Interagency Q&A .12(g) – 4: Can examples of community development (CD) activities discussed in a particular Q&A also apply to other types of CD activities not specifically discussed in that Q&A if they have a similar CD purpose?

Compliance > Regulation BB - CRA
Q:  § ___.12(g) – 4: Can examples of community development activities discussed in a particular Q&A also apply to other types of community development activities not specifically discussed in that Q&A if they have a similar community development purpose?
 
A:  Yes.  The Interagency Questions and Answers Regarding Community Reinvestment (Questions and Answers) provide examples of particular activities that may receive consideration as community development activities.  Because a particular Q&A often describes a single type of community development activity, such as a community development loan, the corresponding examples are of community development loans.  However, because community development loans, qualified investments, and community development services all must have a primary purpose of community development, a qualified investment or community development service that supports a community development purpose similar to the activity described in the context of the community development loan would likely receive consideration under the applicable test.  The same would be true if the community development activity described in a particular Q&A were a qualified investment or community development service.  For example, Q&A § __.12(h) – 1 provides an example of a community development loan to a not-for-profit organization supporting primarily low- or moderate-income housing needs.  Similarly, a grant to the same not-for-profit organization would be considered a qualified investment or technical assistance, such as writing a grant proposal for the not-for-profit organization, would be considered as a community development service.  Further if a financial institution engaged in all of these activities, each would be considered under the applicable test.  See Q&A § __.23(b) – 1.
Moreover, lists of examples included throughout the Questions and Answers are not exhaustive.  A Q&A may include examples to demonstrate activities that may qualify under that Q&A, but the examples are not the only activities that might qualify.  Financial institutions may submit information about activities they believe meet the definition of community development loan, qualified investment, or community development service to examiners for consideration.
 
 
 
This Interagency Q&A, and others, was released in July 2016.  The 2016 Q&As consolidates and supersedes all previously published “Interagency Questions and Answers Regarding Community Reinvestment,” and were noted as being effective immediately.  They may be found here:  http://www.ffiec.gov/cra/qnadoc.htm
 

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