Bankers and other commenters have emphasized the high value that bank branches have for retail customers and small business owners in underserved communities, and research corroborates this. Similar to banks, community organization commenters support updating the CRA regulations as they relate to a bank’s assessment area.
They suggest retaining assessment areas around a bank’s branches in order to retain the CRA’s focus on local low- and moderate-income neighborhoods, while adding areas where banks conduct significant activity without branches. Both bank and community organization commenters were open to having a larger area defined for the purposes of pursuing meaningful community development activities, particularly in cases where banks operate largely without branches.