There is still room to improve CRA in this respect. A great deal of justification is required to demonstrate that certain activities qualify for consideration under the regulations. Much of this is related to the need to demonstrate a benefit to an institution's assessment area.
In order to simplify the regulation's approach to meeting the credit needs of lower-income areas, it may be necessary to consider a different way of measuring impact. Moreover, measuring performance for any institution must take a broad view of community needs, balancing quantitative measures of performance with consideration of the quality of the credit, investments, and services extended.