Last week (10/17), I participated in Jack’s webinar on Identifying and Documenting CRA Community Development Activities. One of the things that struck me was the suggestion to have a Board resolution or have something in the minutes that recognizes the Board and employees PERSONAL charitable activities “on behalf of” our bank. Of course, the notes I made were totally logical at the time… Will you please share that suggestion again?
§ 345.12(i)–2: Are personal charitable activities provided by an institution’s employees or directors outside the ordinary course of their employment considered community development services?
A2. No. Services must be provided as a representative of the institution. For example, if a financial institution’s director, on her own time and not as a representative of the institution, volunteers one evening a week at a local community development corporation’s financial counseling program, the institution may not consider this activity a community development service.
We are suggesting that you assure that such activities are done as a representative of the institution. A board resolution stating appreciation for the services of Director Soandso as a representative of XYZ bank in connection with the ABC Community Development Corporation should provide appropriate documentation.