OCC Publishes 12 CFR Part 25 CRA Framework Covering Scope, Definitions, and Asset Size Thresholds

Key Takeaways

• The OCC's 12 CFR Part 25 sets out the Community Reinvestment Act framework, including authority, scope, and an extensive definitions section that determines how banks are classified and evaluated.
• The excerpt covers only Subpart A (§§ 25.11 and part of 25.12) and is truncated mid-definition, so compliance teams should confirm the full text and current effective dates before acting.

Deep Dive

The OCC's 12 CFR Part 25 sets out the Community Reinvestment Act framework, including authority, scope, and an extensive definitions section that determines how banks are classified and evaluated. The excerpt covers only Subpart A (§§ 25.11 and part of 25.12) and is truncated mid-definition, so compliance teams should confirm the full text and current effective dates before acting.

The definitions section drives institution classification and exam scope. An intermediate bank has at least USD $600 Million in assets as of December 31 in both of the prior two calendar years and less than USD $2 Billion in either of those years. A large bank has at least USD $2 Billion in assets in both of the prior two years. The OCC adjusts these thresholds annually using the CPI-W. The definitions also set up the Retail Lending Test framework: product lines (closed-end home mortgage, small business, small farm, and automobile loans), major product lines, majority automobile lender status, facility-based assessment areas, and outside retail lending areas. Other key terms include deposit data collection and deposit location, community development loans, investments, and services, and income-level tiers (low below 50 percent, moderate 50 to under 80 percent, middle 80 to under 120 percent, and upper 120 percent or more of area median income).

The excerpt gives no new compliance dates. Its source citations show the Subpart A amendments published February 1, 2024 (89 FR 7165 and 89 FR 7166), with a cross-reference to a further amendment at 89 FR 7167. The underlying 2021 final rule is 86 FR 71339. Because the text is cut off at "Reported loan means," and this version is dated September 14, 2026, teams should check eCFR and Federal Register notices for current applicability dates, any stays or litigation affecting the rule, and any rescission or revision.

Recommended actions:
- Confirm the institution's asset-size classification, and monitor the annual CPI-adjusted thresholds.
- Verify whether any special purpose or limited purpose designation applies.
- Map assessment areas and retail lending areas against the definitions.
- Confirm that data governance can support loan location, deposit location, and product line categorization.
- Evaluate whether the institution collects and reports deposits data, since that choice changes the definitions of deposits and deposit location.
- Review how community development activities, including affiliate and volunteer services, are tracked and documented.
- Obtain the complete regulatory text to analyze Subparts B through F and Appendices A through G.

Risk implications: Misclassification or data errors could lead to an incorrect exam type, weak CRA ratings, and adverse effects on expansion and merger applications. Reputational and supervisory risk is also significant, given the heavy data and geographic-mapping demands.

Source: Office of the Comptroller of the Currency