The regulators are looking for comments on proposed new and revised questions and answers. Particularly exciting is the consideration for delivery systems other than physical branches. We all need to review and comment.

Link to pdf

An encouraging statement from the discussion: "The Agencies agree with commenters that additional clarification of the extent to which alternative delivery systems will be considered is necessary in order to recognize an institution’s use of such systems to make products and services available to benefit low- and moderate-income geographies and individuals. Given the extent of technological innovation in the delivery of banking services, alternative delivery systems can create opportunities for institutions to better reach and serve low- and moderate-income geographies and individuals."

The proposed q and a include:

>Address alternative systems for delivering retail banking services.

>Add examples of innovative or flexible lending practices.

>Address community development-related issues by: (i) clarifying guidance on economic development; (ii) providing examples of community development loans and activities that are considered to revitalize or stabilize an underserved nonmetropolitan middle-income geography; and (iii) clarifying how community development services are evaluated.

>Offer guidance on how examiners evaluate the responsiveness and innovativeness of an institution’s loans, qualified investments, and community development services.

I often hear CRA referred to as "that soft stuff" and I have to laugh. It is "the soft stuff" that can bring a bank's growth plans to a screeching halt!

Of course, this still does not deal with the issue of assessment areas built around physical branches.

Just wondering.....how are they going to measure that alternative delivery systems (mobile banking) are serving LMI individuals and geographies? What data would a bank need to track in order to prove this?

That will be tough. Customer addresses can be geocoded for deposit accounts to get the geography.

If a customer has loans with your bank, you could use income to get to the borrower income class.

Or, just a thought, if someone has payroll direct deposited or regular deposits, you could run some numbers to make estimates.

You would want to download data and do this in a spreadsheet, not do the calculations one by one.

I would not use data like this for any government reporting, but for making a case for CRA credit, it just needs to be reasonable.