Interagency Q&A .12(h) – 6: Must there be a benefit to the institution’s assessment area(s) to satisfy the regulations’ requirement that qualified investments & community devel. loans or services benefit an assessment area?

Compliance > Regulation BB - CRA
Q:  § __.12(h) – 6: Must there be some immediate or direct benefit to the institution’s assessment area(s) to satisfy the regulations’ requirement that qualified investments and community development loans or services benefit an institution’s assessment area(s) or a broader statewide or regional area that includes the institution’s assessment area(s)?
 
A:  No.  The regulations recognize that community development organizations and programs are efficient and effective ways for institutions to promote community development.  These organizations and programs often operate on a statewide or even multistate basis.  Therefore, an institution’s activity is considered a community development loan or service or a qualified investment if it supports an organization or activity that covers an area that is larger than, but includes, the institution’s assessment area(s).  The institution’s assessment area(s) need not receive an immediate or direct benefit from the institution’s participation in the organization or activity, provided that the purpose, mandate, or function of the organization or activity includes serving geographies or individuals located within the institution’s assessment area(s).
In addition, a retail institution will receive consideration for certain other community development activities.  These activities must benefit geographies or individuals located somewhere within a broader statewide or regional area that includes the institution’s assessment area(s).  Examiners will consider these activities even if they will not benefit the institution’s assessment area(s), as long as the institution has been responsive to community development needs and opportunities in its assessment area(s).
 
 
 
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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