Most banks recognize that their enterprises can only thrive if their customers do, too. Partnering with local organizations to promote the health of their economic communities is often a top priority for banks. In recent years, financial institutions have faced increasing regulations regarding their efforts to serve the needs of diverse communities.
The Community Reinvestment Act (CRA) ensures banks provide fair access to credit and other financial services to help meet the needs of the communities in which they operate, including low- and moderate-income communities, consistent with safe and sound operations.
OCC–FDIC propose targeted changes to community reinvestment act rules
The Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) have proposed a targeted update to their Community Reinvestment Act (CRA) regulations. The proposal aims to focus CRA evaluations more heavily on lending, clarify which activities qualify for CRA consideration, and reduce compliance burdens for some banks.
The proposal was published on August 12, 2026, and comments are due October 13. It is not a final rule. For now, the agencies continue to apply the CRA rules in effect before the enjoined 2023 modernization rule—generally, the 1995 framework.
Key proposed changes in 2026
Higher asset thresholds
The proposal would raise the threshold for small banks to $1 billion in assets, from $412 million, and set the intermediate-bank threshold at $10 billion, up from $1.65 billion. Banks between $1.65 billion and $10 billion would move out of the large-bank category and, under the proposal, would no longer be subject to large-bank CRA data collection and reporting requirements.
Greater emphasis on lending
The agencies would narrow the retail services considered in CRA evaluations to focus on credit services, excluding deposit services. The proposal would also give greater weight to activities connected to lending and focus evaluations on a bank’s major product lines.
New limits and documentation for community development grants
Grants and donations would generally count only when used directly for a plan, project, or initiative whose primary purpose is community development. Banks with more than $10 billion in assets would have to document that grant recipients’ overhead costs do not exceed 15%.
Clearer eligibility and geographic rules
The proposal would add examples of activities that may or may not qualify as community development, and provide a process for banks to ask their regulator whether an activity qualifies. It would also clarify when certain community development activities outside a bank’s assessment areas may receive consideration.
Changes to public information and strategic plans
The proposal would modernize how banks make their CRA public notice and public file available, and revise the strategic-plan option to make it more workable for banks.
No proposed implementation date yet
The proposal does not set a specific effective date for a final rule. Instead, the agencies are asking for comment on the implementation timing and any transition period that may be needed, particularly for provisions involving new data collection, reporting, and public notices. Any effective or compliance dates will depend on the final rule.
Banks should continue following their current CRA requirements while the agencies review comments and decide whether to issue a final rule. The proposal and its reporting changes should not be treated as requirements currently in force.
How data analytics can support CRA compliance
CRA compliance requires a multifaceted approach. Financial institutions may face challenges integrating data requirements with legacy systems. Smaller banks, in particular, may struggle with the resources required to meet the compliance standards because of the expanded array and amount of information expected. The following strategies can help institutions align their operations with regulatory expectations.
Governance and oversight
- Establish a CRA committee: A committee with senior management and representatives from relevant business units can oversee CRA work and understand the capabilities and limitations of the bank’s data systems.
- Review data and controls: Periodic reviews can help assess whether internal controls are working and whether the bank’s data is accurate.
Data collection, analysis, and reporting
- Invest in data infrastructure: Consider how systems can capture and analyze lending, investment, and community development information. Geospatial tools may help banks understand how activity is distributed across relevant areas.
- Develop reporting mechanisms: Use reports or dashboards to give staff and management a shared view of CRA-related activity and its movement over time.
- Review lending and community information: Use relevant lending and geographic information to understand how the bank’s activity aligns with its goals and community needs. Apply the definitions and reporting requirements of the CRA rules currently applicable to the institution.
- Benchmark performance: Use historical information and appropriate industry comparisons to assess performance and identify trends that may inform community investment strategies.
Risk management and internal controls
- Integrate CRA into risk frameworks: Consider CRA activities as part of the institution’s broader risk management strategy, including how the bank identifies and addresses gaps in serving its communities.
- Train employees: Help employees understand the CRA requirements that apply to the bank and the importance of community engagement.
