We recently completed a CRA exam where the examiners did not want to give us credit for some of some our services if we had multiple employees attending same event. Example; two employees teaching a financial literacy course in the same school, different class rooms, but because it was one school on the same day, they only want to give us credit for one service. In my mind the bank was paying each of these employees to teaching a financial literacy course, it shouldn't matter if they were at the same school or not. Would it also make a difference if we had the same two employees in the same class room?

Any guidance would be great. Thanks!

These regulators are getting out of hand--if a service qualifies it qualifies. It is industry standard to combine board membership activities because it is considered an on going commitment, but not required. If a bank were to issue multiple grants to a nonprofit--we wouldn't deny the least valued loans because we already lent to an organization. Under the most recent Q&As an examiner is not to consider only the quantitative factors, but the qualitative factors of activities. Multiple employees teaching the same class allows for the activity to be more responsive. You're unfortunately going to have to be on the defensive with this examiner and ask her to demonstrate where in the regulation it states that service activities must be combined, or denied if made to the same school or students. Not only that, but what if multiple people are teaching different classes at the same school on the same day. More people benefited from that activity, but if we were forced to deny those other records or combine them it wouldn't demonstrate how qualitative the activity was.