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Question & Answer
Question: We are having a problem with CRA investments. There are almost no opportunities in our assessment area. Should we simply not make investments? Or should we make an investment outside our assessment area?
Answer: You don't really have a choice here. You need to have some investments that respond to the community development needs of your assessment area or a larger area that includes your investment area. Even if you can demonstrate that there is no investment opportunity in your assessment area (and we aren't sure that such a thing can be demonstrated to the satisfaction of an examiner) you are still on the hook for investments that would benefit community development needs in a larger area that includes your assessment area.
How do you justify these larger-area investments? Look for projects that may have an impact, either directly or indirectly, in your area. Take note of considerations such as where people live and work, and where service industries are located. You may find connections that you hadn't known were there. In the process, you may get additional ideas for your CRA program.
Copyright © 2000 Compliance Action. Originally appeared in Compliance Action, Vol. 5, No. 7, 7/00
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