Changes in the Regulatory Framework of the Community Reinvestment Act (CRA)

Attacks on the Community Reinvestment Act over the years have generally ranged from being without evidence to partisan lunacy.
Nevertheless, while the broad goals of the CRA are as important as they were forty years ago, the implementation of those goals needs to be revised to fit today’s world.  
Banking has gone national and whatever portion of consumer finance is not online soon will be. The once dominant banking model of small local and regional bricks and mortar banks serving local communities is becoming obsolete due to technology, data and the fact that households with greater mobility and FaceBook based relationships have far less connection to the areas they live in and local institutions.
After years of discussion, the OCC and FDIC announced in December a new CRA regulatory framework. New mobile banks often have little interaction with the communities where their offices are physically located. The new regulatory framework recognises this  and takes an approach of assessing a bank’s community investing, lending and contributions in areas where banks conduct a substantial volume of retail lending and deposit-taking - even if they have no physical presence in the area.
It remains to be seen exactly what will change with CRA regulations. What’s important is that we are beginning to see significant shifts in policy and regulation to respond to the rapidly changing landscape of inclusive finance and the impact of technology.