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#303770 - 01/14/05 02:03 AM Community Development Credit
Anonymous
Unregistered

Does the bank receive CD credit for charity and/or community involvement activities performed by bank employees such as big brothers, boy scouts, special olympics?

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CRA
#303771 - 01/14/05 02:46 AM Re: Community Development Credit
HRH Dawnie Offline
Power Poster
HRH Dawnie
Joined: Aug 2002
Posts: 7,353
Anchorage Alaska
Only if you can document that it involves the provision of financial services to entities or programs that serve LMI individuals or geographies.

Example: Sit as Finance Committee Member on the Board of the Food bank. That would count.

Worked six hours on the food line. That would not count.

Typically the entities you mentioned would NOT qualify as their services are not specifically geared towards LMI people. In my community I do receive credit for Big's because their target market is an LMI geography. Boy Scouts...good luck! and Special Olympics, if you can document that the majority of the people served are LMI (that isn't hard to do in most communities) AND the position involves finances of the entity somehow, you might be ok.

Feel free to post what they actually do for these entities and I'll be glad to help out more.
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Dawn Coursey VP/CRA Queen

CRA Rating is in...Oh who cares...I'm home with the baby.

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#303772 - 01/14/05 02:58 AM Re: Community Development Credit
Anonymous
Unregistered

Wow, your quick. Thank you for your response.

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#303773 - 01/14/05 06:43 PM Re: Community Development Credit
HRH Dawnie Offline
Power Poster
HRH Dawnie
Joined: Aug 2002
Posts: 7,353
Anchorage Alaska
I work later than the rest of you time zones

Happy to help
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Dawn Coursey VP/CRA Queen

CRA Rating is in...Oh who cares...I'm home with the baby.

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#303774 - 03/08/05 07:07 PM Re: Community Development Credit
Bullseye Offline
Platinum Poster
Bullseye
Joined: Jan 2004
Posts: 968
Quote:

Only if you can document that it involves the provision of financial services to entities or programs that serve LMI individuals or geographies.

Example: Sit as Finance Committee Member on the Board of the Food bank. That would count.

Worked six hours on the food line. That would not count.

Typically the entities you mentioned would NOT qualify as their services are not specifically geared towards LMI people. In my community I do receive credit for Big's because their target market is an LMI geography. Boy Scouts...good luck! and Special Olympics, if you can document that the majority of the people served are LMI (that isn't hard to do in most communities) AND the position involves finances of the entity somehow, you might be ok.

Feel free to post what they actually do for these entities and I'll be glad to help out more.




I have a question somewhat related to this. We have a non-profit organization in our community that we have decided to support. The organization's mission is to build, preserve and enhance affordable housing. The homes are either rented or sold to low/moderate income individuals who have completed homeownership training. We have an exam in the next few weeks and I want to make sure I am listing out our support correctly for CRA. We have provided supplies for them to build the homes (actually purchased the supplies and donated them, so an investment??), we have volunteered our staff to paint & work out at the homes (CRA Service? But not tied to financial services so will it qualify?)and volunteered our staff to teach the homebuyer courses (CRA Service). This is a great program that is really in need of the support our bank can provide to keep it running and it truly supports the intent of CRA. Am I making the most out of what we are providing to them for CRA purposes and do you have any suggestions as to what more we could do for them to get extra "points"? Thanks!

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#303775 - 03/08/05 08:06 PM Re: Community Development Credit
Pale Rider Offline
10K Club
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Joined: Aug 2002
Posts: 34,318
under the Lone Star
Not the Queen here, but you have a yes on the donation, a no for swinging hammers, and a yes for teaching the homebuyer courses.
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Societies that do not find work in and of itself "pleasing to God and requisite to Man," tend to be highly corrupt.


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#303776 - 03/08/05 08:22 PM Re: Community Development Credit
Bullseye Offline
Platinum Poster
Bullseye
Joined: Jan 2004
Posts: 968
Thanks Don. That is what I figured you'd say, and I am sorry but that frustrates me. The bank encourages staff to participate in many activities such as this, like I said, even donating the supplies to get the job done, and will continue to do so with or without CRA. Without our wonderful staff "swinging hammers" on this project, it simply wouldn't happen & these families would be left out on the street....that isn't development of these broken down neighborhoods in our community? That isn't community reinvestment? It makes agree with CubDave's comments in the CRA Proposal thread even more about how a community bank such as ours can spend hundreds of thousands of dollars in our community doing what we think is right but not get an "outstanding" rating because what we have done doesn't qualify. We have ONE low income census tract in our AA and about a zillion truly large banks (larger than us) competing for what little qualified investments there are. Guess who's gonna get the short end of the stick because we are not even a half billion??!! Okay, rant over. I feel better now. Thanks again!

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#303777 - 03/08/05 09:30 PM Re: Community Development Credit
Anonymous
Unregistered

During our last exam, the examiner we had gave us CRA service credit for "swinging hammers" if it was on bank time. The only time our service didn't get counted if it was done off the clock on the bank employee's personal time.

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#303778 - 03/08/05 09:39 PM Re: Community Development Credit
HRH Dawnie Offline
Power Poster
HRH Dawnie
Joined: Aug 2002
Posts: 7,353
Anchorage Alaska
I agree with Don's quick answers, including not getting credit for what my examiner calls "Happy Hammers" But...I'd be sure to include that time and effort in the write up for the service and investment credit so they know you went over and above just cutting a check.

Now, as to the last Anon comment...yup, I've seen folks get credit for Happy Hammers as well, but that does not mean it was right. I've also seen folks get investment credit for FHLB grants, when they put NO money out of their own. Is that right? No, it's an examiner who either didn't spend the time reading each service, or investment, or an examiner who made a mistake but we can't operate hoping we get the same lucky break.

Go with the letter of the law, and push it, but don't hang your hat on the whim of one examiner you got away with it with. Losing credibility is a huge way to fail an exam, and is it worth it for a few hours or your disagreement with the reg? Nope Save that for congress
_________________________
Dawn Coursey VP/CRA Queen

CRA Rating is in...Oh who cares...I'm home with the baby.

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#303779 - 03/09/05 05:48 PM Re: Community Development Credit
CRAatBOK Offline

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Joined: Mar 2004
Posts: 6,172
Further South than I wanna be.
Another possible way to get credit in this situation - member of loan committee. Does the org have a process to approve loans or do the borrowers go outside for loans. If any approval is done internally (or even for those that rent properties) and you sit on the approval committee you can get service credit.
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Life is not the way it's supposed to be. It's the way it is. The way you cope with it is what makes the difference.

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