Does anyone think that a bank could receive CRA credit if they offered the post-financial management course that under the new Bankruptcy law filers must go through and receive a certificate of completion before actually being discharged? I have the application, etc. to submit for approval from the Dept. of Justice but I'm not sure if it would be a shoe-in for CD Service credit...

You need to show the link to LMI populations. Either pair up with an agency who can show they serve a majority LMI, or offer it in an LMI census tract. You're not going to want to collect financial information yourself I'm guessing (I wouldn't) so you have to figure out a way to that link. While you can claim that "most" people who've declared bankruptcy are probably LMI, that is unlikely to fly.