The Community Reinvestment Act (CRA) is a critical tool for holding banks accountable to the communities they serve. This blog provides an overview of the proposed 2026 changes, what they could mean for New Yorkers, and resources to help organizations and communities understand the proposal and make their voices heard.

The Community Reinvestment Act helps shape how banks invest, lend, and serve low- and moderate-income communities. The proposed changes could have significant implications for affordable housing, community-based organizations, philanthropic grantmaking, banking access, and lending transparency. Add your organization’s voice to ANHD’s member sign-on letter and help protect strong CRA accountability for our communities.

Member sign-on deadline: Monday, October 12 at 5:00 PM ET.

 

ANHD CRA Member Sign-on Letter  

 

Why This Matters

The Community Reinvestment Act (CRA) is one of the most important tools our communities have to hold banks accountable for meeting local credit needs, including the needs of low- and moderate-income (LMI) neighborhoods. In New York City, the CRA connects directly to affordable housing, small-business lending, community development, CDFIs, bank branches and services, and support for community-based organizations.

The Office of the Comptroller of the Currency (OCC) and Federal Deposit Insurance Corporation (FDIC) have proposed significant changes to the CRA. ANHD, alongside our members, are concerned that the proposal could reduce CRA scrutiny, narrow public lending reporting, and weaken important connections between bank activity and meaningful tangible benefits for LMI communities. The agencies themselves acknowledge that the proposal could result in less standardized CRA data, reduced evaluation of non-major lending products, and reduced CRA incentives for certain “nonprofit activities.” 

Comments are due October 13, 2026. ANHD is encouraging our member organizations and advocates, who rely on the CRA as an accountability tool, to make their voices heard and help ensure that access to financial resources and banking services remains a priority. The October 13 deadline remains listed by the OCC. 

What Is at Stake

• Less CRA scrutiny for many banks. The proposal would raise the asset thresholds used to determine how banks are evaluated. Banks with less than $1 billion in assets would be treated as small banks, while banks with at least $1 billion and up to $10 billion would generally fall under the intermediate-bank framework. ANHD is concerned that these changes would reduce the depth of community development, investment, and service scrutiny applied to many institutions. 
• Less public data and transparency. Banks with $10 billion or less in assets would no longer be subject to the same CRA data collection, maintenance, and reporting requirements that apply to large banks. ANHD relies on public bank data through our State of Bank Reinvestment work to identify lending gaps, compare bank performance, and engage financial institutions around community needs. ANHD has historically analyzed more than 20 banks operating in New York City across lending, branches, community development activity, and other indicators.
• Reduced scrutiny of branches, banking services, and public CRA data. The proposal would raise the large-bank threshold to more than $10 billion in assets, meaning many banks currently subject to the full large-bank CRA examination would instead be evaluated under a more limited framework. It would also narrow the large-bank service test to credit services, removing deposit products such as checking and savings accounts from direct CRA evaluation.
  
  ANHD is concerned that these changes could weaken accountability around physical banking access at a time when New York City’s branch network is already contracting. ANHD’s analysis of FDIC Summary of Deposits data found that FDIC-reported bank branches across the five boroughs declined from 1,478 in June 2023 to 1,393 in June 2026¹, a net loss of 85 branches. Physical branches continue to play an important role for small businesses, seniors, LMI households, and residents who face barriers to digital banking.

• New restrictions on community development grants. For large-bank grants, the proposal would limit a recipient’s indirect costs associated with administering a grant or donation to 15 percent. ANHD is concerned that this restriction could make flexible general operating support harder to provide, particularly for smaller community-based organizations that rely on grant funding to sustain core staffing, technology, rent, and the administrative capacity needed to carry out their missions. The agencies themselves acknowledge that the proposal could reduce CRA incentives for general operating-support grants and disadvantage organizations with higher operating-cost ratios.
• A weaker connection between economic-development credit and LMI outcomes. The proposal would eliminate the current economic development “purpose test,” which requires qualifying activities to demonstrate outcomes such as creating, retaining, or improving permanent jobs for LMI people or in LMI areas. Under the proposal, certain financing for qualifying small businesses and farms could receive economic-development credit without demonstrating a direct connection to LMI job creation or similar LMI outcomes, so long as the activity otherwise meets the proposed economic-development criteria. ANHD is concerned that this could weaken the link between CRA credit and measurable benefits for LMI communities.
• Narrower review of important lending products. The proposal presents two approaches for focusing retail lending evaluations on a bank’s “major product lines.” ANHD is concerned that a lower-volume financial product could receive less scrutiny even when it addresses an important local need, such as small-business lending in New York City. The agencies themselves recognize that some lending products may receive less CRA evaluation emphasis if they are not considered major product lines, even when they are important assessment areas.

