Ask a CSR Friend: Capturing Employee Volunteer Hours for CRA (Community Reinvestment Act) Compliance

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Dear CSR Friend,

I recently started a new job leading the employee volunteer program at a regional bank and am starting to learn all about the Community Reinvestment Act (CRA). The organization has a proud history of service and engagement in the local community; however, we don’t have a consistent system for tracking employee volunteer efforts. Our compliance team has been requesting more data in preparation for our CRA exam and while I want to make sure we’re capturing and reporting all the right information, I’m not sure where to start. What do I need to know to ensure our volunteer efforts qualify and are tracked appropriately to meet the CRA “service” test?

Curious in Cleveland

Dear Curious,

First, some good news is that CRA compliance and community engagement aren’t at odds. The same volunteer hours that uplift local communities can also help your institution demonstrate measurable impact to regulators.

Also, you’re not alone in figuring this out. In fact, Benevity’s 2025 State of Corporate Purpose shares data showing that 32% of large enterprises are focused on volunteering that counts toward regulatory requirements. Many financial institutions recognize that employee volunteer programs can directly support CRA objectives, but they often struggle to connect the dots between community impact work and compliance. So, let’s break down what you need to know, step-by-step.

What exactly is the Community Reinvestment Act?

The Community Reinvestment Act (CRA), enacted in the US in 1977, encourages financial institutions to meet the credit and service needs of the communities they serve, particularly low- and moderate-income (LMI) neighborhoods. The regulations were updated in 2023 to reflect changes in how financial institutions engage communities, including recognition of digital delivery channels and more detailed guidance on community development services. These updates reinforce the importance of documenting how volunteer activities support community development, especially when tied to financial capability or economic inclusion.

As the Federal Reserve’s CRA overview explains, CRA evaluations consider how institutions help strengthen local communities, including through volunteer service. The OCC’s list of qualifying activities offers a wide range examples of previously approved activities such as:

• Mentoring students in LMI neighborhoods
• Helping low-income individuals prepare tax returns
• Serving meals at homeless shelters

What do I need to track for volunteer service?

Since regulators review several factors related to the community development services a financial institution provides, it’s important to focus on tracking volunteer activities to:

• Document your institution’s commitment to community development
• Identify how service aligns with your CRA assessment areas
• Strengthen your CRA narrative with quantifiable, verified activity data
• Connect your CRA performance with your broader CSR or ESG goals

Even beyond compliance, strong tracking practices let you celebrate your employees’ impact, measure engagement, and share stories that resonate with stakeholders.

Here’s one of the biggest lessons I’ve learned: capture everything first, evaluate later. Institutions can miss CRA credit opportunities simply because they don’t collect complete data. While not every volunteer activity qualifies, collecting all volunteer hours ensures you can later analyze and categorize them correctly.

Encourage employees to log all service, including:

• Skills-based volunteering (mentoring, financial coaching, consulting)
• Traditional hands-on volunteering
• Board or committee service for community organizations
• Virtual or hybrid volunteering opportunities

When logging time, ask employees to record:

• Organization name and mission
• Type of activity and skills used
• Location or community served
• Hours volunteered

How do I analyze volunteer activities?

Use a CRA lens when evaluating activities:

• Does it primarily benefit LMI individuals or communities?
• Is it tied to financial capability, community development, or economic empowerment?
• Can we document the location, beneficiaries, and skills used?

Your CRA or CSR team can then review submissions to determine which qualify under CRA standards. Over time, this approach builds a rich dataset that supports both compliance and storytelling.

You don’t have to reinvent the wheel! If you’re partnering with a CSR platform provider, connect with them to learn more about their tracking capabilities, as they’ve likely had experience working with other financial industry clients that are focused on CRA compliance.

And don’t forget to partner early with your compliance team. When they understand your volunteer programs and you understand their reporting needs, CRA documentation becomes a shared win, not a last-minute scramble.

What’s the bottom line?

Tracking volunteer hours for CRA compliance isn’t just a regulatory exercise; it’s your chance to show how your employees’ time and talent drive community progress. By clearly defining what qualifies, capturing all service, and keeping consistent data, you’ll strengthen both your CRA performance and your culture of service.

Until next time,
Your CSR Friend

P.S. In case you still have more questions or need additional resources, I’ve found these to be helpful!

• Federal Reserve: About the CRA — Overview of CRA goals and evaluation methods
• OCC: Illustrative List of Qualifying Activities — Examples of community development services
• Bonterra: Breaking Down CRA Requirements — A breakdown of CRA compliance for CSR professionals
• YourCause: Qualifying for Community Reinvestment Act Services — How to ensure volunteerism meets CRA standards
• Benevity: Measuring the Business Impact of CSR — Insights on volunteerism and regulatory goals

If you need help strategizing ways to engage your employees in support of your community, Points of Light’s Consulting team is here to help and the Corporate Service Council member network is a great way to engage your peers in conversation on vital topics like this.Still have questions? Don’t forget you can always ask a CSR friend!