Overview

The Community Reinvestment Act (CRA) is a federal law that requires banks to help meet the credit needs of the communities in which they take deposits. It requires periodic evaluation of each bank’s performance. This evaluation is also considered when certain applications are reviewed, such as branches, mergers, and acquisitions. Depending on the size of the bank, it may be required to meet not only a lending test but also tests of its services and investments in its assessment area.

On May 5, 2022, federal bank regulatory agencies jointly issued a proposal to strengthen and modernize regulations implementing the Community Reinvestment Act (CRA) to better achieve the purposes of the law. CRA is a landmark law enacted 45 years ago to encourage banks to help meet the credit needs of their local communities, including low- and moderate-income (LMI) neighborhoods, in a safe and sound manner.

Comment Letter & Template

Comments for the Community Reinvestment Act Proposed Rulemaking are due August 5, 2022. Read IBAT’s comments here

We have also prepared a sample letter that focuses on key issues identified by our team. We encourage you to use it to file your bank’s comments on or before August 5. The letter requires customized messaging for submission. Additionally, you can submit comments using the IBAT Grassroots Action Center

CRA Team

Karen Neeley is IBAT General Counsel and leads a CRA task force comprised of IBAT community bankers.

Shay Iacoponelli is President of the IBAT Education Foundation and is leading the charge in our renewed partnership with CRA Partners. We are working together to reduce incidents of crime in area nursing homes, while offering banks the opportunity to earn CRA credit. 

Investments, Products and Services

Banks other than those defined as “small” must demonstrate their commitment to Community Reinvestment Act expectations through appropriate investments in qualifying activities. In this page, we have collected information on some of these.

U.S. Treasury

Community Development Financial Institutions Fund
Excellent source of qualifying CRA investments, this page includes a link to the list of currently certified CDFIs, which can be sorted by state.
Click Here

OCC

CRA Illustrative List of Qualifying Activities
The OCC has published this non-exhaustive, illustrative list of examples of activities that qualify as community development loans, services, or investments.
Click Here

Cities for Financial Empowerment Fund

Safe, Affordable Bank Accounts
Support for local coalition and financial institution efforts: Bank On National Account Standards that are intended to meet the needs of unbanked and underbanked individuals with safe and appropriate bank accounts.
Click Here

CFPB

Checking Account Access
The CFPB has provided an array of information and guides on checking account access in this press release in 2016.
Click Here

FDIC

Small Dollar Loans
One challenge that banks face is the need of consumers for small dollar loans. This need is currently met too often through payday and title loans. Unfortunately, a small loan program can be challenging for commercial banks. Here is the Interagency Lending Principles for Offering Responsible Small-Dollar Loans (May 2020).
Click Here

FDIC

A Template for Success
For more information about small dollar loan projects, see A Template for Success: The FDIC’s Small-Dollar Loan Pilot Program
Click Here

Resources

The following are a collection of web sites that should be helpful in understanding CRA and its requirements, as well as in identifying activities that will qualify for CRA credit.

CRA Partners

Elder Abuse and CRA Credit
Join CRA Partners to satisfy your bank’s CRA requirements, boost community relations profile and develop new business relationships, while ensuring safe, secure senior living environments, HUD communities and state veterans homes.
Click Here

FDIC

Bankers Resource Center
This page on the FDIC website includes the regulations and supervisory resources.
Click Here

FDIC

CRA Exam Manual
Full PDF of the FDIC's rating system on the bank's CRA performance.
Click Here

FDIC

Community Affairs
This page includes links to Community Affairs Events, Money Smart curriculum, Alliance for Economic Inclusion initiative, Youth Banking Resource Center, Affordable Mortgage Lending Center, FDIC Survey of How America Banks, and a number of “quick links” to other resources.
Click Here

Fed

Consumers and Communities
This page includes consumer resources, community development resources, and research.
Click Here

Fed

CRA Overview
This page includes a wealth of material about the history of the CRA and rulemaking. Its Resources link provides access to links to more banker resources.
Click Here

FDIC

CRA for Directors
FDIC Power Point on CRA developed specifically for bank directors.
Click Here

OCC

FAQs for Bank Customers
List of questions and answers to help educate bank customers on CRA.
Click Here

Interagency

FAQs on CRA
These were published July 25, 2016 as final revisions to earlier FAQs.
Click Here

Texas Association of Community Development Corporations

The Texas Community Development Directory
This is a statewide non-profit membership association of CDC’s and related non-profit, government and for-profit entities. Check out their basic listing for every business or entity that has been identified as engaging in Community Development activities.
Click Here

FDIC

Advisory Committee on Economic Inclusion
This committee was established in 2006 to provide the FDIC with advice and recommendations on important initiatives focused on expanding access to banking services by underserved populations.
Click Here

Financial Literacy

CRA and financial literacy go hand-in-hand. We are often asked by member bankers about opportunities to earn CRA credit through financial literacy, and there are several options that can be helpful. Contact Shay Iacoponelli, President, IBAT Education Foundation for additional guidance.

Money Smart

FDIC
Enhance financial skills and create positive banking relationships. Money Smart has a long track record of success.
Click Here

Jump$tart

A national nonprofit coalition of more than 100 organizations that share a commitment to “financial smarts for students.” Take the Reality Check quiz.
Click Here

Building Wealth

Federal Reserve
A personal finance education resource that presents an overview of wealth-building strategies for consumers, community leaders, teachers and students.
Click Here

Junior Achievement

JA provides ways to get involved whether you’re interested in volunteering, looking for educational materials or looking to help expand the JA mission.
Click Here

MyMoney.gov

FLEC
More than 20 Federal entities with a goal to strengthen financial capability and increase access to financial services for all Americans.
Click Here