We are currently enjoying a CRA exam with the FDIC. My 6th in 22 years, and new this year is a question around donations requests that include a "sponsorship" component. These requests are usually event driven, but are, at their core, fundraising opportunities for the non-profit.
The EIC has questioned the idea of these contributions being reported as "donations" because the bank might be "getting something" in return. She seemed to want me to quantify the value to the bank. She seems to want to lower the value of the donation based on the perks the bank gets. Has anyone else run across this push-bank on donations?

Often these requests come with marketing perks, such as a logo on a website or in the even program. I have no way of assigning a $ to that benefit. In other cases, it comes with a certain number of tickets. Again, unless it's a really large non-profit with a huge development staff, they don't tell us, nor do I think they know, the value of the tickets. And we may or may not even use the tickets.

Have others come across this situation recently, and what are you doing about it?

I've been consulting on CRA matters for more than 30 years and I have not heard this issue brought up before. Anytime a bank does something for a community organization they usually (and rightfully) publicize it. The "value" to the bank is incalculable and should not be a factor for recognizing a qualified community development investment or donation. The impact on the community is the more relevant question. These things are difficult to measure so the default is to use the cost to the bank.

Please post on the outcome of your situation. Sometimes examiners will go rogue on obscure areas.

Same as Len. I've been working in CRA for more than 30 years (examiner, consultant, and banker at various points), and I've never heard of this issue. Benefit to the bank is not a component of community development consideration. Quite the opposite - regulators consistently state that serving all of a bank's communities is a good business practice and safe and sound banking.

Expanding on the tickets to events detail: this would include sponsorships that have tickets to a dinner event. Or sponsorships to golf events that include the opportunity for a foursomes to play.

Does anyone attempt to deduct the cost of dinner or a round of golf from the amount they report. Of course this assumes the proceeds are going to a qualified CD activity.

"Benefit to the community" is the only thing that matters. Impact on the bank is irrelevant.