Fourth and finally, the strategy of an institution should be forward looking: The risk control framework should look “through the cycle” and in particular identify and seek to mitigate the risks associated with pro-cyclicality – that is the exaggeration of the peaks and troughs of the natural economic cycle.
Commenters across the board applauded the significant volume of CRA loans and investments that have supported LMI households and communities, as well as the benefits households and communities have realized from the CRA’s focus on local retail financial services, small business lending, and community development lending, investments, and services.