most or all of their retail activity online to identify states in which they have a significant level of deposits, lending, or other banking activity in which they would have obligations under either the retail or community development test, as appropriate. consistency and predictability there was also wide support for making cra definitions and evaluation criteria clearer and taking other actions to improve the consistent and predictable application of the regulations during evaluations. perhaps more important, the commenters strongly supported the agencies continuing the tradition of working together to have one set of rules, consistent interpretive guidance, and regular examiner training to ensure that the cra is implemented as consistently as possible both within and across the agencies. at the federal reserve, we agree that it is important for the banking agencies to take a consistent approach. metrics finally, there was broad support for expanding the use of metrics in cra evaluations, where appropriate, especially if they are clearly articulated, are used in tandem with performance 5 / 7 bis central bankers'speeches context information, and add to the transparency of cra ratings. we recognize that effective and predictable evaluations rely on good metrics. metrics, in turn, require good data. currently, cra evaluations use hmda data, which are very useful in understanding where mortgages are made, to whom, and at what cost. moreover, hmda data are collected from both banks and non - bank mortgage lenders. but the data collected under cra to support our analysis of small business and small farm loans are not as comprehensive as mortgage lending data. the dodd - frank wall street reform and consumer protection act charges the consumer financial protection bureau with promulgating regulations for the collection of small business loans, and that data should be very helpful when they become available. separately, the data collected under the cra on community development loans are not adequate to support the analysis of a separate community development test, so it may be necessary to consider a better reporting system. collecting data and developing clear metrics will provide the improved clarity and ex ante predictability that banks seek. more and better data will allow for more meaningful metrics by which we can evaluate performance criteria, such as the borrower and geographic distribution of lending and how a bank ’ s performance compares with other similarly situated banks. we may also consider providing more baseline information that describes a bank ’ s performance context, such as the demographic and economic information that helps to describe the credit needs and opportunities present in each assessment area. in addition,

in a community where residents currently must drive an hour to reach a grocery store. in examining a list of all the project funders, it was noticeable that there were active financing commitments from many foundations, but no banks. although this is likely to be a very impactful investment, there is only one bank currently whose assessment area may extend to pine ridge. in contrast, under the proposed community development assessment area approach, more of the banks with branches in aberdeen, south dakota, for instance, might be inclined to make such a community development loan with confidence it would get cra consideration. by creating separate assessment areas for retail and community development activities, we believe that banks would continue to place their community at the center of their retail lending and service activities while participating in meaningful community development opportunities that may have greater impact due to their broader reach. evaluating community development performance : what counts in reflecting on the comments, listening sessions, and research conference, we have also been contemplating approaches to what community development activities count in order to provide greater predictability and better incentives. banks and community organizations have noted that the current structure of the large bank performance tests may actually hinder community development financing in a couple of ways. first, under the existing approach, community development loans are considered in the lending test, while community development investments are considered in a separate test. a number of banks and community organizations argue that the form of community financing may be influenced more by the structure of the cra performance tests than by what makes the most sense for the project. for example, if a bank is concerned about passing its lending test, it might structure financing as a loan rather than an investment to beef up its lending test performance even if an investment would be more effective. second, a number of banks and community organizations pressed the case for giving cra consideration to any community development loan outstanding, rather than only those originated since the bank ’ s last cra evaluation. under the current rule, banks often make short - term, renewable community development loans simply to ensure that the incremental lending receives cra consideration at each examination. by contrast, when it comes to investments, all investments on the bank ’ s books at the time of the evaluation are given consideration. banks and community organizations alike make a compelling argument that all types of community development finance, whether in the form of a loan or an investment, have greater impact when they serve as patient, reliable, committed sources of financing. one possible approach to address these distortions and provide more