Q: § __.12(i) – 3: What are examples of community development services?
A: Examples of community development services include, but are not limited to, the following:
• Providing technical assistance on financial matters to nonprofit, tribal, or government organizations serving low- and moderate-income housing or economic revitalization and development needs;
• Providing technical assistance on financial matters to small businesses or community development organizations, including organizations and individuals who apply for loans or grants under the Federal Home Loan Banks’ (FHLB) Affordable Housing Program;
• Lending employees to provide financial services for organizations facilitating affordable housing construction and rehabilitation or development of affordable housing;
• Providing credit counseling, home-buyer and home maintenance counseling, financial planning or other financial services education to promote community development and affordable housing, including credit counseling to assist low- or moderate-income borrowers in avoiding foreclosure on their homes;
• Establishing school savings programs or developing or teaching financial education or literacy curricula for low- or moderate-income individuals; and
• Providing foreclosure prevention programs to low- or moderate-income homeowners who are facing foreclosure on their primary residence with the objective of providing affordable, sustainable, long-term loan modifications and restructurings.
Examples of technical assistance activities that are related to the provision of financial services and that might be provided to community development organizations include
• serving on the board of directors;
• serving on a loan review committee;
• developing loan application and underwriting standards;
• developing loan-processing systems;
• developing secondary market vehicles or programs;
• assisting in marketing financial services, including development of advertising and promotions, publications, workshops and conferences;
• furnishing financial services training for staff and management;
• contributing accounting/bookkeeping services;
• assisting in fund raising, including soliciting or arranging investments; and
• providing services reflecting a financial institution’s employees’ areas of expertise at the institution, such as human resources, information technology, and legal services.
Refer to Q&A § __.24(a) – 1 for information about how retail services are evaluated under the large institution service test.
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