Would anyone be willing to share their process for making CRA-related donations or contributions to organizations? I am interested in what documentation you are requesting or keeping. I have seen that some banks send a letter with their donations stating what the funds are to be used for, or they have the orgs provide documentation stating that they primarily serve those in LMI census tracts, etc.

I'm trying to solidify a procedure or come up with a checklist for what should be required but would like to keep it as simple as I can while also ensuring a sound process. Any input would be appreciated. Thank you!

We ask our organizations to complete a document we created. It asks for mission, how our funds were used and then asks for number of people served and what % are either below the LMI income for our area, free/reduced lunch eligible or Pell grant or financial aid eligible. Our regulators accept that.

This is helpful. Thank you! Anyone else have feedback on their process? Much appreciated.

I attempt to document what I can from the organization's website. Sometimes, you can get everything you need without contacting the org for additional information. I document everything in my tracking spreadsheet that is provided to the regulators including address with MSA County and Census Tract Codes (indicating the income level of the geo), if applicable I provide the free-reduced lunch rate for the school(s), I also copy the link to their website about page along with a description. It seems like a lot, but once you get a spreadsheet created it doesn't seem so bad. Plus, when it is exam time, you can just hand over the excel workbook and be done.

Of course, depending on the size of your bank or level of donation activity... this method might not be feasible.

We also have an internally produced document that we request the recipient organization to fill out, showing the appropriate CD purpose is being met. Whether that is Affordable Housing, Services to LMI, Economic Development, or Revitalize/Stabilize. However, we have found that the examiners like to have evidence from a publicly available source, so we also try to obtain information from the org's website that describes the LMI nature of the services or affordable housing offered etc. We will also look for any annual reports that may be publicly available that support the CD purpose, as well as any journalistic articles published talking about the projects or services being funded.

Good info, thank you!

For some healthcare related organizations, like those offering group homes or services to disabled individuals, I will look at their 990s to see if the majority of their funding comes from Medicaid.