In its January 5, 2026 release, the Office of the Comptroller of the Currency (OCC) identified 15 institutions rated “Outstanding” among Community Reinvestment Act (CRA) performance evaluations made public in December 2025.
Across these evaluations, the OCC most often attributes “Outstanding” ratings to strong lending distribution results, community development activity framed as leadership or responsiveness, and, in some cases, explicitly identified innovative or flexible products or investments. These conclusions appear in the “major factors” or conclusions sections and reflect how examiner judgments are summarized.
For institutions seeking to understand what drives these outcomes, the most reliable approach is to focus on what the OCC explicitly labels as major factors, rather than inferring intent or weighting beyond the written evaluation.
The consistent drivers across these Outstanding evaluations are not generic “good community impact” statements. They are recurring examiner-scored performance elements that appear in the OCC’s major-factor bullets.
Across both small-bank style lending tests and large-bank lending tests, the OCC repeatedly points to:
Where the evaluation structure includes multiple tests, the OCC explicitly notes that the Lending Test is weighted more heavily in arriving at the overall rating.
Practical read: The banks earning “Outstanding” are frequently those where the OCC can state, in plain terms, that distribution patterns are strong, a term tied to excellent performance, under the relevant test framework, and that those conclusions are backed by the evaluation’s data and comparisons.
Several Outstanding evaluations highlight either leadership in CD lending, or excellent responsiveness to CD needs through a combination of CD loans, investments, and services:
Practical read: “Outstanding” write-ups frequently elevate CD activity when it is both material and easy to connect to community needs, rather than simply present.
A subset of evaluations explicitly credits:
Practical read: This is not universal across all Outstanding banks in this release, but when the OCC includes it, it is treated as a supporting factor that differentiates performance.
The OCC’s “major factors” are not only explanatory. They show how CRA performance is framed, supported, and ultimately summarized in an examination. Financial institutions can use this language as a reference point for evaluating their own documentation, performance narratives, and peer comparisons.
Because the OCC frequently summarizes the rating rationale in a short list, CRA teams can pressure-test whether their own program can be described in the same examiner-ready way:
An “Outstanding” outcome reflects the OCC’s conclusions within the specific evaluation method, assessment area design, product mix, and performance context for that institution. The safest use of these evaluations is to extract repeatable documentation patterns and consistent strong indicators, not to assume the same activities will produce the same rating elsewhere.
The OCC’s January 5, 2026 CRA release lists 15 institutions with “Outstanding” ratings: USAA Federal Savings Bank; Crystal Lake Bank & Trust Company, N.A.; Libertyville Bank & Trust Company, N.A.; Home Bank S.B.; Argentine Federal Savings; Cumberland Valley National Bank & Trust Company; First & Farmers National Bank, Inc.; Winter Hill Bank, F.S.B.; Western National Bank; The First National Bank of Gordon; M.Y. Safra Bank, F.S.B.; JPMorgan Chase Bank, N.A.; American First National Bank; American Express National Bank; and National Bank of Commerce.
Across these evaluations, the OCC most often cites strong lending distribution results (geographic and borrower), lending inside the assessment area, and community development activity framed as leadership or responsiveness through CD loans, qualified investments, and CD services.
Some institutions are evaluated under different CRA frameworks (for example, strategic plan or limited purpose evaluations). In those cases, the OCC’s major factors can focus more heavily on qualified investments and community development services, consistent with the institution’s evaluation method and business model.
