LOS ANGELES – November 02, 2026 -- Raising the Community Reinvestment Act small-bank threshold to $10 billion in assets would leave more than 2.6 million additional people in census tracts where no bank is evaluated for community development, according to a new interactive map from NAAHL and FairPlay AI.
The NAAHL CRA Coverage Map is publicly available and built on FairPlay's CRAi platform. It shows how the rule proposed by the OCC and the FDIC would change the number of banks evaluated for community development in each census tract. NAAHL used the same analysis in comments it filed with the agencies on October 13.
Proposal would lift small-bank cutoff to $1 billion and large-bank cutoff to $10 billion
Under the proposal, the small-bank threshold would rise from $412 million to $1 billion in assets. The large-bank threshold would climb from $1.649 billion to $10 billion. Banks with $1 billion to $10 billion in assets would become intermediate banks, evaluated under a lending test and a community development test rather than separate lending, investment and service tests.
The agencies also requested comment on a broader alternative. It would define small banks as those under $10 billion in assets and large banks as those at $30 billion or more.
About 400 banks holding 7% of deposits made 19% of community development loan dollars
NAAHL estimates that about 400 OCC- or FDIC-regulated banks would shift from the large-bank framework to the intermediate category under the agencies' proposal. Those banks hold about 7% of deposits nationwide. They reported $25.9 billion in community development loans in 2024, or 19% of national dollar volume.
Broader alternative would add 1,385 small banks and strip tests from more tracts
If the small-bank threshold rose to $10 billion, 3,673 banks would be classed as small banks with no community development test, up from 2,288 under current thresholds. More than 31 million people live in census tracts where five or fewer banks evaluated for community development.
Banks with less than $30 billion in assets made nearly $53.5 billion in community development loans in 2024. That is more than a third of community development lending by dollar volume and nearly two-thirds by number of loans. CRA-motivated investors supplied about 80% of the equity for Low-Income Housing Tax Credit projects that year.
FairPlay's CRAi consolidates scattered federal datasets
CRAi pulls together FFIEC CRA disclosure files, FDIC and FFIEC call reports, the FDIC Summary of Deposits, CRA performance evaluations from the FDIC, OCC and Federal Reserve, and U.S. Census Bureau data. NAAHL contributes input from members including banks, community development financial institutions and other affordable housing lenders.
FairPlay founder and CEO Kareem Saleh said the debate over CRA thresholds usually counts banks, while "this map counts people." NAAHL President and CEO Sarah Brundage warned that blunt changes to CRA could carry unintended consequences for families and said the map shows policymakers where the effects would be felt most.
NAAHL also joined more than 475 organizations across all 50 states in a letter urging the OCC and FDIC to keep meaningful community development responsibilities for banks of all sizes.