In October, the OCC, FDIC and Federal Reserve Board issued a final rule to mark their collective commitment to upholding the Community Reinvestment Act (CRA), which helps ensure underserved groups are given fair opportunities to access banking services. 

The final rule is more of a re-up than an update. The agencies are sending a loud and clear message that reinvestment efforts are an ongoing priority and part of a long-term vision to interweave banks’ success with the success of their communities. 

In other words, if your bank’s marketing plan doesn’t currently take a holistic approach to CRA activities, it’s time to rethink your strategy. 


Two CRA mistakes bank managers make 

In our experience, bank managers tend to misstep in two primary ways when it comes to CRA marketing:

  1. They get stuck looking through a “compliance” lens, just ticking boxes to keep the regulators happy. 
  2. They compartmentalize community reinvestment efforts, treating them as a marketing tack-on. 

 Your bank might be prone to ticking, tacking, or both — one error tends to flow into the other.  

 But as a long-term strategy, these methods are overly complicated at best. At worst, they may be totally ineffective, and may also feel disingenuous to your team and to your customers. 

Can we invite you to step off this ill-fated path? There’s a better and simpler way forward. 


Well-designed mobile marketing is CRA marketing

Here’s what happens whenever we build out a mobile marketing plan for a banking client: That bank either serves their community’s low- and middle-income (LMI) demographics by default, or they’re completely set up to do so.  

That’s because mobile marketing targets smartphone users, and smartphone usage is nearly as high for LMI individuals and geographies as it is for any other demographic: In 2021, 76% of U.S. adults with an annual household income under $30,000 owned a smartphone, and that percentage jumped up to 84% for incomes between $30,000 and $75,000. These numbers are only growing. 

 If people from all demographics use smartphones, and your bank’s assessment area represents many different demographics, there’s only one missing piece of information: Which phones registered in your assessment area should you send your ads to? 

Figuring out the answer to that question requires narrowing down your assessment area. Instead of focusing on two metro areas, focus on one. Instead of a city, what about a zip code? 

Companies that can utilize data and target advertisements at geographic locations as specific as U.S. Census tracts are invaluable. These campaign strategies differ significantly from general display advertising and require an experienced team.


Census tract-level LMI data completes the puzzle   

If your bank wants to prioritize reaching customers in specific demographics, the most efficient way to do so is by analyzing census tract-level data. This data can show you exactly which percentage of people within a census tracts belong to the groups you want to reach.  

For example, if you’re trying to find qualified borrowers within a predominantly LMI assessment area, you can identify and target accordingly. Or, if you want to provide financial education services to an underrepresented ethnic group, you can target the tracts where those individuals are more likely to live. 

We know these are simple use cases. Your actual assessment area likely has many local idiosyncrasies and complexities — along with layers of internal and external oversight — that require a custom approach.  

With that in mind, we’ve assembled the following: a short list of common CRA-related pain points, along with ways a skilled mobile marketing  team can help you make progress toward solving them. 


Mobile marketing solutions to common CRA challenges


 “We don’t know where our customers are.”

Regulators want you to know where your customers are located, within and beyond facility-based assessment areas. 

And guess what? An experienced mobile marketing team knows exactly how to target qualified borrowers during the 4-5 hours per day they spend on mobile apps. 

In a single decade, the way in which we consume media has shifted dramatically. Everyday mobile use has skyrocketed, underscoring the move away from offline media.

In other words, you don’t have to know where customers physically spend their time, because you already know where to find them: on their phones. 

But, since assessment areas matter, we also know how to find your customers on a map. Which leads us to… 


“We can’t spend money on advertising to unqualified borrowers.”

 Banks don’t have endless resources, yet they’re being asked to increase marketing spend in areas where there are fewer qualified borrowers.  

With hyperlocal targeting, banks can allocate budgets, ad spend, and KPI measurements based on census tract to target LMI neighborhoods and qualified LMI customers. This reduces your risk and increases your ROI by helping you target exactly the right people at the right time.  

LMI Tract Targeting


“There’s too much data to collect and report.”

Collecting and reporting on deep streams of data is overwhelming, and probably impossible at some point… for people. That’s why mobile marketing teams use algorithms and data-reporting tools to automagically extract the data your managers and auditors need — including engagement details such as clicks, impressions, click-through rates and conversions — for specific demographics, within specific census tracts in your assessment area. At RAIN, we compile this data into monthly reports for clients to make it even easier to interpret. 

Sample of CRA KPI Per Tract


“We have to keep re-creating our ads because of new regulations.” 

Bank ads are supposed to captivate audiences, center diversity, represent your bank’s brand and voice, describe products and services accurately, and feature all the right regulatory logos and legal copy. Oh, and they should also be placed strategically, which includes re-creating them in multiple sizes to meet the requirements of different advertising spaces. Does this checklist sound familiar? 

Outsourcing this task can save you tons of time and energy. Creatives who specialize in mobile marketing for banks are experts at producing impactful, inclusive, compliant advertisements that are true to your company’s brand. These teams also have streamlined processes for placing ads where your target audience is most likely to interact with them — including re-sizing for different formats.  

“We’ve advertised in all the right places, but we’re not hitting our targets.” 

OK, let’s troubleshoot. How sure are you that you’ve advertised in the right places?  

Unlike billboards and other wide-net strategies, custom mobile ad campaigns can target neighborhood-level data through individual census tracts. If you haven’t tried mobile advertising, you might be surprised how much running a well-designed campaign can help.  

No matter how simple or complex your assessment area is, experienced mobile marketers can review it, zero in on your target audience, and deliver your ads right into their hands. Size doesn’t matter: Our team has targeted areas for clients with as few as 19 tracts and as many as 2,500.  

And if you’re still not seeing the results you want? We can say with confidence: Your efforts aren’t a wasted investment — not for your bank’s growth, and not for your CRA rating.  


CRA beyond the numbers 

That’s because robust, data-driven mobile marketing campaigns can deliver two essentials: 

  1. Deep insights into your target audiences’ characteristics and behavior, thanks to the heaps of information these campaigns provide. This data can satisfy the most ambitious internal reporting directives — but, more importantly, it will allow your bank to make well-informed decisions and develop effective, evidence-based strategies. 
  2. Conclusive evidence of engagement (and efforts to engage) with your customers. The same data will establish your bank as one that truly cares about making your products and services helpful and accessible — and that’s the spirit of community reinvestment. CRA rules reward good effort by measuring performance relative to community and peer-reported data. With the vast quantities of data mobile marketing produces, you’ll have no problem demonstrating your due diligence. 


The future is inclusive, data-driven and mobile 

Mobile marketing makes CRA compliance incredibly simple, effective and affordable by targeting the specific census tracts you want to reach, educate, serve, sell or lend to.  

This will remain true even as banks’ customer bases become more diverse and less tied to physical branch locations. Thanks to unprecedented technology access across demographics, the tools available to you for a complete marketing strategy today can also help you grow and serve your community, now and in the future. 

Growth and community reinvestment don’t have to be separate goals.  

The strategies RAIN has pioneered to help banks market to an increasingly mobile world also help banks connect with and serve their communities, fulfilling CRA requirements organically and authentically.  


Connect with us to learn more.