Why Community Input Matters

CRA works best when regulators understand the needs of the communities’ banks serve. ANHD and our members use CRA Performance Evaluations, lending and branch data, public comment opportunities, research, and direct engagement with financial institutions to identify gaps and advocate for greater investment in low- and moderate-income communities across New York City. The CRA and its toolkit have supported ANHD’s work on small-business lending data, affordable housing preservation, and partnerships among community organizations, financial institutions, regulators, and other government agencies.

Our experience also demonstrates why the CRA should evaluate impact, not simply banking activity. A loan, investment, or grant receiving CRA consideration should have a meaningful connection to the people and communities the CRA is intended to benefit. Public comments help regulators understand what CRA means in practice, how communities use it as an accountability tool, and what could be lost if the proposed changes are finalized as written. Make your voice heard before October 13!


1. Association for Neighborhood & Housing Development analysis of Federal Deposit Insurance Corporation, Summary of Deposits, branch-level data as of June 30, 2023, June 30, 2024, June 30, 2025, and June 30, 2026. Analysis limited to FDIC-reported offices in Bronx, Kings, New York, Queens, and Richmond Counties. Calculations by ANHD.

 

How to Submit Comments on the New CRA Proposal: 

You can sign to ANHD’s CRA Comment Letter, submit your own comments separately, or both.

Sign on to ANHD’s comment letter here:

 

ANHD CRA Member Sign-on Letter  

 

To submit your own comments separately:

1. Start with the sample language below and personalize it. Add examples from your organization’s mission, work, or experiences with the CRA in your line of work.
2. Submit your comment to the OCC through Regulations.gov using Docket ID “OCC-2026-0694” in the search box and click “search.”
3. Remember that comments are generally part of the public record. Do not include information you consider confidential.

For the FDIC Comment Submission: 

• Email your comment letter to comments@fdic.gov, referencing “RIN 3064-AG31” in the subject line.

Sample Comment Letter

This is a shorter public-facing template drawn from ANHD’s full 2026 comment letter. Personal examples should be added wherever possible.

[DATE]

Re: Comment on Community Reinvestment Act Regulations, [OCC Docket ID OCC-2026-0694; RIN 1557-AF57; FDIC RIN 3064-AG31]

To the Office of the Comptroller of the Currency (OCC):

To the Federal Deposit Insurance Corporation (FDIC):

I am writing regarding the OCC and FDIC’s proposed changes to the Community Reinvestment Act (CRA).

[Introduce yourself and/or your organization. If applicable, explain the community you serve, your relationship to ANHD, and how CRA-related lending, investments, services, grants, or bank accountability affect your work.]

The CRA remains an essential tool for ensuring that banks help meet the credit needs of their entire communities, including low- and moderate-income (LMI) neighborhoods. In New York City, CRA supports an ecosystem of affordable housing, small-business lending, community development, CDFIs, nonprofit partnerships, branches, and banking services. I am concerned that the proposal would reduce the level of scrutiny and transparency applied to many financial institutions without adequately accounting for what those changes could mean for our communities.

First, the proposed asset thresholds would significantly reduce the level of CRA scrutiny applied to many banks. Banks with less than $1 billion in assets would be treated as small banks, while banks with at least $1 billion and up to $10 billion would generally be evaluated under the intermediate-bank framework rather than the more comprehensive large-bank framework. It is estimated that 40.4% of banks in New York State would lose large-bank status, while 21.7% would no longer be subject to a community development evaluation¹ under the proposed thresholds. These changes could mean less scrutiny of the lending, investments, services, and community development activities that New York communities rely on.

Second, the proposal would reduce the amount of CRA lending data available to communities and the public. It is estimated that 8.2% of the CRA small-business lending data currently available in New York State could be lost² under the proposal, compared with approximately 11% nationally. Public CRA data is not simply a regulatory reporting requirement. Community organizations use this information to identify credit gaps, compare bank performance, understand whether local needs are being met, and hold financial institutions accountable when they are not.

Third, CRA examinations should continue to meaningfully evaluate branch access and banking services. It is estimated that 17.7% of bank branches in LMI census tracts in New York and 14.4% of branches in communities of color—152 of 1,057 branches—could lose the level of CRA service scrutiny associated with large-bank examinations³ under the proposal. These figures do not mean those branches are expected to close. Rather, they demonstrate the scale of branches that could be affected by the proposed reduction in large-bank CRA status, meaning they’ll have fewer obligations.

That reduced scrutiny matters. Research highlighted by economists at the Federal Reserve Bank of New York found that when merging banks closed a branch, the number of small-business loans in affected census tracts fell by 13% and remained lower for more than eight years⁴. The decline in lending was concentrated in low-income and majority-minority census tracts. The New York Fed researchers noted that these effects may reflect the loss of local relationships and “soft information” that branch managers develop about borrowers and local business conditions. Branches and local banking relationships therefore continue to matter for access to credit, particularly for small businesses and communities that have historically faced barriers to mainstream financial services.

