Important CRA Lesson from OCC proposal for all Intermediate-Small and Large Banks

Len explains that the OCC issued a December 18, 2025 proposal to create a “Simplified Plan Process for Community Banks” to make the CRA strategic plan option easier, but he believes its real value extends beyond banks using strategic plans because it reveals how regulators think about “Satisfactory” and “Outstanding” performance under normal CRA standards. The proposal distinguishes between “custom” bank-specific goals (which Len says offers little practical guidance) and “elective” goals, which are quantifiable targets drawn from approved plans and OCC supervisory experience. Len highlights that the most useful—and historically murky— CRA test is Community Development. The OCC's proposal provides explicit benchmarks for CD lending, investing, combined lending/investing, and CD services, using ratios tied to Tier 1 capital or total assets (including notably lower investment thresholds when a bank relies heavily on donations, acknowledging their significance). He notes the proposal also introduces measurable expectations for CD service hours per employee, while offering little new insight on traditional lending tests. Although the OCC states elective goals are not “safe harbors” and not formal benchmarks outside the simplified process, Len argues they align with what regulators historically expect and can help CRA officers set internal performance targets;  this is where you would provide a linik to the 67 tests, performance standards and ratings. https://geodatavision.com/content/occ-proposed-elective-goals-for-cra-strategic-planning/


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