Accessible Version

Figure 1: HOLC Map of Atlanta 1938

Left Panel

Example of a Home Owners' Loan Corporation (HOLC) Map of Atlanta from 1938. Areas on the map are shaded for mortgage security. High level neighborhoods are grade “A” shaded in green meaning   minimal risk areas for banks for areas with safe investments. Areas shaded blue were grade "B", yellow areas were grade "C" and the areas shaded in red were considered a grade level of "D" and were considered hazardous for investing.

Right Panel

Historical form titled a “Form 8” with the Area Description of the security map of Atlanta, Georgia. The form lists the area characteristics such as description of terrain, favorable influences and detrimental influence, percentage of land improved, Inhabitants and their occupations, if they are foreign born, etc.

Source: Robert K. Nelson, LaDale Winling, Richard Marciano, Nathan Connolly, et al., “Mapping Inequality,” American Panorama, ed.,

Figure 2: Small Business Owners that Received Bank Funding in the Last Five Years

Small Business Owners Percent
Non-Hispanic White 46
Non-Hispanic Black 23
Hispanic 34

Figure 3: Evaluation Framework with Separate Retail and Community Development Tests

There are two panels Retail Test (left) and Community Development Test (right). The Retail Test panel contains two different sized text boxes. The larger box represents "Retail Lending Subtest - Retail Lending Metrics" and the smaller box represents "Retail Services Subtest - Qualitative Review of Delivery Systems and Deposit Products." The Community Development Test panel contains two different sized text boxes. The larger box represents "CD Financing Subtest - CD Financing Metric" and the smaller box represents "CD Services Subtest - Qualitative review."

Figure 4: Examples of Retail Lending Thresholds Based on Local Data


  Share of LMI families Share of mortages to LMI borrowers
Adams County, CO 48 56
Seminole County, FL 31 21

Source: American Community Survey 2013-2017 5-year average data, and Home Mortgage Disclosure Act 2017 data.

Figure 5: Community Development Loan & Investment Dollars-to-Deposit Ratios

Metropolitan vs. Non-Metropolitan Assessment Areas
Assessment Area Type Dollars-to-Deposit Ratios
Metropolitan 1.4%
Non-Metropolitan 0.9%
Two Example MSAs
City Dollars-to-Deposit Ratios
Little Rock, AR 1.1%
San Diego, CA 3.0%

Source: Board analysis of CRA Analytics Data Tables and Summary of Deposits data from 2014-2017. Additional details related to these calculations can be found in the ANPR.

Figure 6: Retail Lending Dashboard Example

CRA Retail Lending Dashboard
ABC Bank
Assessment Area: Any Town, USA
Product: Home Mortgage Lending
Evaluation Period: 2015 to 2018

Item Borrower Distribution Geographic Distribution
Current Threshold 26% 36%
Performance to Date 34% 39%
Difference +8% +3%

Note: presumption satisfactory

Last Update: September 21, 2020