The Proposed CRA Rule’s Strategic Plans: A More Predictable Path to Doing Less

By / / Policy, Views / 6 minutes of reading

The strategic plan provisions in the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation’s (FDIC) 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. 

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