We have several employees that volunteer at our state's food bank. Some of the service is done on bank time. The food bank supplies food to local homeless shelters throughout the state, so pretty much all the beneficiaries will be LMI. Is there any way I can count these hours as CRA CD services?

The reality is that sometimes you might get a few "brownie points" from an examiner (so it might be worth ensuring they know about it), though it sounds like these activities won't technically count as they are not a "provision of financial services." Basically, to get service credit, the service must be related to those normally offered by the financial industry. The CRA FAQs explain this:

"§ 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. 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.'

Also, the services technically don't count if they are done on an employee's own time and not as a representative of the bank. From the FAQs:

"ll.12(i)—2: Are personal charitable activities provided by an institution’s employees or directors outside the ordinary course of their employment considered community development services?

A2. No. Services must be provided as a representative of the institution. For example, if a financial institution’s director, on her own time and not as a representative of the institution, volunteers one evening a week at a local community development corporation’s financial counseling program, the institution may not consider this activity a community development service."

Any chance those employees also serve on the board? What about technical expertise? Does the food-bank need help from your IT guy, HR department, etc? Develop forms, processes, etc?

No, they don't have to use their banking experience. Mostly it's collecting, sorting, and packaging the food. It's just a lot of hours and I wanted to see if there was any way to spin it to count.

What type of work are they doing at the food bank? Sorting through food donations? Stocking shelves? Distributing food? Assembling boxes? No to all of the above.

Now lets say that someone volunteers at the food bank and inputs information into the volunteer scheduling, tracking, and reporting software. This data will eventually used to obtain federal and local funding. Are they using the donor/contribution software to track and acknowledge donations. Are they assisting in fundraising? I would say you would be safe to count all of these as CD services.

I think it depends on the examiner as to whether or not credit would be given. Developing the software could be IT experience being used, but simply entering data is another matter. I am pretty confident that the examiners I have dealt with would not have included it as a community development service.

As to volunteering at a food bank or donation center for clothes/toiletries intended for low- or moderate-income individuals or families, couldn't this be counted based on the guidance in the 2016 Interagency Questions and Answers Regarding CRA? See page 3 at the bottom of the left column and top of the right column.

https://www.fdic.gov/resources/supe...mination-manual/documents/11/xi-12-1.pdf

Volunteering at a food bank seems to be the exact type of activity contemplated by the 2016 Interagency Q and As. Am I missing something?

Edit: link now included. Thank you for pointing that out!

Page 3? It might be nice to know what document you are referring to in the format that is in front of you.

Great point - link now included in my post.

Those give examples of ways in which an institution could determine that community services are targeted to low- or moderate-income persons.

And people that go to the food bank would likely prove the target, but only working at a food bank still does not meet the definition of a community service.

How is it related to providing financial services?

Community development service means a service that:

(1) Has as its primary purpose community development;

(2) Is related to the provision of financial services; and

(3) Has not been considered in the evaluation of the bank's retail banking services under Sec. 228.24(d).

I understand, thank for you clarifying that for me.

Do examiners generally scrutinize CRA hours closely to determine that all activities meet all three prongs listed above?

"Do examiners generally"?

Ha - your guess is as good as mine. Some will just check off the box and some will ask you to justify every hour. It really is a crapshoot.