The strategic plan provisions in the OCC and FDIC’s proposed CRA rule have received less attention than the proposal’s headline changes. However, combined with the OCC’s December 2025 guidance, it could make it easier for banks to pass CRA exams while providing less community development financing than they have historically.
Strategic plans are not new. They allow a bank, with regulatory approval and community input, to satisfy their CRA requirements with a customized set of measurable performance goals. NCRC has long recognized that strategic plans can make sense for institutions whose business models do not fit neatly within the standard CRA examination framework.
Strategic plans benefit communities only if they improve previous performance levels and respond to pressing community needs. Taken together, the OCC’s December 2025 strategic -plan guidance and the OCC and FDIC’s new CRA proposal create a serious risk of the opposite: more banks could choose strategic plans precisely because they provide a more predictable, and likely a lower, bar for passing CRA.
The OCC has proposed goals far below historical levels
The OCC proposed elective strategic-plan goals under which combined annual community development lending and investment equal to just 0.12% to 0.24% of assets to receive a Satisfactory rating depending on the size of the bank. Outstanding goals ranged from 0.20% to 0.40% for banks under $30 billion.1
Those figures are strikingly low compared with what banks have actually done. NCRC analyzed Federal Reserve data from CRA examinations and found that OCC-regulated banks with $30 billion or less in assets had median combined community development lending and investment of approximately 0.70% of assets annually from 2016 through 2020. For banks with $1 billion or less, the median was 0.64%.2
NCRC estimated that if just 10% of OCC-regulated banks near median historical performance had instead reduced their activity to the OCC’s proposed 0.24% Satisfactory level, community development financing would have declined by nearly $100 million per year during that period.3
To illustrate how low the OCC’s proposed strategic-plan benchmarks are relative to current performance, NCRC also applied those benchmark percentages to a sample of 69 OCC- and FDIC-supervised banks among the 100 largest U.S. banks by assets for modeling purposes.4 Those banks currently conduct approximately $59.1 billion per year in community development lending and $42.9 billion per year in qualified investments and grants inside their assessment areas, resulting in about $102 billion annually in total.
Measured against bank assets, the current median annual community development lending is approximately 0.69% of assets, more than four times the proposal’s 0.16% strategic plan benchmark, while median qualified investments are approximately 0.32% of assets, eight times the proposal’s 0.04% benchmark.
If the 69 banks in NCRC’s sample reduced their activity to those two benchmarks, annual community development lending and investments would fall from approximately $102 billion to $31 billion, a difference of roughly $71 billion per year. NCRC does not assume that every bank would reduce its activity to those levels. But, the gap shows that the benchmarks are far below what banks do today and could encourage much lower levels of community development activity in the future.
The real concern is that regulators would be establishing an explicit target that banks can reasonably understand as sufficient for receiving a passing CRA rating. Once the government tells banks that a particular level is satisfactory, it should expect that some institutions will adjust their community development dollars to be set at, or just slightly above, that number.
The new rule would encourage more banks to take the strategic plan route
Today, strategic plans are relatively uncommon. The FDIC reports that only 45 of the 2,689 CRA-covered institutions it supervises—about 1.7%—currently operate under strategic plans. The proposal describes strategic plans as “underutilized” and says the agencies intend to make them a “viable choice for more banks.”5
Under the August CRA proposal, banks would gain substantially more ability to shape strategic -plan goals with regulators before communities have a chance to weigh in. Regulators could provide substantive preliminary feedback on a bank’s proposed measurable goals before the plan is released for public comment.6 That is a meaningful change from current interagency guidance, which permits consultation about process and completeness, but says regulators should not advise banks on the merits of the plan or adequacy of its goals. The proposal expressly changes that policy.7
Banks would also receive clearer procedures for determining when a plan is technically complete, clearer grounds for denial and a process for curing deficiencies and resubmitting a rejected plan.8 Their cumulative effect is to make the strategic -plan option substantially more predictable for banks. Because the OCC’s proposed benchmarks are well below historical levels of community development activity, that predictability will likely come with a built-in incentive to invest less in communities while still earning a passing CRA rating.
The ultimate issue is how much capital reaches communities
Strategic plans can serve a legitimate function when a bank’s business model does not fit neatly within the standard CRA tests. The relevant policy question, however, is not whether strategic plans offer banks flexibility or merely preserve a minimum level of performance. It is whether the plan is rigorous enough to respond to the actual credit and community development needs of the communities the bank serves.
That is where the proposal falls short. The agencies would make strategic plans easier to negotiate, easier to complete and more predictable to use, while the OCC’s earlier guidance contemplated community development benchmarks below the historical performance of many banks. Taken together, the changes are likely to lower the effective level of CRA activity associated with a Satisfactory rating.
That in turn translates into less financing for affordable housing, CDFIs and small business development, even where banks historically have done more. The end result is that the proposal gives banks more certainty while allowing them to invest less in communities.
1 Office of the Comptroller of the Currency, Community Reinvestment Act: Simplified Strategic Plan Process for Community Banks, 90 Fed. Reg. 59,744, 59,7632 (Dec. 22, 2025), Appendix A.
2 https://ncrc.org/ncrcs-comment-on-the-occs-proposed-strategic-plan-guidance
3 Id.
4 NCRC analysis of the most recent CRA performance evaluations for the 69 OCC- and FDIC-supervised institutions among the 100 largest U.S. banks by assets. The evaluations were issued between 2020 and 2026, with 98 of the 100-bank dataset’s evaluations issued between 2022 and 2025, and cover evaluation periods beginning as early as 2016 and ending as late as 2025. Because evaluation periods vary by bank, NCRC annualized each bank’s reported activity. Among the 69-bank OCC/FDIC sample, median annual community development lending inside assessment areas was approximately 0.69% of assets and median annual qualified investments were approximately 0.32% of assets. By comparison, the OCC’s December 2025 proposed simplified strategic-plan guidance identifies, for certain larger, more complex community banks, a 0.16% of assets annual community development lending goal and a 0.04% annual qualified-investment goal. The banks in NCRC’s sample currently conduct approximately $59.1 billion in community development lending and $42.9 billion in qualified investments annually inside their assessment areas, approximately $102 billion combined. If all 69 banks were hypothetically to reduce activity to the 0.16% lending and 0.04% investment levels, the modeled total would be approximately $31 billion annually, roughly $71 billion below current annualized activity. This is a scenario illustrating the distance between current activity and the referenced benchmarks, not a prediction that banks will reduce activity by $71 billion.
5 Community Reinvestment Act Regulations, 91 Fed. Reg. 52,114, 52,147–48, 52,170 (Aug. 12, 2026).
6 Community Reinvestment Act Regulations, 91 Fed. Reg. 52,114, 52,191.
7 Community Reinvestment Act Regulations, 91 Fed. Reg. 52,114, 52,144.
8 Community Reinvestment Act Regulations, 91 Fed. Reg. 52,114, 52,142, 52,145
