Can anyone give examples of:

1. investments are considered to be innovative or complex.
2. how the bank can exhibit a leadership role for investments

I hate to assume we are not doing them just because I don't know that they are. Fingers crossed!!!

You may want to look at this link https://philadelphiafed.org/egmp/publications/banks-community-reinvestment-act-opportunities

Use the drop down box to filter for investments. Then use the find function to locate the words "innovative" or "complex". Seems as a good number are related to the use of low-income housing tax credits (LIHTCs).