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This opinion was issued in the third quarter of 1999.
The Division would consider a state-chartered institution's membership dues to the Massachusetts Community and Banking Council ("MCBC") a qualified investment under the Commonwealth's CRA statute provided the organization's activities benefit the institution's assessment area(s) or a broader statewide or regional area that includes the institution's assessment area(s). Further, the Division would consider a state-chartered institution's in-kind contribution to MCBC a qualified community development service as defined under 209 CMR 46.12. In making its determination the Division reviewed the applicable state regulations for evaluation of this proposal under the "investment test", set forth at 209 CMR 46.23(1) and the "service test", set forth at 209 CMR 46.24(1).