Answer:
I don't see how it would specifically help your CRA program if it is not a low- or moderate-income area. And if it is an area populated by the majority, vs. the minority, you do stand to be criticized if you provide special terms or pricing. This is a greater risk, in my opinion, if your assessment area includes a low- or moderate-income area that is also in need of revitalization. CRA focuses on this. If your program doesn't meet any of the criteria under Section 202.8(a), standards for special credit programs, I would participate but use your already competitive rates and terms.
First published on BankersOnline.com 8/15/05