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Financial Institution Letter
Joint Proposal to Strengthen and Modernize Community Reinvestment Act Regulations


The Federal Deposit Insurance Corporation, Office of the Comptroller of the Currency, and the Board of Governors of the Federal Reserve System are requesting comment on a joint Notice of Proposed Rulemaking on the Community Reinvestment Act. The NPR is intended to strengthen and modernize the rule that implements the CRA by:

  • Expanding access to credit, investment, and basic banking services in low– and moderate–income (LMI) communities, which are CRA’s core goals;
  • Adapting to changes in the banking industry, including mobile and internet banking by modernizing assessment areas while maintaining a focus on branch–based areas;
  • Providing greater clarity, consistency, and transparency in the application of the regulations through the use of standardized metrics as part of CRA evaluation and clarifying eligible CRA activities focused on LMI communities and under–served rural communities;
  • Tailoring CRA rules and data collection to bank size and business model; and
  • Maintaining a unified approach among the regulators.

Statement of Applicability: The contents of, and material referenced in, this FIL apply to all FDIC-insured financial institutions.


  • Higher thresholds. The NPR would set new thresholds for small and intermediate banks. Under the proposal, Small Banks are defined as those with assets of up to $600 million and Intermediate Banks are those with asset of at least $600 million but less than $2 billion. Large Banks are those with assets of at least $2 billion.
  • No New Data Collection or Reporting. Small Banks and Intermediate Banks would have no new data collection and reporting requirements and existing data would be used whenever possible.
  • Update CRA to address changes in banking industry. The NPR would modernize the approach to the delineation of AAs and would apply performance standards and metrics for retail and CD activities tailored to bank size and business model.
  • Establish four tests for Large Banks. Four tests below would apply to Large Banks, including those evaluated under a strategic plan, although certain provisions of the Retail Services and Products Test and Community Development Services Test would apply only to Large Banks that had average quarterly assets, computed annually, of over $10 billion in both of the prior two calendar years:
    • Retail Lending Test. A retail lending screen would be used to measure a bank’s retail lending relative to its capacity to lend in a particular facility-based assessment areas. Geographic and borrower distribution metrics would be used to assess the bank’s lending performance with respect to LMI individuals and LMI areas, and small businesses and small farms.
    • Retail Services and Products Test. This test would measure the delivery systems and deposit and other products of a bank through the use of certain metrics and performance context.
    • Community Development (CD) Financing Test. This test would use a CD metric paired with an impact review to evaluate the quantitative and qualitative aspects of a bank’s CD financing activity.
    • Community Development Services Test. This test would use some metrics, for example hours for each CD activity, but would remain mostly qualitative to measure responsiveness to community needs.
  • CD Activities: Eligibility of qualifying activities would be expanded in certain areas, including for mission–based entities and Native Land Areas. A non–exhaustive list of, and confirmation process for, qualifying activities would provide increased certainty and clarity on what qualifies for CRA credit.
  • Data Collection, Maintenance, and Reporting for Large Banks: Large Banks over $10 billion would be required to collect, maintain, and report data for their retail deposits, retail lending, retail services, CD loans and investments, CD services, and assessment areas. Large Banks with assets between $2 billion and $10 billion would be subject to some data collection and reporting requirements. Small Banks and Intermediate Banks would collect data in the normal course of business as they do currently.
  • Performance Conclusions and Ratings: Under the proposed rule, the agencies would assign a bank, except a small bank, conclusion scores, including a single score at the institution level to arrive at the bank’s overall statutory rating assigned by the agencies.

Comments are due by August 5, 2022.

Last Updated: May 5, 2022