Let me take a minute to highlight some of the key proposals addressed in the ANPR. First, we propose a CRA evaluation framework that incorporates the use of metrics and tailored standards that take into account differences across local communities and reflect differences in bank size and business model.
We heard feedback about the importance of separately evaluating retail and community development activities in order to capture the distinct importance of each type of activity in meeting community needs. Therefore, the ANPR proposes that large retail banks would be evaluated under two separate tests—a Retail Test and a Community Development Test.