February 20, 2026
Office of the Comptroller of the Currency
(submitted through Regulations.gov)
RE: Docket ID OCC-2025-0669 – NCRC Comment on proposed strategic plan guidance
The National Community Reinvestment Coalition (NCRC) appreciates the opportunity to comment on the Office of the Comptroller of the Currency’s (OCC) proposed guidance regarding the strategic plan process for community banks. The OCC must provide significantly more detail on how it determined the proposed elective goals for community development financing. Our analysis of publicly available CRA performance evaluation data indicates that the proposed goals would lower regulatory expectations and risk a significant decline in community development loans and investments if the goals are not raised. The proposed guidance also misses an opportunity to provide common sense updates to how the public participates in the development of strategic plans.
NCRC is a network of more than 700 community-based organizations dedicated to creating a nation that not only promises but delivers opportunities for all Americans to build wealth and attain a high quality of life. We work with community leaders and policymakers to advance solutions and build the will to solve America’s persistent racial and socio-economic wealth, income, and opportunity divides, and to make a Just Economy a national priority and a local reality.
This comment is organized into three sections: goal setting, data collection, and public participation. To summarize our feedback and recommendations:
- the proposed elective goals do not compare well to previous performance levels and will lower regulatory expectations of satisfactory and outstanding community development performance if they are not raised,
- banks must provide previous performance levels when drafting strategic plan goals in order to put proposed goals in context,
- the OCC should not move forward with accepting lower investment goals if at least half of the investments meet vaguely defined levels of high impact,
- impact factors previously identified by the agencies in the 2023 CRA rule could help with the development of goals for high impact activities,
- goals should increase over time to account for growth,
- easily surpassed goals should be raised,
- banks must not be allowed to dictate how multiple goals will be weighed,
- small business and small farm data reporting requirements can not be waived through guidance, and
- the OCC should post draft strategic plans online and encourage banks to post draft plans online during comment periods to improve the public’s ability to comment on draft strategic plans.
Goal Setting
Proposed Elective Goals Lower Regulatory Expectations of Satisfactory and Outstanding Community Development Performance
The guidance includes potential elective goals for the level of community development financing that the OCC would consider as Satisfactory or Outstanding performance.[1] The goals provide specific ratios of community development loans or investments compared to assets or tier one capital, including that the OCC would consider 0.12% to 0.24% of assets devoted to combined community development loans and investments per year as Satisfactory based on the size and complexity of the bank.[2] The OCC has provided little detail on how the goals were determined but states that the proposed goals are based on “performance levels that the agency historically has expected of community banks with ‘Satisfactory’ or ‘Outstanding’ ratings” based on both previously approved strategic plans as well as ‘community banks’ CRA performance under the otherwise applicable performance tests and standards.” NCRC’s analysis of this same historical performance indicates that the current proposed goals are setting expectations far too low.[3]
The Federal Reserve released data from CRA performance evaluations published from 2005 to 2020 in order to facilitate analysis of proposals to revise and update the CRA’s implementing regulations.[4] These Federal Reserve data sets are the most comprehensive public database of CRA performance evaluations, and include information that can be used to analyze the OCC’s proposed elective goals such as previous amounts of community development loans and investments reported by bank and assessment area, the time frame of the community development evaluation period, and asset sizes of the bank evaluated.
The chart above shows that the historical median percentage of community development loans or investments outperform most of the OCC’s proposed elective goals.[5] The median for combined community development loans and investments per year was 0.70% of assets for OCC regulated banks with $30 billion or less in assets, and 0.64% for banks with $1 billion or less in assets, from 2016 through 2020. This performance is significantly higher than the OCC’s proposed 0.12% to 0.24% for Satisfactory performance, and even higher than the 0.20% to 0.40% suggested for Outstanding ratings.[6] These medians are also a conservative estimate of previous performance as the Federal Reserve’s data set does not include data on community development loans and investments made outside of assessment areas.
NCRC estimates that if the OCC’s proposed elective goals were already in place, community development loans and investments would have decreased by nearly $100 million a year from 2016 through 2020 if just 10% of OCC-regulated banks near median performance dropped down to 0.24% of assets.[7] Significantly more community development financing would be at risk if more banks decide to opt into strategic plans using the OCC’s currently proposed goals.
