I have always said that community activist organizations may be more of a problem than examiners with respect to CRA. There is evidence that these groups are becoming more active and more sophisticated in the use of CRA and HMDA to put more pressure on banks. Check out this CRA performance evaluation CRA Performance Review and Criticism developed by Empire Justice on a bank in the Rochester NY area. In today's hyper-charged political environment many bankers may find themselves undergoing intense CRA performance scrutiny by other community activist groups.

About 5 years ago we received a phone call from a Connecticut bank that had just received a similar sophisticated analysis that attempted to embarrass the bank. We had to develop a very thorough market analysis to rebut the criticism and show how the community organization's analysis was unfair and unbalanced. Around the same time, New Haven Savings Bank which had received 5 consecutive "outstanding" CRA performance ratings had a merger delayed by community groups misusing CRA and HMDA data to criticize bank performance. I wonder how many BOL readers may have been confronted with a critical CRA performance analysis by a community organization?