The current definition of a bank’s assessment area—the area in which a bank’s performance is assessed—relies on the area around its main branches and deposit-taking automated teller machines (ATMs), which includes a substantial portion of its lending. The internet was just becoming available for commercial use when the current assessment area regulations were finalized.
Since that time, technology and changing consumer preferences have led to banks gathering deposits and making loans well outside of their physical branches—for example, online and via mobile devices. So it is fair to ask whether the CRA’s current assessment area definition adequately reflects the community a bank serves today.