There have recently been quite a number of changes within the banking industry impacting Community Reinvestment Act (CRA) program management. From the twists and turns of CRA modernization, to adapting to evolving examination expectations and changes within banks themselves, a CRA professional’s job never ceases.
While these developments may seem unrelated, together they are changing how CRA programs are managed. Regulatory uncertainty, evolving examination practices, staffing changes at the federal agencies, and increased merger activity are forcing banks to rethink how they document performance, monitor activity, and prepare for examinations. This article looks at each of these developments and what they mean for CRA professionals today.
CRA modernization pause
Efforts to modernize the CRA by the federal banking agencies have been quite the series of ups and downs since 2018. There have been various proposed and final rules over the last eight years, including the interagency CRA final rule in 2023, which we all hoped would be a clear path forward. However, in July 2025, the banking agencies announced their intent to rescind the 2023 final rule, replacing it with the prior CRA regulations adopted in 1995.
As of July 2026, a formal rescission of the 2023 CRA final rule is still outstanding. In practice, examiners and bank staff have maintained the status quo of the 1995 rules, managing CRA with the same methodologies and guidance utilized for over 30 years. Unfortunately, the rescission also means that any updates and guidance included within the 2023 final rule, some of which were viewed positively by banks and industry partners, have been shelved indefinitely, as the banking agencies consider CRA’s future.
On June 4, 2026, while appearing before the House Financial Services Committee, Federal Deposit Insurance Corporation (FDIC) Chairman Travis Hill shared that the agencies expect to decide soon whether to continue to operate under the 1995 CRA rule or to consider options for a new approach. These options include issuing the rescission of the 2023 CRA final rule but could also mean other proactive ways to reform CRA.
Shifting examinations
Beginning in early 2025, changes within the examination structure and agency staffing impacted bank CRA examinations, including updates to the frequency of examinations.
These initial actions impacted bank CRA examinations, in some cases requiring staffing changes to onsite examination teams, but more generally, delaying the timing of examinations for banks beyond the anticipated examination date.
In November 2025, the FDIC issued its Consumer Compliance Examination Manual, applicable to all FDIC-regulated banks. The revised examination cycle schedule significantly extends the frequency of examinations for smaller financial institutions (FIs). For banks with a Satisfactory or Outstanding CRA rating, the timeframe between examinations could increase to up to 78 months, depending on bank asset size. The updates also introduce a new “mid-point risk analysis” for certain FIs, wherein FDIC examiners will determine if a targeted visitation is needed. The FDIC began operating under the revised procedures immediately, with the first mid-point analyses happening in 2026.
Similarly, effective January 1, 2026, the OCC also updated its examination frequency as published in Bulletin 2025-24. CRA examinations can now occur every 24 to 75 months, depending on factors such as asset size, number of ratings areas, most recent CRA rating, and whether the bank is a de novo bank. In a May 2026 News Release (2026-38), the OCC reiterated these updates impacting CRA and other bank activities, noting that the agency will “tailor its examination for a community bank’s specific activities” to reduce supervisory burdens for banks with assets of $30 billion or less.
Bank changes and growth
While the banking agencies have pursued updates to the regulatory examination timeframes and staffing, banks have also experienced increased changes in their own staff, impacted by ongoing acceleration in merger and acquisition activities.
In a November 2025 article published by the ABA Banking Journal, the average time for bank merger approval fell to just four months in 2025, the shortest average since 1990, as reported by the Financial Times. Recent bank mergers and acquisitions have taken on all shapes and size, from some of the largest banks in the nation merging to frequent acquisitions of smaller community banks by competitors and periodically by fintech and credit unions.
Rapid M&A activities present some unique challenges for CRA program management. In some cases, the merger of two smaller FIs immediately hurls the surviving bank up the CRA ladder, with some small banks becoming intermediate small banks or large banks literally overnight. This instant growth can add expansive CRA needs, as small banks must suddenly begin tracking community development activities as an intermediate small bank or reporting a CRA Loan Register as a large bank.
Furthermore, banks could also be presented with new or expanded Assessment Areas, spreading into geographies an existing CRA professional may or may not be familiar with serving. The shortened approval period further complicates these responsibilities by necessitating that CRA staff assess merger and acquisition risks, evaluate the transaction’s impact on the institution, and implement necessary program changes within a compressed timeframe.
In response to the changes within the examination framework and bank overall growth strategies and business models, more banks are considering a move to a CRA Strategic Plan. Included in the CRA regulations for decades, many banks have forgone utilizing the Strategic Plan option, as it remains a somewhat uncommon approach to CRA management. However, FIs with unique business models, larger geographic reach, or specialized products have found many benefits with the deployment a Strategic Plan, which allows them to develop their own measurable goals for CRA performance which can incorporate the uniqueness of their business model and product mix. However, FIs with unique business models, broader geographic footprints, or specialized products can benefit from a Strategic Plan because it allows examiners to evaluate the bank against customized, regulator-approved performance goals, rather than generally applicable CRA performance standards.
In December 2025, the OCC issued proposed guidance for a simplified Strategic Plan process for community banks (News Release 2025-129) as part of its wider efforts to reduce regulatory burden. The OCC’s proposal attempts to provide greater clarity on developing and setting measurable goals and other components of the Strategic Plan process. It also outlines a simpler method for drafting and submitting a proposed Strategic Plan to the OCC for approval. Comments were open for 60 days on the proposed guidance, but as of this article, the guidance has yet to be finalized. The Strategic Plan is also available to banks supervised by the FDIC and the Federal Reserve, but these agencies have not proposed similar guidance.
What’s Next?
For the foreseeable future, the changes of the past few years will continue to impact CRA program management, as the banking agencies continue their ongoing efforts and bank merger and acquisition activities do not appear that they will slow down any time soon. For CRA professionals of all experience levels, the key to program management is ensuring that a bank’s documentation and monitoring processes are locked-in on the core CRA concepts that effectively demonstrate your community impact.
This article originally appeared in the September/October 2026 issue of the ABA Risk and Compliance Magazine published by the American Bankers Association.