On December 17, the Office of the Comptroller of the Currency (OCC) proposed new guidance that would significantly streamline how community banks elect to be evaluated under the Community Reinvestment Act (CRA) by providing a simplified strategic plan form. Framed as part of Comptroller Gould’s broader initiative to reduce regulatory burden on community banks, the proposal would make the strategic plan option more accessible, more predictable, and less resource‑intensive for smaller institutions.

Background

The CRA requires the OCC and other federal banking agencies to assess how banks help meet the credit needs of the communities from which they draw deposits, including low- and moderate-income neighborhoods, consistent with safe and sound operation. Traditionally, that assessment is conducted under standardized performance tests and standards (e.g., the small bank test, large bank lending/investment/service tests, and wholesale/limited purpose bank tests).

Community banks have long raised concerns that CRA examination framework can be opaque, qualitative, and difficult to manage against, particularly for smaller institutions with limited compliance staff or nontraditional business models. While the CRA regulation already allows any bank to opt into a customized “strategic plan” evaluation, in practice relatively few have done so. The process has often been seen as complex, consultant‑heavy, and uncertain.

The OCC’s Proposal

The OCC’s proposed guidance does not change the underlying CRA regulation. Instead, it layers on an optional, more user‑friendly process and form for community banks that want to use a strategic plan.

  1. A “Simplified Strategic Plan Form”

Rather than asking banks to draft bespoke plans from scratch, the OCC would provide a standardized form that:

  • Captures all information required under the existing strategic plan provision, including measurable goals, performance context, assessment areas, public participation, and effective dates; and
  • Builds in agency-developed examples of measurable goals (elective goals) that reflect performance levels the OCC has historically viewed as “Satisfactory” or “Outstanding” for community banks.

Community banks could adopt these elective goals where appropriate or develop their own customized goals. The form is intended to reduce guesswork about what needs to be included, and to minimize back‑and‑forth with the OCC over missing information.

The OCC is considering implementing the form initially as a fillable PDF, with a possible transition to a more sophisticated web‑based tool that could automatically generate a plan document from the data entered.

  1. Clearer, More Practical Guidance on Measurable Goals

Current CRA guidance provides only high-level direction on what “measurable goals” should look like. As a result, many banks have felt compelled to hire outside consultants to design strategic plans, particularly to set reasonable “Satisfactory” and “Outstanding” performance levels.

The proposed guidance would:

  • Offer specific, exam-tested elective goals across lending, investment, and service categories (for example, community development lending as a percentage of Tier 1 capital or total assets, or ranges of retail lending to LMI borrowers or geographies);
  • Allow those elective goals to be converted into dollar thresholds over a multi‑year plan, with built‑in growth assumptions where appropriate; and
  • Preserve flexibility for banks to design custom goals that reflect unique business models, markets, or products, including goals focused on highly impactful activities like grants or innovative community development investments.

Crucially, these elective goals are not safe harbors. The OCC would still review each plan in light of performance context and public comments, but the agency is signaling in advance what types of goals it has generally found reasonable for similarly situated community banks.

  1. A More Robust and Useful Consultation Process

Historically, OCC “consultations” on draft strategic plans were limited to process and format, not the merits of the goals themselves. Under the simplified process, the OCC would formalize what has already become its informal practice: providing timely, initial feedback on both the structure of a draft strategic plan and the proposed measurable goals, in light of the bank’s capacity, constraints, business strategy, and community needs.

  1. Same Public Input, Streamlined Documentation

The CRA regulation’s public participation requirements would remain in place. What would change is how banks document that process.

Under the simplified process, a community bank would:

  • Use the first stage of the Simplified Strategic Plan Form to generate a draft plan for public comment; and
  • After the comment period, complete the second stage of the form, certifying compliance with public participation requirements and explaining how public input was considered.

Banks would not have to submit newspaper notices and publication dates, and the OCC could verify compliance as needed.

Comments on the proposed guidance will be accepted until February 20.