Banking and Finance Law Daily Wrap Up, COMMUNITY DEVELOPMENT—NCRC analyzes community reinvestment strategic plans, (Apr 7, 2026)
Organizations Mentioned:National Community Reinvestment Coalition
“CRA strategic plans offer a path for institutions to tailor their community investment responsibilities in a transparent and accountable manner,” the organization said.
The National Community Reinvestment Coalition has released an analysis of community reinvestment strategic plans, offering “to work with institutions to develop strategies that prioritize the needs of their communities.” The Community Reinvestment Act (CRA) requires financial institutions to meet the credit needs of the communities they serve while implementing regulations establishing five methods for evaluating banks’ compliance. One method of compliance is a strategic plan which replaces CRA tests with tailored performance goals developed by the bank with community input.
According to the NCRC, “[a] CRA strategic plan allows a bank to propose its own measurable goals for CRA responsibilities to meet community credit needs in lieu of being evaluated under the standard lending, investment, and service tests.” An approved strategic plan becomes a bank’s CRA evaluation framework for a set period of time, customarily three to five years, and can provide additional flexibility and clarity for CRA compliance.
A CRA strategic plan must include:
measurable annual goals;
an evaluation period of not more than five years;
performance context factors; and
defined assessment areas with specific goals.
The NCRC additionally stressed the importance of public participation, including an opportunity for a public review and comment period. In that regard, a bank must, among other requirements, formally solicit public comment on a draft strategic plan for at least 30 days before its submission, and submit all public comments to the bank’s CRA regulator together with the plan and the bank’s written response. If the plan is approved in accordance with a specified regulatory review process, the bank must then comply with a number of continuing obligations with respect to the plan.
The NCRC noted that while the strategic plan framework is flexible enough for institutions to tailor CRA goals to their community’s needs, several structural weaknesses could undermine its effectiveness, including a lack of community engagement, minimum goal setting, and limited geographic scope. Meaningful community reinvestment, on the other hand, should incorporate robust community input, measurable and time-bound goals, prioritized staffing reflecting the communities being served, and the creation of a community advisory council.
Companies: National Community Reinvestment Coalition
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