Does a lending insitution enhance its CRA rating through active support of fair housing enforcement organinations--i.e, purchase of a membership and participation on their governing boards?

-- Robert W. Adams (badams@wright.edu), July 20, 1998

Answers

In my opinion, it depends on the activities of the fair housing enforcement organization. If the organization provides homeownership counseling or home loan referrals, particularly for low- or moderate- income homebuyers, and a lender subject to CRA (large institution) assists in these activities, they should receive CRA consideration under the Service Test and the Lending Test (for loans originated). Any funds to the organization to support these activities, should be given credit under the Investment Test. Lastly, board membership should receive consideration under the Service Test--especially if serving on a subcommittee that helps further educate the community about various loan programs.

-- Greg Matthews (gmmfserv@aol.com), February 14, 1999.