The Office of the Comptroller of the Currency (OCC) is reportedly moving to give community banks more time between examinations under the Community Reinvestment Act (CRA), the federal anti-redlining statute that shapes how banks serve low- and moderate-income communities. As reported by Bloomberg Law, based on a May 15 supervisory memorandum obtained by the publication, the OCC has revised its exam cycle expectations for community and small regional banks that demonstrate strong CRA performance.

Longer CRA Exam Intervals for Strong Performers
According to Bloomberg Law’s report, the OCC’s new supervisory policy extends the maximum interval between CRA performance evaluations to 78 months for banks with up to $30 billion in assets that receive “outstanding” or “satisfactory” ratings. Under the prior framework, those institutions generally would not go more than 60 months between CRA exams.

For banks that receive lower CRA ratings, the reported policy maintains closer supervisory attention. Banks rated “needs to improve” may go up to 54 months between exams, while banks in “substantial noncompliance” are expected to receive a follow-up exam within 24 months. In effect, the OCC is rewarding sustained strong CRA performance with more breathing room between exams, while continuing to apply heightened scrutiny to institutions that struggle to meet their CRA obligations.

The CRA itself does not specify how frequently regulators must examine covered institutions. Instead, exam timing has historically been guided by statute and agency policy. As reported by Bloomberg Law, the OCC’s supervisory memorandum references the Gramm-Leach-Bliley Act of 1999, which provides that banks with $250 million or less in assets should generally not be examined more often than every 48 months if they receive a “satisfactory” rating or every 60 months if they receive an “outstanding” rating. The reported policy appears to build on that premise and extend its logic to a broader category of banks.

Our Take

The OCC’s apparent changes to CRA examination frequency, which were foreshadowed in OCC Bulletin 2025-24 (Oct. 6, 2025) concerning the agency’s efforts to update its policies to eliminate mandatory examination activities not required by law or regulation for community banks, come amid a broader recalibration of community bank supervision. The OCC’s move is part of a wider effort by the federal banking agencies, which has been described by the Trump administration as reducing regulatory burdens on smaller institutions and focusing only on material financial risks in the examination process.

The reported extension of CRA exam intervals for certain banks with less than $30 billion in assets represents a potentially meaningful shift in how the OCC approaches supervision under the anti-redlining law, particularly for institutions that consistently achieve “outstanding” or “satisfactory” ratings and will now be further rewarded for those CRA ratings. Extended CRA exam intervals will give banks incremental opportunities to monitor and self-test CRA performance, and then implement further improvements before the next exam date.  However, OCC-supervised institutions with an existing CRA rating of “needs to improve” or “substantial noncompliance” that seek to quickly improve their rating may not find the longer examination intervals beneficial.