This is important because banks are uniquely situated to evaluate the community development finance projects in the states where they operate and to provide the smaller, more complex, and often more impactful, investments that don’t attract institutional investors.
If banks cannot be confident ex ante that they will get the benefit of CRA consideration for these efforts, which may be timeconsuming to evaluate and structure, it is not surprising they would instead gravitate toward activities they know will count.5 In addition to these broad changes to what and how community development activities should be counted, we recognize there are several definitional issues that merit consideration.