This is my first time working for a bank with it's own foundation and I'm trying to wrap my head around how this works.

Can the bank count any of the donations made by the foundation as a CRA donation?

Not all of the foundations donations meet the CD definition so we can't just count the entire donation to the foundation.

Any suggestions on how to get credit?

Yes, the regulation specifically allows for consideration of investments made by affiliates, so first make sure the foundation would be considered an affiliate under the regulation.

Reg 12 CFR 25.12 Definitions: (a) Affiliate means any company that controls, is controlled by, or is under common control with another company. The term “control” has the meaning given to that term in 12 U.S.C. 1841(a)(2), and a company is under common control with another company if both companies are directly or indirectly controlled by the same company.

Reg 12 CFR 25.23(c) Affiliate investment. At a bank's option, the OCC will consider, in its assessment of a bank's investment performance, a qualified investment made by an affiliate of the bank, if the qualified investment is not claimed by any other institution.

You will need to review each donation made by the affiliated foundation; purpose, amount, date, etc. Good luck!

Aha, that makes sense! Thank you.