Measuring social impact appears daunting. Many CRA-obligated institutions are trying to comply with regulations that they provide banking services (beyond deposit) to low-and middle-income communities. Few want to be held accountable for outcomes beyond their control when they are contributing just one piece to a larger effort, and most lack the capacity to assess social impacts in a meaningful way on their own. Yet although the reluctance of CRA-obligated institutions to wade into this area is understandable, business as usual—that is, calling lending “impact investing” without targeting or measuring impacts—is not a particularly defensible option.