Community Benefits Agreements
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The Community Reinvestment Act (CRA) requires banks to meet the credit needs of the communities where they take deposits, including low- and moderate income (LMI) neighborhoods.
Community benefits agreements (CBAs) are a way for banks to spell out how they will satisfy CRA requirements. CBAs open doors for LMI communities and communities of color, and they increase lending, investments and philanthropy for underserved borrowers and neighborhoods compared to prior practices.
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For additional information on NCRC’s CBA process.
CBAs are between banks and community groups. Since 2016, the National Community Reinvestment Coalition (NCRC) has facilitated the creation of CBAs with 21 bank groups worth a combined $580 billion  for mortgage, small business and community development lending, investments and philanthropy in LMI and under-resourced communities.
Learn more about how NCRC facilitates the creation and performance monitoring of CBAs here.
CBAs completed with NCRC:
(Updated January 2024)
- BMO Harris Bank in November 2022 for more than $40 billion.
- Umpqua in May 2022 for $8.1 billion.
- US Bank in May 2022 for more than $100 billion.
- Old National Bancorp in February 2022 for $8.3 billion.
- ($1.2 billion addendum in January 2024.)
- Flagstar Bank (f/k/a New York Community Bancorp) in January 2022 for $28 billion.
- M&T Bank in October 2021 for $43 billion.
- PNC Bank in April 2021 for $88 billion.
- First Citizens Bank in February 2021 for $16 billion.
- (Expanded in November 2023 to $22.5 billion.)
- CIT Group in November 2019 for $7.75 billion. (Acquired by First Citizens Bank in 2022)
- Morgan Stanley in September 2020 for $15 billion.
- First Merchants Bank in June 2020 for $1.4 billion.
- (Expanded in November 2022 to $2 billion.)
- Truist in July 2019 for $60 billion.
- Cadence Bank in June 2019 for $2.5 billion.
- (Expanded in February 2022 to $23.2 billion.)
- Wells Fargo & Company (DC) in October 2018 for $1.6 billion.
- First Horizon Bank (f/k/a First Tennessee Bank) in April 2018 for $4 billion.
- IBERIABANK in November 2017 for $6.7 billion. (Acquired by First Horizon Bank in 2020)
- Santander Bank in November 2017 for $11 billion.
- (Renewed in June 2023 for an additional $4.6 billion.)
- First Financial Bank in October 2017 for $1.7 billion.
- (Renewed in January 2024 for an additional $2.4 billion.)
- Fifth Third Bank in November 2016 for $30 billion.
- (Expanded in October 2018 to $32 billion.)
- Huntington Bancshares in May 2016 for $16.1 billion.
- (Expanded in September 2020 to $36.1 billion.)
- (Expanded in June 2021 to $76.8 billion.)
- KeyBank in March 2016 for $16.5 billion.
Frequently Asked Questions
- More than half of the money referenced in NCRC CBAs is for direct lending. Banks agree to increases in mortgage lending and small business lending, with an emphasis on addressing racial inequity in lending.
- A smaller portion of existing CBAs focus on increases in community development loans and investments. Investments differ in each CBA but involve CRA approved activities like affordable housing and tax credits.
- Finally, there are sections of a CBA that often involve commitments from the bank for new branches, increased supplier and staff diversity, CRA-approved philanthropy, and initiatives like age-friendly banking and rural strategies.
Planning, meetings, and drafting a CBA usually takes about 4-5 months but can be shorter or longer. The resulting CBA typically covers a five-year period.
- An upcoming bank merger or acquisition is a chance for a bank to work with NCRC on a CBA, because banks are required to show that the merger will create a public benefit. NCRC’s CBA process gives community groups an opportunity to weigh in on how banks should be serving their communities.
- A bank could also be motivated to start a CBA process if it has failed a CRA exam and not met its responsibilities as outlined by the CRA. NCRC’s research team analyzes bank lending patterns to better understand if banks are failing to fulfill their obligations in local markets.
All current NCRC members are invited to “opt-in” and agree to comply with Ground Rules before participating in a CBA process. The process will then include meetings with NCRC members and community groups affected by the CBA campaign and potentially the opportunity to join and speak at meetings with bank leadership to discuss priorities for a CBA.
All types of organizations have a place in the CBA process. CRA approved activities cover a wide spectrum. NCRC’s negotiations with financial institutions have expanded the types of community investments banks are willing to include in a CBA. A strong mix of community groups and organizations is critical for securing additional investments from banks and creating a Just Economy.