Would participating in a CRA Working Group count towards CRA Service Hours?
Example: ABA Working Group or local CRA Peer Professionals Group

What service are you performing for your community by participating in that group?

Its more of connecting with other banks and discussing what they are doing for CRA in the community. Also, experiences in recent CRA Exams. Occasionally there will be guest presenters from local non-profit organizations or vendors. Lastly, CRA Modernization is also discussed.

Yes, not going to be easy to make a case for that benefiting the community. How is that a service?

I don’t see how you are using financial or
Technical expertise to benefit a low- or moderate-income
Community in your example.

Would a leaseback pay employee of a large bank be eligible to receive CRA Service hours for that bank.

The leaseback employee would be providing financial literacy courses directly to LMI individuals in our assessment area.

We are considering this option to take advantage of more Service hours in the assessment area.

Sorry - what is a leaseback pay employee?

Leaseback employees results when an agreement between two entities occurs, and they are leasing an employees services to another.

A non-profit organization we partner with would be leasing out an employee to the bank. The employee is a financial literacy coach and thus their work would result in eligible CRA service hours.

https://www.occ.gov/publications-an...permissible-for-nat-banks-fed-saving.pdf
Page 33
“Leasing Bank Employees From Third Party. National banks may lease the services of its employees from a third party as long as the board of directors continues to retain and exercise general supervision over the affairs of the bank. OCC Interpretive Letter No. 431, reprinted in [1988-1989 Transfer Binder] Fed. Banking L. Rep. (CCH) ¶ 85,655 (November 5, 1987); 12 CFR 7.2010.”

Why do you not just directly provide funds to the 501(c)3 for the purpose of paying the employee and sponsoring the training? Investment money is worth a lot more than service hours, I would think.