OCC, FDIC Propose Amending CRA Rules

The OCC and FDIC proposed amending their Community Reinvestment Act ("CRA") rules to raise bank size thresholds, narrow community development criteria, revise Lending Test and Service Test evaluations, and modernize public disclosure requirements, largely retaining the structure of the agencies' 1995 CRA rules.

The proposal follows a preliminary injunction barring enforcement of the 2023 interagency CRA rules and replaces a July 2025 interagency proposal to rescind those rules, which the agencies decided not to finalize. The Federal Reserve did not join the proposal. The OCC and FDIC said decisions about the Federal Reserve Board's next steps rest with its Governors.

The large-bank asset threshold would rise from $1.649 billion to more than $10 billion and the small-bank ceiling from $412 million to $1 billion, a change the agencies estimate would classify roughly 80 percent of covered banks as small banks. The proposal would also replace the "intermediate small bank" category with an "intermediate bank" category covering banks with between $1 billion and $10 billion in assets. The agencies also proposed revised standards for limited purpose and wholesale bank designations, including a new definition of incidental-basis lending capped at 5 percent of total lending; added a new "military bank" definition permitting such banks to delineate the entire United States and its territories as a single assessment area; and clarified strategic plan requirements covering pre-filing communications, a 90-day submission deadline, amendment, and assessment over the full plan term.

The revised Lending Test would evaluate banks of all sizes only on major product lines rather than requiring evaluation of home mortgage, small business, and small farm lending, regardless of significance. One option would designate the two largest of the four lines (home mortgage, small business, small farm, consumer) bank-wide by dollar volume and loan count. An alternative would designate major product lines assessment area by assessment area, using quantitative and qualitative factors. Under either option, consumer lending would count as a major product line only if it constitutes a majority of the bank's retail lending by both dollar volume and loan count, or at the bank's election.

Comments are due by October 13, 2026.