Community development support also needs enough flexibility to reach the organizations best positioned to meet local needs. Staffing and reasonable operating costs are part of the infrastructure required to deliver housing counseling, tenant education, small-business assistance, financial education, and other community services. CRA should encourage banks to support organizations based on their ability to meet community needs, rather than creating requirements that could make smaller community-based organizations more difficult to support.

CRA credit should also demonstrate meaningful community benefit. I am concerned about the proposal to eliminate the economic-development purpose test and narrow retail lending review to major product lines. A business loan does not automatically create jobs or economic opportunity for LMI people or communities, and a lower-volume lending product should not escape meaningful scrutiny simply because it represents a smaller share of a bank’s overall business.

[ADD A LOCAL EXAMPLE HERE: Describe how CRA-related lending, a bank branch, a community development grant, affordable housing financing, CDFI investment, or small-business lending has affected your organization or community.]

Before finalizing these changes, the OCC and FDIC should identify which LMI communities would receive less CRA scrutiny; quantify the branches, lending, investments, services, and community development activities affected; and evaluate whether those impacts would be concentrated in communities. Reducing regulatory burden should not come at the expense of meaningful community accountability.

I urge the OCC and FDIC to reconsider the proposed changes and preserve a CRA framework that maintains strong community accountability, meaningful public data, and incentives for banks to respond to demonstrated local credit and community development needs in the neighborhoods they bank in.

I also urge the agencies to provide additional time for community-based organizations and other stakeholders to evaluate the proposal and submit meaningful commentary. Additional time would allow organizations and communities affected by these changes to better understand their potential impact, analyze the proposal, and provide regulators with informed feedback about what is at stake.

Thank you for your attention and consideration of my comment. If there are any questions or concerns, I could be reached at:

Sincerely,

[NAME]
[ORGANIZATION, IF APPLICABLE]
[CONTACT INFORMATION]

1. National Community Reinvestment Coalition, CRA 2026 Comment Resources and State-Level Impact Analysis, New York interactive state analysis (2026). NCRC CRA interactive map
2. Id. at Small Business Lending Data. 
3. Id. at Banking Branches data
4. Donald P. Morgan, Maxim L. Pinkovskiy & Bryan Yang, Banking Deserts, Branch Closings, and Soft Information, Federal Reserve Bank of New York, Liberty Street Economics (Mar. 7, 2016). The authors discuss research finding that merger-related branch closings were followed by a 13 percent decline in small-business lending in affected census tracts and that the decline persisted for more than eight years. New York Fed research

 

Optional ANHD / NYC Examples to Personalize the Letter

• Branch access: ANHD’s analysis of FDIC Summary of Deposits data found NYC’s FDIC-reported banking offices declined from 1,478 in June 2023 to 1,393 in June 2026.
• Banking access: ANHD’s 2026 comment letter cites NYC Department of Consumer and Worker Protection research reporting that 7.0% of NYC households were unbanked in 2023, including 13.5% in the Bronx.
• Small business: ANHD’s small-business lending analysis emphasizes persistent disparities in access to financing and the importance of better public lending data.
• CDFI/community impact: ANHD’s comment letter cites Renaissance Economic Development Corporation and the Leviticus Fund as examples of organizations directing capital and services toward underserved communities.
  
  

CRA 2026: Resources for Further Research

Sources cited or used in ANHD’s 2026 CRA comment-letter research

How to use this guide. Start with the federal proposed rule and OCC bulletin for the regulatory text and agency summary. NCRC materials provide advocacy analysis; Federal Reserve, FDIC, and NYC sources provide research and data; and ANHD resources show how CRA and lending data are used for local accountability in New York City. Each public resource below includes a clickable direct link and the full URL. 

Primary Regulatory Sources

1. OCC & FDIC — 2026 Community Reinvestment Act Proposed Rule

Community Reinvestment Act Regulations, 91 Fed. Reg. 52,114–52,218 (Aug. 12, 2026), Docket ID OCC-2026-0694. This is the primary source for the proposed changes and the October 13, 2026 comment deadline.

Direct link: Federal Register:: Community Reinvestment Act Regulations

2. Office of the Comptroller of the Currency — Bulletin 2026-35

Community Reinvestment Act: Interagency Notice of Proposed Rulemaking (July 31, 2026). A shorter OCC summary of the proposal and its major provisions.

Direct link: Community Reinvestment Act: Interagency Notice of Proposed Rulemaking | OCC

CRA Policy and Advocacy Analysis

3. National Community Reinvestment Coalition — CRA Resource Center

NCRC’s central resource page for the 2026 CRA proposal, including public education and comment resources. NCRC is an advocacy organization; its analysis is best read alongside the agencies’ proposal.

