Community Reinvestment Act: Interagency Notice of Proposed Rulemaking
AI Analysis
The OCC and FDIC issued an interagency notice of proposed rulemaking on July 31, 2026 to revise Community Reinvestment Act rules, with the stated goals of narrowing CRA evaluation toward lending, improving how community development grants are counted, reducing burden on smaller institutions, and clarifying qualification standards. For compliance teams, this is a significant consultation because it signals potential changes to CRA exam scope, bank-size categories, documentation expectations, and strategic plan treatment.
Key dates
- 2026-07-31
- OCC Bulletin 2026-35 issued; interagency proposed CRA rule released
Suggested considerations
- Compliance teams may wish to map current CRA inventories against the proposed lending-focused retail services framework to identify deposit-service items that could lose CRA consideration.
- Firms may wish to review community development grant and donation controls to determine whether documentation exists to show direct use for a qualifying primary-purpose community development activity.
- Large banks may wish to assess whether recipient overhead data, written commitments, attestations, tax filings, and budget records would be available to support the proposed 15% overhead limitation.
- Banks near the $1 billion and $10 billion thresholds may wish to model whether the proposed size reclassification would change their CRA evaluation approach, reporting obligations, or supervisory expectations.
- Institutions using or considering strategic plans may wish to reassess whether the proposal would make that option more operationally feasible under the revised framework.
- CRA and public-disclosure teams may wish to inventory public file and notice processes to determine whether technology-enabled publication changes would require procedural updates.
What changed
['The proposal would narrow the retail banking services analyzed under CRA to focus on credit services and would exclude deposit services from that component of the evaluation, while giving greater weight to activities with a lending nexus.', 'Community development grants would count only if they are directly used for a plan, project, or initiative with community development as a primary purpose; for large banks, defined as banks with assets over $10 billion, the recipient would also need documented overhead costs not exceeding 15% of the grant amount.', 'The bank-size framework would be recalibrated by raising the small-bank threshold to $1 billion from $412 million and the intermediate-bank threshold to $10 billion from $1.65 billion, which would expand the population of institutions tre
Compliance impact
The OCC describes the proposal as intended to reduce unnecessary burden while preserving continuity in much of the CRA framework, so the immediate impact is consultation-stage rather than binding change. If adopted, the rule could materially change which activities earn CRA credit, how banks are categorized for exams, and the documentation burden for community development grants, especially for ba
Who is affected
Related regulations
References
AI-generated analysis. May contain errors or omissions — verify with the original OCC source before acting. Full disclaimer.
What the OCC said
The OCC and FDIC are proposing to amend their Community Reinvestment Act (CRA) rules by making certain substantive, technical, and process-oriented changes to refocus on the statutory objective of encouraging banks to meet the credit needs of their communities; to better ensure that community development grants reach…
Extract from OCC . Read the full notice at the source for the authoritative text.