The Federal banking agencies requested comment on September 4 on proposed revisions to the Interagency Questions and Answers Regarding Community Reinvestment to address alternative systems for delivering retail banking services. The proposed questions and answers would add examples of innovative or flexible lending practices and provide guidance on community development-related issues. Comments on the proposed questions and answers are due by November 10, 2014.

     Nutter Notes: Among other things, the proposed CRA questions and answers would describe the factors considered by examiners when evaluating the effectiveness of an institution’s systems for delivering retail banking services. Such factors include convenient access to full-service branches and effective alternatives, such as ATMs, online banking and mobile banking. The proposed questions and answers would also provide guidance on how examiners evaluate the responsiveness and innovativeness of an institution’s loans, qualified investments, and community development services.