We're hosting a series of financial education events across our footprint focused on fraud prevention, elder abuse, etc. Events are open to current clients as well as general public and generally held in one of our local branches (when they have facility large enough) or other community location, event center, etc. Can this qualify for CD Service hours without demonstrating specific LMI focus/target through % of audience, location of event, partnership with a qualifying organization, etc.?

Any Community Development activity must have its "primary purpose" a qualified CD activity. In this case it looks like you think it may apply as a community service provided by your bank. To fulfill the primary purpose test there are two options. First, the majority of the cost or the majority of the beneficiaries are LMI persons. Second, if you can't meet the first option, you must have written documentation showing the express intent of providing benefits to LMI persons, the activity must be structured in such a way that LMI persons will benefit and third, there's a reasonable certainty that the purpose will be fulfilled. In addition, when the service is provided by the bank it must be financial in nature or relate to the expertise of the employee volunteer.

I would suggest you make an explicit effort to solicit the LMI community to attend the event. In a recent anti discrimination settlement one factor cited was that the seminars held by the financial institution all were in middle- and upper-income census tracts. It would be a good idea to have some of your events in the poor and minority communities inside your assessment area to demonstrate the events are aimed at those audiences.

Thank you Len, that was what I was thinking regarding the "purpose" test but wanted to double-check. Appreciate the info!