Understanding Community Development Needs through the CRA Performance Context

Author

Laura Choi and William Dowling

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December 8, 2014

Community development efforts to revitalize low- and moderate-income neighborhoods should begin with an appropriate understanding of the needs and opportunities present within these communities. This sentiment is especially true of banks looking to fulfill their Community Reinvestment Act (CRA) obligations. A truly responsive and innovative CRA program should begin with the “performance context,” or knowledge about the bank’s local markets, including the needs of the community as well as the opportunities that exist within the local network of resources and organizations. This paper attempts to demystify the performance context and establish its strategic value to the CRA process. It explores new opportunities for strengthening the performance context as a community development tool, from the perspective of both bankers and regulators.