For example, in Morgan County, Ohio, LMI families are 49 percent of the population, compared with 31 percent in O’Brien County, Iowa (figure 4). We believe this tailored approach is empirically sound and avoids imposing arbitrary CRA performance measures on a bank and its community.
In order to ensure it meets standards of safety and soundness, CRA lending must be evaluated in the context of the characteristics of the bank and its community. Additionally, the proposed retail lending metric would automatically adjust to changes in the business cycle.