Banks that do not pursue strategic plans may also point to this guidance to justify decreasing their community development financing. The OCC notes that “the elective goals should not be considered benchmarks for ‘Satisfactory’ or ‘Outstanding’ CRA performance outside the simplified strategic plan process.” However, if the proposed goals are significantly under current performance levels, as our analysis indicates, it risks turning the strategic plan option into a way for banks to decrease their CRA activity while still receiving passing CRA ratings. Furthermore, despite the OCC’s qualifications that the proposed goals should only be used in the development of strategic plans, we have already observed one instance of a legal advisor highlighting the proposed goals as indicative of how banks should analyze their levels of community development financing – regardless of whether they do strategic plans or are even OCC regulated.[8]
The OCC must provide the data and methodology used to determine the proposed elective goals, and our analysis indicates they should be raised to prevent a decrease in needed community development financing. NCRC agrees that clarity around how much community development is expected is helpful for banks as they consider strategic plans and set their own internal performance benchmarks. However, these must be carefully constructed based on previous performance levels to avoid any long-term reductions in community development financing.
In addition, the proposed Simplified Strategic Plan Form should require banks to include their past performance in reference to the metrics of all goals – community development, retail lending, and services – in order to put proposed goals in context. For example, if a bank offers a combined annual community development loan and investment goal equivalent to 0.24% of assets – then the bank should provide their current ratio of community development loans and investments per year compared to assets. This will help the OCC implement its stated expectation that the strategic plan process will not be used to justify reductions in CRA-qualifying activity.[9]
High Impact Activities
The OCC is offering to accept lower community investment goals as long as “50 percent of the activity would be allocated to high impact activities, such as donations or complex or innovative investments.”[10] For example, the OCC suggests that as little as 0.04% of assets per year dedicated to community investments could merit a ‘Satisfactory’ rating as long as at least half of the activity was high impact, with 0.08% expected if less than half is high impact, and 0.24% if less than half is high impact and the bank does not offer a community development lending goal.[11]
This approach confuses more than it clarifies. For instance, using the metrics from the example above, a larger community bank would typically be expected to devote .08% or .24% of assets to community development investments per year, why then would the OCC be satisfied if only .02% (half of .04%) had high impact? How was the 50% high impact threshold arrived at, and how does that compare to previous levels of high impact CRA activity? How is the OCC defining high impact?
The quality and quantity of a bank’s community development activities are equally important when reviewing CRA performance. We reject the idea that less CRA activity is acceptable if it meets undefined levels of impact, and consequently, less impactful activities are also acceptable if the bank does more of them. NCRC recommends that the OCC remove this portion of the proposed elective goals.
The OCC also requests input on whether they should offer an “elective goal based on the percentage of qualified investments that are highly impactful, such as grants or donations?”[12] This could be helpful, but the OCC must provide more detail on what is considered “highly impactful”. The 2023 CRA rule created twelve different factors that examiners would use to evaluate the impact of a bank’s community development activities, including activities to benefit persistent poverty counties, census tracts with poverty rates over 40%, and Native Land Areas.[13]
Instead of creating a generic high impact goal, the OCC should instead offer elective goals for each of the twelve different factors previously identified by the OCC and the other agencies in charge of implementing the CRA. Banks could then draft goals related to which of those impact factors are relevant to their assessment areas. For example, a bank with census tracts with poverty rates over 40% in their assessment area could create a goal related to lending or community development activities that would benefit those tracts. As with all goals, NCRC strongly recommends that banks be required to provide their previous performance to allow reviewers of the strategic plan to put proposed goals in context. NCRC would also support an elective goal specifically for CRA-eligible grants or donations, which was one of the factors identified in the 2023 rule.
Increasing Goals
The OCC asks for input on whether it’s “appropriate to increase the performance expectations for community banks’ annual interim measurable goals over time?”[14] We support the OCC’s stated expectation that a bank will “annually increase the dollar-denominated thresholds in its interim goals to account for a bank’s expected growth and the resultant increase in capacity.”[15] Furthermore, if a bank significantly surpasses an annual goal in the first year of a multi-year strategic plan, it indicates that the goal was set too low and there should be a recalibration of the goals for the remaining years of the strategic plan using the plan amendment process already provided in the strategic plan regulations.[16]
Weighing Goals
Finally, the OCC requests input on whether it should “include the option for banks to specify a methodology for weighting measurable goals included in the proposed strategic plan” in instances where a strategic plan includes multiple goals or assessment areas.[17] This approach gives too much leeway for banks to determine how their CRA performance is evaluated. Instead the OCC should clarify the methodology it will use to weigh multiple goals. The OCC has suggested using “deposit market share, lending market share, or a combination of the two” as possible weighing methodologies.[18] Our recommendation would be for the OCC to clarify that it will use a combination of deposit and lending market shares, and not give banks the option to determine how their performance will be weighed across multiple goals or assessment areas.
No Waivers for Small Business or Small Farm Data Collection
The OCC is proposing to waive small business or small farm data collection requirements on a case-by-case basis.[19] This is unsuitable for regulatory guidance because it directly contradicts current strategic plan regulations that specifically describe how “approval of a plan does not affect the bank’s or savings association’s obligation, if any, to report data as required by § 25.42.”.[20] Section 25.42 requires all banks, except small banks, to collect small business or small farm data, and the OCC must not allow through this guidance the possibility of a waiver from these requirements.
