comment letter

CBA Summary of Final CRA Rule



The Final Rule updates the evaluation framework for banks, with Small Banks defined as those with less than $600 million in assets, Intermediate Banks as those with $600 million to under $2 billion in assets, and Large Banks as those with $2 billion or more in assets. Large Banks are evaluated under the Retail Lending Test, Retail Services and Products Test, Community Development Financing Test, and the Community Development Services Test. Banks operating under CRA strategic plans are still subject to all four evaluations, unless they fall under a limited exception. The majority of the provisions, tests, and definitions of the Final Rule will be implemented on January 1, 2026, with data reporting requirements beginning on January 1, 2027.

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