Any form of modernization of the Community Reinvestment Act must have measurable analysis of community value at the foundation, according to Jim Marous of The Financial Brand. A physical branch may not have any incremental value to a community — and in fact, may be detrimental — if it is open and empty, so long lending and investment in the community is strong. Costly, dormant overhead contributes little to local economies, and the OCC should recognize that. The Financial Brand
