I particularly want to emphasize that disclosure need not be in a standard accounting framework or exactly the same for all organizations. Rather, each entity should disclose the information its stakeholders need to best evaluate the entity's risk profile. Companies should be less concerned about the vehicle of disclosure and more concerned about the substance of the information made available to the public.
There is still room to improve CRA in this respect. A great deal of justification is required to demonstrate that certain activities qualify for consideration under the regulations. Much of this is related to the need to demonstrate a benefit to an institution's assessment area.