For anyone whose bank has participated in this program, did your examiners give your bank CRA credit automatically or were you required to document that it qualified as community development(primarily benefitting LMI students or a school in a LMI geography)? I wondered if this is considered in the same vein as the FDIC's Money Smart Program, which in my understanding, is automatic CRA credit?

At our exam, we only received credit for activities at those schools who primarily had LMI students.

We also only received credit for activities at those schools who were primarily LMI.

We were told that if we taught Money Smart there we could get credit. Well, unless they are going to re-write Money Smart I don't think that is going to work as we mostly go into the elementary schools!

Thanks for your comments.

By the way, participation in the FDIC's program is not "automatic" credit. Examiners will ask that you demonstrate that the beneficiaries are low- or moderate-income individuals.

Also on a side issue, it's not "credit" you receive for participation in these activities, but it's "CRA consideration" that you receive. There is no numeric or dollar value placed on CD services. If you look at the recently issued guidance from the FBAs, they all refer to it as "CRA consideration" because not everything that a bank does relates to CRA.

You're absolutely right - I should have been more careful in my statement, I was using the term "credit" loosely fully understanding that all community development activities must pass the community development test. And while nothing qualifies automatically, some CD activities (properly documented)tend to be more "slam dunk" than other activities. Right or wrong, our CRA examiner did comment that the Money Smart program would qualify. It wasn't pursued at the time and I probably shouldn't have referenced it here. I just mentioned it as a comparision to the ABA's education program.

Actually, our examiner is quite strict and she told us that we would get credit/consideration for teaching Money Smart to ANY group, not just LMIs.

Yes, I am an FDIC bank and no it still does not make sense.

One of my problems is that I only have 7 schools with over 50% participation in free/reduced lunch programs and oddly enough they are all in upper or middle income census tracts.

Rie, I don't think it matters what tract they are in as long as you can show the kids qualify.

I tried using the arguement once (in jest) that all teaching to kids should qualify because the were all unemployed and poor. Besides, we were helping shape their future so they would know how to manage money when they grew up. Needless to say, it didn't fly with the examiners.
Someday the middle class will be broke because we never reached out to them.

Funny, we tried the same argument in our last exam. It didn't fly then either.

We really need to educate these examiners.

We just finished the FDIC CRA exam. They asked how many employees had participated in teaching the children, but did not ask anything about the census tract or income demographics of the schools. They indicated we would receive consideration for this program and they intended to include it in the written report.

That's great. Glad it worked out for you. I see enough difference between examiners we'll play it safe and be sure to include those schools we know have student populations exceeding 50% LMI.

Question - what kind of time commitment did this require for your employees?