Retail Test—Metrics for Retail Lending The core of the retail lending test would be to use widely available data to assess two clear objectives: how well a bank is serving LMI borrowers, small businesses, and small farms in its assessment area, and how well a bank is serving LMI neighborhoods in its assessment area.
The metrics used to evaluate these two questions would rely on loan counts rather than dollar value in order to avoid inadvertent biases in favor of fewer, higher-dollar value loans.