Final Rule Amending Community Reinvestment Act Regulations

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We asked for it and we got it! The Federal Reserve, FDIC, and OCC have released the long-awaited CRA modernization rule. Here are some highlights.

Effective date:  April 1, 2024, however assessment area requirements and some general provisions become effective January 1, 2026, and reporting requirements are effective January 1, 2027, with data being reported by April 1, 2027.

Tiered framework:  The rule provides for four categories by which banks will fall into. The rule also retains the strategic plan option for banks.

Category Total Assets as of 12/31
Prior 2 Years
Evaluations and Weighting Data Collection
Small < $600M Current CRA evaluation criteria

Optional: New Retail Lending test

No change
Intermediate $600M – $2B Current Community Development evaluation (50%)

New Retail Lending test (50%)

Optional: New Community Development Financing test

No change
Large >$2 billion Retail lending test (40%)

Retail services and products test (10%)

Community Development Financing test (40%)

Community Development Services test (10%)

Updated and expanded.
Limited Purpose Current “limited purpose” and “wholesale” Community Development Financing Test No change

Tests: The rule maintains, adjusts, and introduces new tests and criteria.

Test Geographic Area Considerations
Retail Lending Facility-based assessment areas.

Retail lending assessment areas: For large banks with 80 percent or less of their lending in facility-based assessment areas, closed-end home mortgage or small business lending would also be evaluated in areas with > 150 closed-end home mortgage loans or 400 small business loans originated in both of the prior two years.

Outside retail lending areas: For large banks, as well as for intermediate banks if the majority of their retail lending is outside their facility-based assessment areas.

Home mortgage loans

Multifamily loans

Small business loans

Small farm loans

Automobile loans (only for certain banks)

Community Development Financing Facility-based assessment areas

At the institution level

Dollar volume of loans and investments.

Standard benchmarks

Impact and responsiveness

Community Development Services Facility-based assessment areas.

Rural areas


Volunteer hours related to financial services or community development.

Activities that promote financial literacy.

Retail Services and Products Facility-based assessment areas.

At the institution level.

Retail banking products (which includes both deposit products and credit products and programs) would only positively contribute to a bank’s conclusion on this test.

Credit and deposit products or programs that facilitate a relationship.

Branch and remote service facilities.

Digital and other delivery systems.


Community Development Categories:  The rule defines 11 community development categories providing more clarity regarding the loans, investments, and services that the agencies have determined support community development.


It will take a while for all of us to digest the almost 1,500 pages of the rule, however, Treliant can assist your institution with evaluating the effects, interpreting the rules, and implementing the requirements.

Our team of experts is experienced in understanding the challenges these dramatic rule changes can have and stand ready to help you navigate through these changes, even helping to determine if a strategic plan is the better option for institutions that do not quite fit in to the new framework.

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Lorraine Faust

Lorraine Faust, a Senior Manager with Treliant, is a regulatory and compliance professional with over 25 years’ experience in the financial services industry. She has worked in small, mid-size, and large financial institutions in both internal audit and compliance. Knowledgeable in a wide range of consumer protection laws, Lorraine’s focus…