We are confident that there are ways to expand the area where we evaluate a bank’s CRA performance without losing the regulation’s focus on the unique role banks play in meeting local credit needs and providing services that are only possible by using branches.
Treasury’s recommendation that the agencies revisit the regulations to allow CRA consideration for a bank’s activities in its assessment area, as currently delineated around branches and deposit-taking automated teller machines, as well as in low- and moderateincome areas outside that branch footprint, is a reasonable place to start our interagency discussions. Second, banks should be encouraged to seek opportunities in areas that are underserved.