As a result, a larger mortgage loan would count the same as a smaller-dollar mortgage under the proposed metrics. We think this is important to avoid providing incentives to serve borrowers seeking to finance higher-priced homes at the expense of lower-income borrowers seeking finance for lower-priced homes.
Third, the ANPR proposes combining consideration of community development loans and qualified investments, including originations and purchases, into one metricsbased Community Development Financing Subtest. We believe this could encourage the provision of patient capital because both new originations and those already on the balance sheet would be included in the evaluation metric.