Q: CRA Credit for Assisting LMI Employees. Can a financial institution receive positive CRA consideration for assisting its LMI employees?
A: The CRA Statement discusses categories and examples of activities related to COVID-19 that will be given consideration under the CRA. Provided the financial institution’s employees are LMI and live within the financial institution’s assessment area or broader statewide or regional areas (for community development activities), the financial institution can receive CRA consideration for activities beyond the scope of the normal employment relationship that benefit the employees during this pandemic, given that those activities match the permissible retail or community development activities under the regulations and the interagency questions and answers related to CRA. Nothing in the guidance differentiates between LMI individuals who are non-employees of the bank and those who are employed at the financial institution. Consideration would be dependent on the activity on a case-by-case basis.
This Q&A was contained in the Frequently Asked Questions for Financial Institutions Affected by the Coronavirus Disease 2019 (Referred to as COVID-19) – As of March 3, 2021 (which may be updated from time to time). This may be found on the FDIC’s website here: https://www.fdic.gov/Coronavirus/faq-fi.pdf.