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#2199218 - 11/27/18 10:00 PM Community Development Services - by a contractor
In It Together Offline
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Joined: Feb 2016
Posts: 16
Would the performance of a CD service, such as a speaking engagement on ID theft, that is conducted by a contractor who is engaged by a bank count for CRA CD credit, or does the service have to be performed by a bank employee?

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#2199309 - 11/28/18 09:27 PM Re: Community Development Services - by a contractor In It Together
Lori01 Offline
100 Club
Joined: Jan 2007
Posts: 186
VT
Seems like you could count the money you spent to hire the contractor as an investment, provided there is a CD hook, like the group presented to is LMI. If bank staff organized the event and marketed it, that staff time could possible count too, on the service side.

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#2201376 - 12/21/18 10:13 PM Re: Community Development Services - by a contractor In It Together
mrogersfib Offline
100 Club
Joined: Aug 2018
Posts: 116
You can hire people to perform CD Services as long as the contractor is not also subject to CRA. Say for instance you hire a credit counseling firm to provide free counseling to your bank clients in an LMI area that would qualify. For your instance, you are going to have to prove that the people who attended the meeting were LMI, for instance the speaking location was held in an LMI census tract.

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