Public Participation
The process for the public to provide comments on draft strategic plans is woefully out of date. The 1995 CRA regulations require banks to informally seek public input during the drafting of a strategic plan and to post notices of draft plans in at least one newspaper in their assessment areas for a 30-day comment period, as well as making the plan available in branches.[21] In practice, these notices are largely placed in trade papers that are not widely read by the public and nonprofit organizations active in community development, resulting in minimal opportunities for stakeholders to weigh in on how banks will serve their communities.
It’s concerning and inconsistent that the OCC is considering options that make it easier for banks to submit strategic plans online, such as web based forms, without applying the same considerations to public input.[22] To correct for this, the OCC could post draft plans on its website and revise the proposed guidance to encourage banks to also post draft strategic plans online to better facilitate public participation. This would not contradict current strategic plan regulations that require strategic plans to be placed in “ in at least one newspaper” in each assessment area as plans could be posted online in addition to newspapers, and the regulatory language establishes a minimum of at least one newspaper but does not restrict further steps to solicit public input.[23] Without improvements to facilitate public input, increased use of the strategic plan option poses a serious risk of restricting opportunities for meaningful participation in the CRA process.
Comments on CRA exams typically raise performance issues or highlight community needs that are currently being underserved. The purpose of commenting is to encourage a bank to devote more resources to aspects of their performance, or consider additional priorities for their community development portfolio. However, the public’s ability to influence a bank’s CRA performance is limited while the bank is operating under a strategic plan. The bank has essentially worked out with its regulator what they need to accomplish to receive a passing rating, increasing the importance of providing a meaningful opportunity for the public to weigh in on plans before they are finalized. If this guidance is approved without improvements, the anticipated increase in the adoption of strategic plans risks relegating local community development practitioners, elected representatives, and other stakeholders to bystander roles, as banks lock in their CRA priorities and commitments for up to five years with little public input.
Conclusion
The proposed elective goals must be revised in order to prevent significant reductions in community development financing, and the OCC should use this guidance to recommend banks post draft strategic plans online, as well as posting on the OCC website, in order to modernize the public comment process.
Thank you for considering our views on this important matter. If you have any questions, please contact me at khill@ncrc.org.
Sincerely,
Kevin Hill
Senior Policy Advisor
National Community Reinvestment Coalition
[1] Federal Register / Vol. 90, No. 243 / Monday, December 22, 2025 / Proposed Rules. Pages 59762-59763. https://www.govinfo.gov/content/pkg/FR-2025-12-22/pdf/2025-23547.pdf
[2] Federal Register / Vol. 90, No. 243 / Monday, December 22, 2025 / Proposed Rules. Page 59763. https://www.govinfo.gov/content/pkg/FR-2025-12-22/pdf/2025-23547.pdf
[3] Federal Register / Vol. 90, No. 243 / Monday, December 22, 2025 / Proposed Rules. Pages 59748-59749 . https://www.govinfo.gov/content/pkg/FR-2025-12-22/pdf/2025-23547.pdf
[4] The Federal Reserve’s CRA data tables are available for download at https://www.federalreserve.gov/consumerscommunities/data_tables.htm. Information about the data tables, including the number of performance evaluations reviewed and sampling methodology can be found in the “User Guide – CRA Analytics Data Tables” available online a
t https://www.federalreserve.gov/consumerscommunities/files/cra-final-rule-data-tables-user-guide.pdf.
[5] Based on NCRC’s analysis of the Federal Reserve’s merged data table. We first combined the community development loan and investment data from all of a bank’s reported assessment areas during a single performance evaluation and created a ratio of the total community development loans or investments per year compared to asset size, and then removed performance evaluations where there appear to be issues in the reported data. Specifically we removed all exams with no community development loan and investment data, as well as exams where the ratio of combined average community development loans and investments per year was greater than 10% or less than 0%. After removing these outliers, our sample included 239 OCC bank performance evaluations from 2016 through 2020 involving banks with assets greater than $30 billion, and 131 under $1 billion.
