On July 31, the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) issued a Notice of Proposed Rulemaking that would significantly reshape the Community Reinvestment Act (CRA) framework for many institutions. Among other changes, the proposal would increase the asset thresholds used to classify banks, place greater emphasis on lending activity and locally focused community development and reduce regulatory burden for many community banks. Notably, the proposal was issued jointly by the OCC and FDIC, but not the Federal Reserve, underscoring that the CRA regulatory landscape continues to evolve. The proposal is now open for public comment before any final rule is adopted.
Whether or not the proposal is finalized in its current form, it reinforces an important reality: CRA is entering another period of transition. Institutions are once again evaluating how regulatory expectations may change while continuing to build programs that effectively serve their communities and support strategic business objectives.
Interestingly, many of the themes reflected in the proposal were already evident during the Mortgage Bankers Association’s CRA Lending Workshop this past June. Discussions throughout the conference consistently emphasized strategic planning, understanding community credit needs, data-driven decision-making, community partnerships, and thoughtful program execution. Those conversations offer a useful perspective for understanding not only today’s CRA environment, but also where it may be headed.
The following are seven signals that stood out from this year’s workshop—and that remain particularly relevant as the industry considers the latest proposed changes to the CRA framework.
1. CRA is becoming a strategic business discipline
Perhaps the strongest signal from this year’s workshop was that successful institutions are integrating CRA into broader business strategy rather than managing it as a standalone compliance requirement.
Across multiple sessions, speakers emphasized aligning CRA with market growth, governance, community needs assessments, product development, and fair lending strategy. Institutions that understand where community needs exist—and intentionally incorporate those insights into strategic planning—are often better positioned to demonstrate meaningful impact while supporting business objectives.
This broader trend is also reflected in the OCC’s recently proposed guidance on community bank strategic plans. The proposal reinforces several concepts discussed throughout the workshop, including:
- A deeper understanding of local market conditions and community needs.
- Strong board and management engagement in strategic planning.
- Alignment among growth strategy, risk management, compliance, and community impact.
- Clear, measurable goals that enable institutions to track progress internally and against peers.
- Well-documented, intentional decision-making that demonstrates how strategic priorities are developed and executed.
Taken together, these developments suggest regulators increasingly expect institutions to be proactive—not simply compliant.
2. Community Credit Needs Assessments are becoming more important
One message surfaced repeatedly throughout the workshop: institutions need a clear, data-driven understanding of the communities they serve.
Whether supporting CRA planning, identifying community development opportunities, evaluating assessment areas, or informing partnerships, community credit needs assessments are becoming foundational tools for decision-making. Institutions that understand changing demographics, housing markets, small business needs, and local economic conditions are better equipped to direct resources where they can have the greatest impact.
3. Data is only valuable when it drives decisions
The industry has access to more CRA-related data than ever before; however, the workshop made clear that data alone is not enough.
Leading institutions are moving beyond reporting metrics toward using analytics to identify opportunities, evaluate performance, prioritize outreach, monitor trends, and tell a more complete story about their CRA activities. The emphasis is shifting from collecting information to generating actionable insight.
4. State CRA laws continue to expand the compliance landscape
Several sessions highlighted the growing influence of state CRA requirements, particularly for independent mortgage banks and institutions operating across multiple jurisdictions.
As additional states adopt or refine CRA-like frameworks, institutions may face varying requirements, expectations, and reporting obligations. Organizations operating in multiple states will increasingly benefit from coordinated compliance strategies rather than approaching each state’s requirements independently.
5. Partnerships continue to be one of the most effective CRA strategies
No institution can address every community credit need on its own.
Discussions throughout the workshop reinforced the value of strong relationships with community organizations, housing nonprofits, economic development groups, and local stakeholders. Effective partnerships not only strengthen CRA performance but also provide institutions with a better understanding of local needs and opportunities that may not be apparent through quantitative analysis alone.
6. Documentation matters more than ever
Strong CRA performance is not simply about doing good work, but also about demonstrating it.
Workshop discussions repeatedly emphasized maintaining thorough documentation of community development activities, strategic decision-making, partnerships, performance monitoring, and program outcomes. Effective documentation supports examination readiness while also helping management and boards understand the institution’s overall CRA strategy and progress.
7. CRA, fair lending, and business strategy are becoming increasingly connected
Perhaps the most significant long-term trend is the convergence of disciplines that have historically been managed separately.
CRA, fair lending, HMDA analytics, governance, market strategy, and community engagement are increasingly informing one another. Institutions that break down these traditional silos are often better positioned to identify opportunities, manage risk, and develop strategies that serve both their communities and their business objectives.
Rather than viewing CRA solely through the lens of regulatory compliance, leading organizations are beginning to treat it as a framework for understanding markets, improving access to credit, and supporting sustainable growth.
Although the OCC and FDIC’s proposal will undoubtedly receive significant attention over the coming months, the workshop reinforced that many of the fundamentals of a successful CRA program remain unchanged. Institutions that understand their communities, leverage data effectively, build meaningful partnerships, maintain strong governance, and align CRA with broader business strategy will be well positioned regardless of how the final rule evolves.
If anything, the timing of the proposal reinforces the workshop’s central message: CRA should not be viewed as a static compliance obligation. Regulatory requirements will continue to change, and the institutions that succeed will be those that build adaptable, well-governed, and community-focused programs capable of evolving alongside them. As the regulatory landscape continues to evolve, institutions that invest in strategic planning today will be better positioned to adapt, respond, and thrive in whatever comes next.
Contact CrossCheck to learn how our CRA consulting services can help your team assess performance, prepare for exams, and build a proactive strategy.
Authored by Rebecca Escario
