CRA Performance Context: Why it is Important for Community Development and How to Improve it

Josh Silver

This white paper explains performance context analysis and explains why it is important from a community perspective. It first discusses the definition of performance context referencing CRA regulatory documents. Second, it reviews current thinking regarding the implementation of performance context analysis. While the thinking has evolved, the federal agency implementation is still centered too much on the banks and not enough on the community perspective. Third, the paper will review examples of both poor and good performance context analysis in CRA exams. Fourth, the paper will offer some examples of data analysis and community group input that provides a foundation for improved performance context analysis. 

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