This has been known for a long time, but often housing cycles have occurred simultaneously with other events. For example, the housing downturn in the early 1990s occurred at the same time as the 90s recession. As a result, it can be difficult to fully isolate the direct effect of the housing market itself from the other forces at work.
We have heard general support for assessment areas that reflect each bank’s business model, recognizing that branch-based assessment areas work for many banks but that additional or different assessment areas may be appropriate for others. Third, we have received helpful input on tailoring CRA regulations to banks of different sizes and business models.