[6] Federal Register / Vol. 90, No. 243 / Monday, December 22, 2025 / Proposed Rules. Page 59763. https://www.govinfo.gov/content/pkg/FR-2025-12-22/pdf/2025-23547.pdf
[7] To prepare this estimate, we used the Federal Reserve’s merged data table to identify OCC published CRA performance evaluations from 2016 through 2020 reviewing banks at $30 billion in assets or less. We included all exams in the Federal Reserve’s merged data table with any reported community development loan and investment data and ratios of annual combined community development loans and investments compared to assets of less than 10% and greater than 0%. After removing these outliers, we sorted the 239 exams based on their ratio of combined average community development loans and investments per year compared to assets. We used that to calculate the median of .70% for OCC regulated banks with assets of $30 billion or less with CRA performance evaluations released from 2016 through 2020. To prepare the reduction estimate we then organized the 120 banks above .70% into deciles and compared the actual amount of community development loans and investments per year reported in their CRA performance evaluation to the level of community development loans and investments expected if the bank achieved .24% of assets devoted to community development loans and investments per year for banks in the lowest decile. This determined that combined community development loans and investments would have decreased by $94.7 million per year from 2016 through 2020 if those lowest decile banks had achieved .24% of assets devoted to community development financing as compared to their actual levels.
[8] “To be sure, the agency does state that the elective goals are deigned for use in the simplified strategic plan process for community banks only and that the elective goals should not be considered as benchmarks for “Satisfactory” or “Outstanding” CRA performance outside the simplified strategic plan process. But at the same time, the agency states, “the OCC is proposing elective goals that are consistent with the performance measures and performance levels that the agency historically has expected of community banks with ‘Satisfactory’ or ‘Outstanding’ ratings”.
I know this, as we advise our clients about their CRA performance we intend to reference the OCC’s proposed measures and performance levels for “Satisfactory” and “Outstanding” community development performance ratings. This is particularly true in light of the agency’s admission that the proposed standards and ratings reflect their historical experience.”
Important Lessons in OCC Simplified Strategic Plan Proposal for all ISB’s and Large Banks. JD Supra. January 28, 2026. https://www.jdsupra.com/legalnews/important-lessons-in-occ-simplified-9260357/
[9] Federal Register / Vol. 90, No. 243 / Monday, December 22, 2025 / Proposed Rules. Page 59748. https://www.govinfo.gov/content/pkg/FR-2025-12-22/pdf/2025-23547.pdf
[10] Federal Register / Vol. 90, No. 243 / Monday, December 22, 2025 / Proposed Rules. Pages 59752 – 59753. https://www.govinfo.gov/content/pkg/FR-2025-12-22/pdf/2025-23547.pdf
[11] Federal Register / Vol. 90, No. 243 / Monday, December 22, 2025 / Proposed Rules. Page 59763. https://www.govinfo.gov/content/pkg/FR-2025-12-22/pdf/2025-23547.pdf
[12] Federal Register / Vol. 90, No. 243 / Monday, December 22, 2025 / Proposed Rules. Page 59753. https://www.govinfo.gov/content/pkg/FR-2025-12-22/pdf/2025-23547.pdf
[13] Federal Register / Vol. 89, No. 22 / Thursday, February 1, 2024 / Rules and Regulations. Page 6714. https://www.govinfo.gov/content/pkg/FR-2024-02-01/pdf/FR-2024-02-01.pdf
[14] Federal Register / Vol. 90, No. 243 / Monday, December 22, 2025 / Proposed Rules. Page 59751. https://www.govinfo.gov/content/pkg/FR-2025-12-22/pdf/2025-23547.pdf
[15] Federal Register / Vol. 90, No. 243 / Monday, December 22, 2025 / Proposed Rules. Page 59748. https://www.govinfo.gov/content/pkg/FR-2025-12-22/pdf/2025-23547.pdf
[16] Title 12 Chapter I Part 25 Subpart B § 25.27 (h)
[17] Federal Register / Vol. 90, No. 243 / Monday, December 22, 2025 / Proposed Rules. Page 59753. https://www.govinfo.gov/content/pkg/FR-2025-12-22/pdf/2025-23547.pdf
[18] Federal Register / Vol. 90, No. 243 / Monday, December 22, 2025 / Proposed Rules. Page 59753. https://www.govinfo.gov/content/pkg/FR-2025-12-22/pdf/2025-23547.pdf
[19] Federal Register / Vol. 90, No. 243 / Monday, December 22, 2025 / Proposed Rules. Page 59761. https://www.govinfo.gov/content/pkg/FR-2025-12-22/pdf/2025-23547.pdf
[20] Title 12 Chapter I Part 25 Subpart B § 25.27 (b)
[21] Federal Register / Vol. 60, No. 86 / Thursday, May 4, 1995. Page 22182. https://www.govinfo.gov/content/pkg/FR-1995-05-04/pdf/95-10503.pdf
[22] Federal Register / Vol. 90, No. 243 / Monday, December 22, 2025 / Proposed Rules. Page 59755. https://www.govinfo.gov/content/pkg/FR-2025-12-22/pdf/2025-23547.pdf
[23] Title 12 Chapter I Part 25 Subpart B § 25.27 (d) (2)
