What Proposed Changes to the Community Reinvestment Act Could Mean for Our Communities

For nearly 50 years, the Community Reinvestment Act (CRA) has played an important role in encouraging financial institutions to invest in the communities they serve. Today, proposed changes to CRA regulations by the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC) deserve the attention of housing advocates, community organizations, financial institutions, and Pennsylvania residents.

Why the Community Reinvestment Act Was Created

Congress enacted the CRA in 1977 during a period when many low- and moderate-income neighborhoods struggled with disinvestment and limited access to mainstream credit. The legislation emerged against the backdrop of redlining and other practices that contributed to households and entire neighborhoods being denied access to mortgage credit and financial services.

The basic principle behind the CRA was straightforward: financial institutions have an obligation to help meet the credit needs of the communities in which they operate, including low- and moderate-income neighborhoods, while continuing to make loans in a safe and sound manner.

Over the decades, CRA has helped encourage partnerships between banks and community organizations like AHCOPA  that understand the needs of local residents. Those partnerships have supported the development of affordable housing units, the creation of small businesses, financial education, housing counseling, and responsible pathways to homeownership.

For organizations like AHCOPA, CRA has also helped create an ecosystem in which financial institutions and nonprofit housing organizations can work together. Banks provide affordable mortgage products, down payment assistance, financial support, and community investment, while HUD-approved housing counseling agencies help households improve credit, manage debt, establish savings, understand mortgage options, and prepare for the responsibilities of homeownership.

CRA helps encourage these relationships.

Why the Proposed Changes Concern Us

In the summer of 2026, the FDIC and OCC proposed significant changes to their CRA regulations. The agencies have stated that their objective is to reduce unnecessary regulatory burden, provide greater clarity, and refocus CRA on lending. We recognize that regulations should periodically be reviewed and improved.

However, modernization should not come at the expense of accountability or community investment.

The proposed changes include substantially higher asset thresholds for determining how banks are evaluated, reduced data collection and reporting requirements for certain institutions, greater emphasis on a bank’s major lending products, and changes to how community-development grants receive CRA consideration.

One provision is particularly concerning to nonprofit organizations. Under the proposal, large banks seeking CRA consideration for community-development grants would need to document that a recipient’s overhead costs do not exceed 15 percent.

A rigid overhead threshold could unintentionally discourage banks from supporting organizations with the capacity and infrastructure necessary to deliver meaningful results.

Modernize CRA Without Abandoning Its Purpose

The financial system of 2026 looks dramatically different from the financial system of 1977. Online banking, fintech companies, interstate banking, nonbank mortgage lenders, and consolidation have transformed how Americans obtain financial services. CRA should evolve accordingly.

But its fundamental principle remains relevant: communities that provide deposits, customers, workers, and economic opportunities to financial institutions should have meaningful access to credit and investment.

Pennsylvania communities still need affordable mortgage products. They still need down payment assistance. They still need small-business lending, affordable housing investment, foreclosure prevention, financial education, and housing counseling.

As federal regulators consider changes to CRA, AHCOPA believes modernization should strengthen—not diminish—the partnerships, transparency, accountability, and investments that help low- and moderate-income households build financial security and achieve sustainable homeownership.

Nearly 50 years after CRA was enacted, its central promise remains important: access to responsible credit and financial opportunity should extend to every community.

Take Action

Community members and organizations can make their voices heard as federal regulators consider these proposed changes. National Community Reinvestment Coalition (NCRC) has resources to help individuals and organizations submit comments, contact members of Congress, and reach out to state and local leaders.