BPI and CBA Comment on OCC and FDIC’s Community Reinvestment Act Proposal

The Consumer Bankers Association^[1] and the Bank Policy Institute^[2] (together, the "Associations") appreciate the opportunity to provide these comments to the Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation (the "Agencies") in response to the Notice of Proposed Rulemaking (the "Proposal") to revise the Agencies' Community Reinvestment Act regulations.^[3]

The Associations represent banks that carry out a significant portion of the nation's community reinvestment activity, across the full range of business models from branch-based retail banks, regional and super-community banks, wholesale and limited purpose institutions, to banks with specialized or nationwide lending operations. We support efforts to ensure that the CRA remains an essential part of the framework for sustaining and revitalizing communities. Based on our members' decades of experience delivering credit to low- and moderate-income ("LMI") communities under the CRA, we understand that the value of the CRA framework turns not only on the substance of its standards but also on its stability, clarity, and consistency across the three federal banking agencies. To that end, we write to urge the Agencies to ensure that the final rule is designed to endure across administrations, harmonize with the Federal Reserve's requirements, and direct resources to the communities that need them.

To read the full comment letter, please click here, or click on the download button below.

[1] The Consumer Bankers Association ("CBA") is the only national financial trade group focused exclusively on retail banking and personal financial services-banking services geared toward consumers and small businesses. As the recognized voice on retail banking issues, the CBA provides leadership, education, research, and federal representation for its members. CBA members include the nation's largest bank holding companies as well as regional and super-community banks that collectively hold two-thirds of the total assets of depository institutions.

[2] The Bank Policy Institute ("BPI") is a nonpartisan public policy, research and advocacy group that represents universal banks, regional banks, and the major foreign banks doing business in the United States. BPI produces academic research and analysis on regulatory and monetary policy topics, analyzes and comments on proposed regulations, and represents the financial services industry with respect to cybersecurity, fraud, and other information security issues.

[3] 91 Fed. Reg. 52,114 (Aug. 12, 2026).