Streamlining the CRA regulations and clarifying the performance measures could create stronger incentives for  -8-  banks to pursue the less obvious, but potentially more impactful, projects that low- and moderate-income neighborhoods need the most to become areas of opportunity.
We will want to update the CRA in ways that reduce the distortions that lead to some areas becoming credit “hot spots” and others credit deserts. Where there is a high density of banks relative to investment opportunities, the result of too many banks competing for too few CRA-qualified investments can be declining returns.