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#2261201 - 10/18/21 08:01 PM Digital Banking and How it Affects CRA
Compliance Nut Offline
100 Club
Joined: Feb 2016
Posts: 198
If a bank begins allowing deposit accounts to be opened online, how does this affect (negatively or positively) the bank's CRA performance?

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CRA
#2261229 - 10/19/21 03:16 PM Re: Digital Banking and How it Affects CRA Compliance Nut
Compliance Nut Offline
100 Club
Joined: Feb 2016
Posts: 198
bump

And also....if a bank receives a majority of its retail deposits from outside its assessment area, would this trigger the need to include that area in its delineated assessment area?

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#2261293 - 10/19/21 11:56 PM Re: Digital Banking and How it Affects CRA Compliance Nut
Rocky P Offline
Power Poster
Joined: Jun 2003
Posts: 7,650
Florida
Could be a close call depending on why the bank got the accounts. If they solicited/marketed in the area, it should be considered, especially if there is lending in the area. It might be different if there was no marketing, however, affluent tenants in the same location used the bank for convenience.

If there was concentrated lending, the bank might be subject to a fair lending review based on REMA
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