OCC's New CRA Strategic Plan ProposalWhat Community Banks Need to Know

1/21/2026 - By Lorraine Faust, CRCM

The OCC is proposing new guidance to simplify how community banks can create and use strategic plans under the Community Reinvestment Act (CRA). This change is designed to reduce regulatory burden and make it easier for smaller banks to demonstrate how they serve their communities.

Understanding the Proposal

The Office of the Comptroller of the Currency (OCC) has released a request for public comment on a simplified strategic plan process for community banks. Banks have always had the option to be assessed under a self-developed strategic plan, and now the OCC is proposing to make that process easier by providing clearer expectations for measurable goals, such as lending targets or community development activities.

This proposal also aligns with Executive Order 14192, “Unleashing Prosperity Through Deregulation,” which emphasizes reducing private expenditures required to comply with federal regulations. Community banks, the simplified process could free up resources to invest directly in local credit needs rather than compliance paperwork.

How to Get Involved

The OCC is inviting public comments on this proposal. Stakeholders,including banks, community organizations, and individuals, can submit feedback through Regulations.gov using Docket ID OCC-2025-0669. Comments will help shape the final guidance and ensure it balances regulatory clarity with community needs.

Final Thoughts

By streamlining the strategic plan process, the agency is making it easier for smaller institutions to demonstrate their commitment to local communities. This also comes at a time when there are more and more banks with specialized lending products and region-wide or nation-wide lending that may be more conducive to a strategic plan. It may also provide some insights for other banks without strategic plans to understand the expectations for satisfactory and outstanding ratings.

Navigating strategic planning expectations doesn’t have to be complex. Contact our Financial Institutions team to discuss your questions and explore how these updates may affect your bank.

About the Author | Lorraine Faust, CRCM

Lorraine is a director with experience across internal audit, compliance, and regulatory risk management. She began her career in the financial services industry over 30 years ago in internal audit before transitioning to a compliance and risk management role focusing on lending compliance, fair lending, and responsible banking practices. Her primary areas of experience include supporting financial institutions of all sizes in managing fair lending and CRA responsibilities, ensuring regulatory compliance, and mitigating risk.

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