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,

course, include the many advances for encrypting and filtering information. we may even see the deployment of technologies that permit individuals to make choices calibrating their degree of privacy in conducting individual transactions. with some irony, even some of the ability of the government to pursue protection of individual rights is being impaired by effective encryption. this leads to the important question of how to balance the legitimate expectations of individuals for privacy with the needs of government for information to effectively administer the laws and provide for the public safety. the most delicate care is needed in this regard to prevent unnecessary intrusion when specific government decisions are implemented and to avoid the risk of a gradual, long - term erosion of privacy. beyond these issues are immediate questions about privacy in the delivery of professional, commercial, and financial services over open computer networks as well as personal communications through devices such as e - mail. for example, there are typically strong assumptions about privacy surrounding medical, legal, and financial communications and records. these assumptions are designed to safeguard the autonomy of the individual and to facilitate a society where special expertise can be developed and called upon, when necessary, to promote the individual ’ s welfare. it would be a strange outcome, indeed, if traditional notions of privacy applied only at the physical office of the doctor, lawyer, or banker, but not when modern computer technologies were employed to make professional services available at lower cost and with greater convenience. it may be that some services and communications channels will be used regardless of what privacy guarantees are provided. providing medical advice by computer network to rural areas with no resident doctors may be one example. more common services, however, such as certain cellular telephone technologies and the use of e - mail over the internet, are subject to less privacy than some other modes of communication, although extensive efforts are currently being directed to address that. the growing use of credit cards without security measures to pay for goods and services over open networks is another example. clearly, as these examples demonstrate, privacy concerns may be outweighed, if only for the moment, by other factors such as cost and convenience. however, given choices in the marketplace that include price, quality and differing degrees of privacy, i have little doubt that privacy would be valued and sought after. in the financial sphere, the payment systems of the united states present a paradox. our systems, and banking arrangements, for handling high - value dollar payments are all electronic and have been for many years. banking records, including those for loans and deposits, have been