On December 17, 2025, the Office of the Comptroller of the Currency (OCC) issued proposed guidance aimed at simplifying the strategic plan process under the Community Reinvestment Act (CRA) for community banks. The proposal, accompanied by an 80+-page supplemental guidance document, seeks to clarify expectations for measurable goals and the components required for regulatory approval.
Within the CRA framework, the strategic plan option allows a bank to establish regulator-approved, measurable CRA objectives in advance, rather than being evaluated solely through retrospective examination of lending, investment, and service activity. Once approved, the strategic plan becomes the benchmark against which CRA performance is assessed over a multi-year period.
The timing of the proposal is notable. It follows a year of sustained regulatory activity, including the proposal to rescind the CRA Final Rule issued in October 2023, which restored emphasis on the long-standing 1995 CRA framework.
Against that backdrop, renewed attention to the CRA strategic plan option is particularly telling. Strategic plans have existed for decades as an alternative evaluation path, yet they have remained peripheral for most institutions, less because of relevance than because of the difficulty banks have faced in operationalizing them with confidence.
A marginal option by the numbers
Despite being available for decades, the CRA strategic plan option has been adopted by only a small segment of the industry. As of now, just 14 OCC-supervised banks are operating under an approved CRA strategic plan. That number does not materially increase when viewed across regulators. The Federal Deposit Insurance Corporation (FDIC) lists 44 institutions with approved strategic plans, and the Federal Reserve lists 11. In total, fewer than 70 banks nationwide are using the strategic plan framework across all three federal banking agencies.
This limited adoption is notable because the strategic plan option is explicitly designed to provide flexibility. It allows banks to:
- Set measurable CRA goals aligned to their business model
- Calibrate performance expectations to their community footprint
- Establish evaluation criteria in advance of examination
In theory, these features should appeal to community banks seeking predictability and alignment between CRA performance and institutional strategy. In practice, availability has not translated into widespread adoption.
A fundamentally different CRA evaluation model
Part of the disconnect lies in how different the strategic plan option is from traditional CRA examination frameworks. A strategic plan is not simply an alternate scoring mechanism; it represents a fundamentally different sequence for evaluating CRA performance.
Under a strategic plan, the evaluation process is effectively conducted in reverse:
- The institution engages with community stakeholders.
- Local credit needs and opportunities are identified.
- A multi-year plan with measurable goals is developed.
- The regulator approves the plan before implementation.
Once approved, the strategic plan becomes the benchmark against which CRA performance is assessed. Expectations are set upfront, before activity occurs.
Traditional CRA examination frameworks, by contrast, are retrospective. Banks first conduct their lending, investment, and service activities. Examiners then evaluate those activities in context and determine how well outcomes align with community needs, assigning a CRA rating after the fact. In this model, intent and alignment are inferred rather than established in advance.
The strategic plan option allows institutions to invert that process: align expectations first and execute second. While this structure offers greater clarity in theory, it has long been perceived as resource-intensive and procedurally complex. Uncertainty around approval standards and examiner interpretation, combined with the multi-year commitment involved, has historically outweighed the perceived benefits for many institutions.
What simplification is and is not trying to solve
Viewed in this context, the OCC’s proposal to simplify the strategic plan process appears less about introducing a new compliance pathway and more about addressing a long-standing usability problem. The proposal implicitly acknowledges that the barrier has been operational, not conceptual.
At the same time, it is important to read the fine print. While the proposal discusses simplification and, in some cases, relief from certain procedural requirements, it does not operate as a blanket waiver of CRA-related obligations. A footnote in the proposal explicitly references 12 CFR 25.42, the regulation governing CRA data collection, reporting, and disclosure requirements, including small business and small farm lending data.
That reference is consequential. It signals that while the OCC may be willing to streamline how strategic plans are developed and approved, foundational CRA data obligations remain intact. Simplification should not be interpreted as an erosion of underlying CRA data expectations, but rather as an attempt to make the strategic planning framework more navigable within existing regulatory guardrails.
This distinction matters for institutions evaluating whether a strategic plan could meaningfully change their CRA posture. The proposal appears aimed at reducing process friction and uncertainty, not redefining the informational baseline used to assess CRA performance.
Practical considerations as the 2025 regulatory year closes
For banks evaluating the OCC’s proposal, the more useful question is not whether the CRA strategic plan option has changed, but whether the surrounding conditions have shifted enough to warrant reconsideration.
Several considerations may be relevant:
- Revisiting prior decisions: Institutions that previously explored, and ultimately decided against, the strategic plan option often cited complexity, approval risk, or long-term rigidity rather than misalignment with CRA objectives. Clarified expectations may alter that cost-benefit analysis.
- Engaging in the comment process: Strategic plans are inherently grounded in local context, community needs, market dynamics, and institutional capacity. Institutions that have firsthand experience with these dynamics, including those that considered strategic plans but opted out, are well positioned to inform the OCC about what has historically limited adoption and what would make the option more practical.
- Assessing timing and readiness: While the proposal carries a 60-day comment period, longer than some abbreviated windows seen this year, it remains relatively short given the operational implications. That increases the likelihood that the guidance will be finalized largely as proposed. As a result, institutions may benefit from beginning to assess now what a simplified strategic plan framework could mean for their CRA governance, community engagement, and long-term strategy.
As the year closes, the OCC’s proposal adds another data point to an already full regulatory landscape. It does not demand immediate action, but it does invite reflection. For banks that view CRA as an exercise in alignment — rather than a retrospective scoring exercise — this moment may warrant renewed attention to a tool that has long existed, but rarely been used.
Frequently Asked Questions
What is the CRA strategic plan option?
The CRA strategic plan option is an alternative CRA evaluation framework that allows a bank to establish regulator-approved, measurable CRA goals in advance, which then serve as the basis for evaluating CRA performance over a multi-year period.
Does the OCC’s proposed guidance eliminate CRA data requirements?
No. The proposal references existing regulations, including 12 CFR 25.42, indicating that CRA data collection, reporting, and disclosure requirements remain in effect despite efforts to simplify the strategic plan process.
Which institutions may benefit most from reconsidering a CRA strategic plan?
Community banks seeking greater alignment between CRA performance expectations, community engagement, and long-term business strategy may find the strategic plan option more relevant if approval standards and procedural expectations are clarified.
