First, for some institutions the concept of the "local community" is no longer as clear as it was when the CRA was enacted. Today, some institutions are not identified with a particular community but are regional or national in scope, which inevitably makes the definition of the relevant assessment areas somewhat difficult.
Moreover, to an increasing extent, banks use nontraditional avenues--the Internet, for example--to interact with customers, in some cases avoiding a bricks-and-mortar presence altogether. To date, defining "local community" for the purposes of CRA assessment has been manageable as most banks still lend in local communities where they have deposit-taking facilities or branches.