lmi borrowers and the percentage of loans to lmi neighborhoods. tailoring performance evaluations to bank size and business model the proposed separate subtests would also ensure expectations are tailored to the size and business models of different banks. it is important for smaller banks to be able to remain under - 11 the current more qualitative approach if they so choose. accordingly, small retail banks could continue to be evaluated under the current cra framework, but they would have the option to have their retail lending evaluated under the metrics - based retail lending subtest. small banks could also elect to have their retail services and community development activities evaluated. wholesale and limited purpose banks would be evaluated only on their community development activities. the anpr solicits feedback on options for additional tailoring and flexibility for these institutions, which do not lend themselves to evaluation under the same metrics that would be applicable to large retail banks. minimizing data collection and reporting burden the anpr seeks comment on striking an appropriate balance between providing greater certainty for how banks are assessed through the increased use of metrics and minimizing the associated data collection and reporting burden. in an effort to reduce burden, the proposed metrics would rely to the greatest extent possible on existing data collections and public data sources, and the approach would exempt small banks from deposit and certain other data collection requirements. large banks currently report community development loans at an aggregated level. a bank may also share information with its examiner on its community development loans and investments in a specific assessment area during a cra exam. however, the bank does not formally report data on these activities for each assessment area, nor are the data currently available through other sources. without reporting data more consistently to provide the basis for comparison, it would be difficult to measure and evaluate a large bank ’ s community development performance in a more consistent and predictable way. - 12 clarify and expand eligible cra activities to focus on communities the anpr proposes updating and clarifying which community development activities qualify in order to provide greater certainty to banks and communities about what counts. the anpr proposes to publish and regularly update an illustrative, but not necessarily exhaustive, list of qualifying activities. to provide additional certainty, the board also seeks feedback on a preapproval process, so that banks can propose a community development activity to their examiner to determine whether it will qualify before proceeding with the loan, investment, or service activity. this additional certainty could help promote greater investment by banks

finally, in considering how the cra ’ s purpose and history relate to the nation ’ s current challenges, the board seeks feedback on what other modifications and approaches would strengthen the cra regulation in addressing systemic inequities in credit access for minority individuals and communities. meeting the needs of lmi individuals and communities it is important for the cra to ensure that a wide range of lmi banking needs are met. we heard from stakeholder feedback that both retail and community development activities are - 7important in meeting lmi banking needs. accordingly, we propose to assess large retail banks using a separate retail test and a community development test with separate financing and services subtests ( figure 3 ). separate assessments of retail lending, retail services, community development financing, and community development services will support robust bank engagement with communities through a variety of channels. stakeholder feedback has highlighted that each of these areas is essential to lmi communities. the standalone retail lending test is important to stay true to the cra ’ s core focus on providing credit in underserved communities. retail lending is the channel through which a family can get a mortgage to buy its first house and an entrepreneur can get a loan for a small business. retail services are the channel through which an lmi household might get access to essential services from a local bank branch, such as a low - cost checking account. community development financing captures bank lending and investments that create and maintain affordable housing, promote economic development, and revitalize and stabilize lmi communities. community development services include financial counseling for low - income families and important volunteer activities undertaken by bank staff, such as serving on the board of a local nonprofit. some of these activities lend themselves primarily to a qualitative review. for example, the anpr highlights essential banking services that are responsive to community needs, such as customer support that is provided in multiple languages and flexible branch hours to accommodate lmi customers ’ work schedules. although we concluded that the value of services to a local community does not lend itself easily to a monetary value metric, the anpr proposes introducing quantitative benchmarks where appropriate, such as indicators of whether branch locations are maintained or increased in underserved areas. - 8addressing changes in the banking industry the anpr proposes to modernize cra assessment areas in recognition that reliance on mobile and internet banking has increased in the 25 years since the cra regulation was last substantially revised. the anpr still maintains a focus on branches, given