The problem is even more acute when the law is applied to the growing number of "virtual banks" that operate only through phone lines or over the Internet.
If a virtual bank can satisfy its responsibilities by lending in any lower-income area, the direct community involvement so prized by neighborhood groups will be lost.
One possible solution is to provide credit under the Community Reinvestment Act to a virtual bank that establishes operations in a lower-income neighborhood.
A virtual bank is also a common feature, in which users can deposit currency and gain interest on it over time.
The initial success of internet banking services provided by traditional banks led to the development of internet-only banks or "virtual banks".
The aftershocks of this collapse caused severe liquidity problems for other virtual "banks", which critics had long asserted were scams.
Bank One is making a big Internet push, both with its own Web site and by opening a virtual bank last June, Wingspan.com.
CashPool is a cooperation of smaller private banks (including many virtual banks), which mutually waive the fees.
Predictions like this, despite all the talk of Microsoft's cooperative demeanor, make bankers worry that software and computer companies want to be virtual banks.
It's strictly an information-based function that you really no longer have to pay for if you choose to create an internal, virtual bank.