Here We Go Again: The OCC and FDIC CRA NPR

On July 31, 2026, the OCC and FDIC issued a joint notice of proposed rulemaking that would amend their Community Reinvestment Act (CRA) regulations. The comment period runs 60 days. The Federal Reserve did not join.

The proposal would raise the asset-size thresholds that determine how a bank is examined and whether it collects and reports CRA data. RiskExec applied the proposed tiers to the 2024 CRA peer data. Join us for what we found and what it would mean for your program.

What the 2024 Data Shows

Source: RiskExec analysis of the FFIEC 2024 CRA data, the most recent published reporting year.

What We'll Cover

• The proposed thresholds: Small under $1 billion, Intermediate $1 billion to $10 billion, Large over $10 billion, and how asset size would be measured
• The RiskExec re-tiering analysis, agency by agency, and which institutions move
• What a smaller reporting population would mean for national CRA peer analysis and market comparisons
• How examination expectations change for banks moving from Large to Intermediate, including the proposed treatment of the Investment and Service Tests
• The grant provisions: direct use of funds, and the proposed 15 percent limit on indirect administrative costs for Large banks
• Documentation your community development program may need to support qualification decisions
• Where to focus if you plan to file a comment, including the alternative $850 million Small bank threshold the agencies raised

Who Should Attend

CRA officers, compliance managers, community development officers, and risk and audit leaders at OCC-, FDIC-, and Federal Reserve-supervised institutions. The session is most relevant to banks between roughly $1.65 billion and $10 billion in assets, and to any institution that relies on public CRA data for peer analysis.

Can't attend live? Register anyway and we'll send you the recording and slides.

Questions

Is this a final rule?
No. This is a proposal. Current CRA classifications, examination procedures, and reporting requirements remain in effect until the agencies complete the comment process and issue a final rule.

Does this affect Federal Reserve-supervised banks?
Not directly. The Federal Reserve Board did not join the proposal, so state member banks would remain under the current Federal Reserve rules unless the Board takes separate action.

Would banks under $10 billion be barred from reporting?
No. The proposal would allow eligible banks to opt in to CRA data reporting voluntarily.

Is there a cost?
No. The session is free, and a recording goes to everyone who registers.