Q: PPP CRA Services. Considering the challenge of providing in-person community development services during the COVID-19 pandemic, how will such services provided virtually by bank representatives be considered for CRA purposes?
A: Historically, for CRA purposes, bank representatives have primarily provided community development services in-person. However, the agencies recognize that the COVID-19 pandemic has limited banks’ ability to continue doing so. As an alternative to in-person services, the agencies will consider services provided virtually (e.g., Zoom, Microsoft Teams, WebEx, etc.) by bank representatives that have a primary purpose of community development and that are related to the provision of financial services. Examples of community development services provided virtually could include, but are not limited to, financial literacy programs or first-time homebuyer education sessions targeted to low- and moderate-income individuals and small business or small farm technical assistance sessions.
Community development services provided virtually are qualified individually, by each event conducted and in consideration of the assessment area(s) benefitted. Therefore, if a bank representative conducts a financial counseling session to help people affected by COVID-19 virtually for primarily low- and moderate-income individuals in a single assessment area, the bank will receive credit for one community development service for the assessment area. Of note, a community development service provided virtually that reaches multiple assessment areas should be considered at either the state or institution level. For example, if a bank representative conducts a small business technical assistance session that is virtually attended by businesses nationwide, the community development service will be considered at the institution level.
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.