Whether a State-Chartered Credit Union or Banking Institution's Participation in a Program Is a Qualified Activity under the Massachusetts Community Reinvestment Act ("CRA") - April 9, 2003By the Division of Banks
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April 9, 2003
Mr. Daniel J. Forte, President
Massachusetts Bankers Association
73 Tremont Street, Suite 306
Boston, Massachusetts 02108
Dear Mr. Forte:
This letter is written to formally clarify the Division of Banks' ("Division") treatment of a state-chartered bank's participation in the Federal Deposit Insurance Corporation's (FDIC) Money Smart financial literacy program under the Massachusetts Community Reinvestment Act, G. L. c.167, s.14, and 209 CMR 46.00 et seq., its implementing regulations.
The Money Smart program was developed by the FDIC to aid financial institutions and others interested in sponsoring and teaching financial education programs. The Money Smart curriculum helps individuals build financial confidence and use banking services effectively. Under 209 CMR 46.24 the Division evaluates an institution on the extent and innovativeness of its community development services. A community development service is defined as a service that is related to the provision of financial services. The FDIC Money Smart program provides lesson guides and teaching materials that can be used by a financial institution to bring financial literacy benefits.
Based on the above provisions and the nature and purpose of the Money Smart program, the Division would consider a state-chartered bank or credit union's participation in this program a qualified activity under the Massachusetts CRA.
Please distribute this letter's conclusions as to the CRA status of the Money Smart program to the Association's Massachusetts-chartered bank membership. This letter also will be posted on the Division's website entitled Selected Opinions for 2001-2003 ( www.mass.gov/dob/digest_new.htm).
The conclusions reached in this letter are based solely on the facts presented. Fact patterns that vary from that presented may result in a different position statement by the Division.
Very truly yours,
Thomas J. Curry
Commissioner of Banks