Second, changes in the structure of the financial industry have resulted in many financial transactions that fell under the CRA umbrella in 1977 having become increasingly the province of nondepositories not subject to CRA, including companies owned by banks or bank holding companies.
Holding companies' nonbank affiliates, for instance, can be included in the CRA assessment of the banking institution at the discretion of the bank but need not be. Most mortgages are now packaged by brokers, and nearly two in three mortgages are originated by nondepositories not covered by the CRA.