A non-profit organization that our bank has supported in the past recently approached me and asked whether I would like to serve as a member of their Board. Here's the problem. I am the Bank's CRA Officer and I have been told that if CRA Officers maintain a board position with a non-profit organization, then the regulators ( in our case FDIC, because we are a state chartered bank) would provide very little if any CRA credit, because they would prefer bank officers or branch managers to serve on such boards rather than the the CRA Officer. Can anyone verify whether this is fact? I have no idea, because I've only been in CRA at my bank for 1 year and 3 months. Your feedback is greatly appreciated. If anyone know of a contact person at the FDIC out on the West Coast who can perhaps speak to this that would be great.

Regards,

I have never heard that. FWIW, we received credit during our last exam (earlier this year) for our CRA Officer holding a board position at a qualified non-profit. We are FDIC regulated.

This could be a quirk with your examiners. I am the CRA officer and serve on a number of boards and get credit for my time. While it might be nice if upper management served on more of these boards chances are it ain't gonna happen.

Actually that comment reminds me of when an examiner told me we won't get as much credit for doing financial education to youth instead of adults because it was more important for adults. I told them that our plan was to prevent the problems adults already have by being proactive. Duh.

bunk!

our CRA people serve on many boards and all are considered in the service test

Great! Based on the responses I've received so far, it sounds unanimous that a CRA Officer will receive credit for serving on a Board of a non-profit organization.

Regards,

I'm on the west coast...FDIC regulated...and we document all of our employees services (CRA qualified or not) and say our employees do X amount of community services each year and XX are CRA qualified...if the service is something that benefits LMI's then we get credit if it is on BANK time and is BANKING related (i.e. serving on a board making financial decisions, technical support). For our exempt employees (salary) we were given credit for all hours served where the employee represented the bank (since they aren't hourly and "bank time" is your entire life )

If you would like a contact, PM me.

That is such an odd comment. The CRA Officer is a bank officer. Do they think the CRA Officer knows less about banking and financial matters than other bank officers? I would be insulted.

I would clearly document any and all time spent by the CRA Officer. Present a strong case with documentation of types of advice, etc.

Many of our bank client CRA officers are active in Community services and I have never seen their bank denied credit for their services. There is no restriction for CRA Officer activty written into the Reg and there is no restriction explained in the Q&A's either.