Report Suggests ‘Internet Rating’ for Updated CRA Assessment Areas

In a new paper, Mark Willis with the Furman Center, suggests including an ‘Internet Rating’ in a modernized Community Reinvestment Act (CRA) framework since the current assessment areas used to delineate the primary geographies within a bank’s CRA test do not adequately account for the rise of internet banking. Under his proposal, banks would be separately evaluated for CRA performance within its assessment area(s), as well as beyond its assessment area(s), with the latter evaluation consisting of both a retail products test and a community development test. The results of these tests would then be blended together to arrive at the overall rating for the bank.