools supplies and delivering them to recipients similar to that of “swinging a hammer” for Habitat for Humanity? We, the bank would never get service credit from our examiners.

Is it considered a COmmunity service? We are going to have a food drive at the bank for our local food bank. We are also thinking of having a coat drive. Can we include it as a CRA service?

Thank you.

This can vary depending upon the description of the activity and the examiner. The Q and A gives examples from which you can obtain guidance on what needs to be included to obtain credit in an exam. Managing the entire project could be seen as providing services that use skills used in banking. I have seen banks obtain credit for managing and counting the money raised in a fund raising drive.

§ ll.12(i)—1: In addition to meeting
the definition of ‘‘community
development’’ in the regulation,
community development services must
also be related to the provision of
financial services. What is meant by
‘‘provision of financial services’’?

A1. Providing financial services
means providing services of the type
generally provided by the financial
services industry. Providing financial
services often involves informing
community members about how to get
or use credit or otherwise providing
credit services or information to the
community. For example, service on the
board of directors of an organization
that promotes credit availability or
finances affordable housing is related to
the provision of financial services.

§ ll.12(i)—3: What are examples of
community development services?

A3. Examples of community
development services include, but are
not limited to, the following:
• Providing technical assistance on
financial matters to nonprofit, tribal, or
government organizations serving lowand
moderate-income housing or
economic revitalization and
development needs;
• Providing technical assistance on
financial matters to small businesses or
community development organizations,
including organizations and individuals
Providing technical assistance about
financial services to community-based
groups, local or tribal government
agencies, or intermediaries that help to
meet the credit needs of low- and
moderate-income individuals or small
businesses and farms is also providing
financial services. By contrast, activities
that do not take advantage of the
employees’ financial expertise, such as
neighborhood cleanups, do not involve
the provision of financial services.

§ ll.12(i)—3: What are examples of
community development services?

A3. Examples of community
development services include, but are
not limited to, the following:
• Providing technical assistance on
financial matters to nonprofit, tribal, or
government organizations serving lowand
moderate-income housing or
economic revitalization and
development needs;
• Providing technical assistance on
financial matters to small businesses or
community development organizations,
including organizations and individuals
who apply for loans or grants under the
Federal Home Loan Banks’ (FHLB)
Affordable Housing Program;
• Lending employees to provide
financial services for organizations
facilitating affordable housing
construction and rehabilitation or
development of affordable housing;
• Providing credit counseling, homebuyer
and home maintenance
counseling, financial planning or other
financial services education to promote
community development and affordable
housing, including credit counseling to
assist low- or moderate-income
borrowers in avoiding foreclosure on
their homes;
• Establishing school savings
programs or developing or teaching
financial education or literacy curricula
for low- or moderate-income
individuals; and
• Providing foreclosure prevention
programs to low- or moderate-income
homeowners who are facing foreclosure
on their primary residence with the
objective of providing affordable,
sustainable, long-term loan
modifications and restructurings.
Examples of technical assistance
activities that are related to the
provision of financial services and that
might be provided to community
development organizations include
• serving on the board of directors;
• serving on a loan review committee;
• developing loan application and
underwriting standards;
• developing loan-processing
systems;
• developing secondary market
vehicles or programs;
• assisting in marketing financial
services, including development of
advertising and promotions,
publications, workshops and
conferences;
• furnishing financial services
training for staff and management;
• contributing accounting/
bookkeeping services;
• assisting in fund raising, including
soliciting or arranging investments; and
• providing services reflecting a
financial institution’s employees’ areas
of expertise at the institution, such as
human resources, information
technology, and legal services.

Refer to Q&A §ll.24(a)—1 for
information about how retail services
are evaluated under the large institution
service test

Thank You.

Soliciting and collecting anything of value (money, canned goods, sweaters, backpacks) is a form of fund raising. So that would count for Service Credit.

However, handing OUT the donated items would not count for Service Credit.

Bringing this back to get some feedback.

Have any FDIC regulated institutions been able to receive community service credit for food drives or school supplies drives?

In order for an activity to qualify for a CD Service it must be related to the provision of financials service. Or if you are serving on a board/committee of an organization that is handling the drives you could count your activity as providing technical expertise to the organization around fundraising, or marketing if that is apart of the persons expertise within the bank. Handling, or taking donations that are not cash cannot count as a service, but if you are handling cash, or credit cards for the drive at lets say a silent auction then that activity would qualify if also the organization qualified for CD.

Arguing against the point of Princess above--taking or assistance in taking of anything other than cash, or instrument processing is not related to the provision of financial services at the bank. For instance, knocking on nails for Habitat for Humanity is not an expertise normally found at a bank besides those employees who work in facilities. Conversely, if your organization matches hours spent working at a location then the labor match can qualify as a donation. Alternatively in the case of food or school supply drives I try to get the bank to match the monetary value of the drive with a donation.