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#816648 - 09/17/07 07:28 PM Does a bank receive CRA Investment credit for....
up all night Offline
New Poster
Joined: Feb 2007
Posts: 14

Does a bank receive CRA Investment credit for....

(1) Forming a charitable foundation

(2) Receiving a Federal Home Loan Bank AHP grant/subsidy

Any Q&A or regulation reference would be appreciated.

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#816676 - 09/17/07 07:52 PM Re: Does a bank receive CRA Investment credit for.... up all night
Pale Rider Offline
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Joined: Aug 2002
Posts: 34,318
under the Lone Star
1) depends on the grants the foundation makes (they would have to be CRA eligible)

2) I doubt the bank is receiving the FHLB grant, but only the member of the FHLB sponsoring a non-profit, which is most likely the recipient of the grant from the FHLB - is this is the case, then "no", your bank can't get investment credit, but service credit
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#816764 - 09/17/07 08:58 PM Re: Does a bank receive CRA Investment credit for.... Pale Rider
bubs63 Offline
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Joined: May 2003
Posts: 665
Highland Park IL
I agree with Pale Rider. If it meets the definition of CD then you will get credit for it.
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#816834 - 09/17/07 09:59 PM Re: Does a bank receive CRA Investment credit for.... bubs63
Mrs. Rizzo Offline
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Joined: Mar 2006
Posts: 10,392
Curled up by the fire...
I've read a few PE's for other banks and they did in fact get credit for starting their own non-profit (Magyar Bank - Jersey and River City Bank in northern California are 2 for example). The credit given was the funds given by the bank to start the non-profit and keep it running annually. They also got services credit for the bank employees working the foundation.
One PE gave consideration for the CRA qualified grants by the foundation (even though they weren't given directly by the bank itself).
I'd look into checking out some PE's on the FDIC's website and do some research.

And the FHLB offers a lot of products that you can participate in...in this case, your bank is probably the go between for FHLB and the entity receiving the grant
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#816855 - 09/17/07 10:15 PM Re: Does a bank receive CRA Investment credit for.... Mrs. Rizzo
CRAatBOK Offline

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Joined: Mar 2004
Posts: 6,172
Further South than I wanna be.
"They also got services credit for the bank employees working the foundation."

I would watch this one especially if you have the OCC. We were not given service credit for our employees that work with our bank owned CDC. The examiners said because it was related to the bank it was part of our job. Of course they gave us credit in the past, just not at this exam.
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#816899 - 09/18/07 05:33 AM Re: Does a bank receive CRA Investment credit for.... CRAatBOK
Len S Offline
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Joined: Oct 2004
Posts: 2,130
Connecticut
We have had several bank clients who formed foundations for community development purposes and were given credit during their exams. It is important to make certain the foundation is funding qualified community organizations however.
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#817091 - 09/18/07 03:25 PM Re: Does a bank receive CRA Investment credit for.... Len S
bubs63 Offline
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bubs63
Joined: May 2003
Posts: 665
Highland Park IL
Anything that you do that qualifies as CD will get you credit, no matter how it is packaged or what you call it. A Good example is the FHLB. They have a number of programs that could qualify as CD. Being a member of the FHLB will not get you CD Credit.
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Bubs-

"truth does not occur in the database" - Actual search result on a goverment website

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