Direct link: Community Reinvestment Act – NCRC

4. NCRC—The Proposed 2026 CRA Rollbacks: Key Takeaways and Why It Matters

August 3, 2026. NCRC analysis of the proposed asset thresholds, bank classifications, community development, branch and service scrutiny, data reporting, grants, and other changes.

Direct link: The Proposed 2026 CRA Rollbacks: Key Takeaways and Why it Matters – NCRC

5. NCRC—CRA’s New Benchmark Could Put 85% of Current Community Development Activity at Risk

September 10, 2026. NCRC analysis comparing the proposal’s 0.625% Tier 1 capital benchmark with recent community development activity at large OCC- and FDIC-supervised banks.

Direct link: CRA’s New Benchmark Could Put 85% of Current Community Development Activity at Risk – NCRC

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

September 1, 2026. NCRC analysis of the proposal’s strategic-plan provisions and their potential effect on community development expectations.

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

Research and Public Data

7. Federal Reserve Bank of Philadelphia — CRA and Mortgage Lending

Lei Ding & Leonard Nakamura, “Don’t Know What You Got Till It’s Gone”—The Effects of the Community Reinvestment Act (CRA) on Mortgage Lending in the Philadelphia Market, Working Paper 17-15 (2017).

Direct link: https://doi.org/10.21799/frbp.wp.2017.15

8. Federal Reserve Bank of Philadelphia — CRA and Small-Business Lending

Lei Ding, Hyojung Lee & Raphael W. Bostic, Effects of the Community Reinvestment Act (CRA) on Small Business Lending, Working Paper 18-27 (2018).

Direct link: Effects of the Community Reinvestment Act (CRA) on Small Business Lending

9. Federal Reserve Bank of New York — Banking Deserts, Branch Closings, and Soft Information

Donald P. Morgan, Maxim L. Pinkovskiy & Bryan Yang (March 7, 2016). Discusses evidence on branch closures, banking deserts, and small-business credit access.

Direct link: Banking Deserts, Branch Closings, and Soft Information – Liberty Street Economics

10. Federal Deposit Insurance Corporation — Summary of Deposits

Annual FDIC branch-level dataset used by ANHD to examine changes in banking offices and deposits, including ANHD’s 2023–2026 New York City branch analysis.

Direct link: FDIC: BankFind Suite – Summary of Deposits

11. NYC Department of Consumer and Worker Protection — 238,900 Households in NYC Are Unbanked

September 24, 2025. DCWP research on the geographic and demographic characteristics of New York City households without bank accounts.

Direct link: DCWP Releases Updated Research Brief: 238,900 Households in NYC Are Unbanked | City of New York

ANHD and New York City Resources

12. ANHD—State of Bank Reinvestment in NYC Annual Report

ANHD’s long-running research project analyzing local bank performance, branches, lending, community development, small-business activity, and CRA-eligible grants in New York City.

Direct link: State of Bank Reinvestment in NYC Annual Report | ANHD

13. ANHD — Fair Lending Data at Risk!

September 26, 2019. Background on HMDA, fair-lending data, mortgage access, and why public lending data matters for community accountability.

Direct link: Fair Lending Data at Risk! | ANHD

14. ANHD — Better Small Business Lending Requires Better Data: Why Implementing Section 1071 Cannot Wait

November 20, 2025. ANHD analysis of small-business lending transparency, Section 1071, disparities in access to capital, and the importance of public lending data.

Direct link: Better Small Business Lending Requires Better Data: Why Implementing Section 1071 Cannot Wait | ANHD

Supporting Community and Small-Business Research

15. National Urban League — Black-Owned Businesses Face Significant Obstacles

Research cited in ANHD’s Section 1071 analysis on disparities in financing approval and denial rates for Black-owned businesses.

Direct link: Black-Owned Businesses Face Significant Obstacles. Anti-Racial Justice Efforts Are Making Them Worse | National Urban League

16. Accompany Capital—NYC Women Entrepreneurs Survey

Survey of women entrepreneurs in New York City examining access to startup capital, bank financing, technical assistance, and other business needs.

Direct link: https://accompanycapital.org/wp-content/uploads/Accompany-Capital-NYC-Womens-Entrepreneurship-Survey.pdf

17. Renaissance Economic Development Corporation — Mission and Impact

NYC-area CDFI resource illustrating how targeted small-business capital and technical assistance can translate into measurable community outcomes.

Direct link: About Renaissance – Our Mission

18. Leviticus 25:23 Alternative Fund — 2025 Annual Report

CDFI/community-development resource covering affordable housing and community-development lending and impact.

Direct link: Welcome to the 2025 Annual Report | Leviticus Fund