Leaders from Wolters Kluwer Financial & Corporate Compliance and FairPlay examine how data, analytics, and AI-powered intelligence can help financial institutions better evaluate lending opportunities, improve exam performance, and drive more informed decisions that benefit both communities and the balance sheet.
The Community Reinvestment Act (CRA) was established to help ensure that lending institutions meet the credit needs of the communities they serve, including low- and moderate-income neighborhoods. CRA performance is evaluated by federal regulators and plays an important role in an institution’s regulatory standing, influencing everything from merger approvals to reputation and stakeholder confidence. For lending institutions, earning a strong CRA rating is both a compliance objective and a reflection of their commitment to community development.
Craig Crabtree, CEO of Wolters Kluwer Financial & Corporate Compliance, and Kareem Saleh, Founder and CEO of FairPlay, believe that with the right data, technology, and market intelligence, CRA performance can also become a source of growth and competitive advantage. That belief has helped shape the companies' recently expanded partnership, which brings together Wolters Kluwer's decades of regulatory compliance and fair lending expertise with FairPlay's innovative AI and analytics capabilities to help institutions better understand, manage, and improve CRA performance.
Here, Crabtree and Saleh discuss how their complementary technologies are empowering lending institutions to take a more strategic approach to CRA, by making it easier to evaluate opportunities, strengthening examination readiness, and supporting data-informed CRA decision-making that delivers stronger outcomes for institutions and the communities they serve.
A conversation with Craig Crabtree and Kareem Saleh
Q: Craig, what factors make effectively managing CRA performance so challenging?
Craig Crabtree: Earning an Outstanding CRA rating is about much more than checking regulatory boxes. Institutions must identify and document qualifying activities, measure community impact, maintain data integrity, and demonstrate results across diverse markets, all while balancing business growth and evolving compliance requirements. At the same time, regulators, boards, and executive teams want a clear understanding of how the institution is performing relative to its peers and where opportunities exist to strengthen results. The challenge is that many institutions still lack the centralized data, visibility, and analytics needed to connect all those dots. With CRA-related activity often spread across multiple departments, uncovering opportunities, measuring impact, and making informed decisions can be difficult without the right technology and insights.
Q: Wolters Kluwer and FairPlay recently expanded your relationship. How does your alliance help lending institutions address those challenges?
Craig Crabtree: Our two organizations initially came together to help lenders strengthen their fair lending programs, by partnering Wolters Kluwer’s Fair Lending Wiz analytics with FairPlay’s AI-powered capabilities for identifying, addressing and documenting potential disparities in lending decisions. Now, we’re expanding our relationship into CRA, to provide institutions with both an internal and external view of their performance.
Our Wolters Kluwer Wiz Suite platform helps institutions manage and measure their own CRA performance and improve exam readiness through data collection, analysis, and reporting. FairPlay’s AI-powered CRAi platform provides institutions with the market intelligence and benchmarking capabilities they need to understand how their CRA performance compares with peers, and where the best lending opportunities to serve historically underserved communities may exist.
Together, our technologies provide a more complete view of CRA performance, empowering institutions to meet regulatory expectations, make better decisions about future lending strategy, and expand access to credit in a responsible, data-driven way.
Q: Many lending institutions assume improving a CRA rating requires deploying more capital. Is that an accurate assumption?
Kareem Saleh: Not necessarily. When FairPlay analyzed more than 80,000 CRA exams and matched them to publicly available financial data, we found that institutions receiving Outstanding ratings often looked very similar financially to institutions receiving Satisfactory ratings. What often separates them is their ability to identify the right opportunities, understand how they compare with peers, and ensure qualifying activities are recognized during the examination process. In many cases, the difference is strategy, execution, and visibility, rather than balance sheet size. That's where data-driven tools and AI-powered insights can help institutions identify overlooked opportunities, understand their performance relative to peers, and build a stronger CRA strategy without simply committing more capital.
Q: One theme that comes up repeatedly in CRA discussions is benchmarking. Why is that so important?
Kareem Saleh: CRA benchmarking is important because context matters. A bank operating in a high-cost urban market faces very different circumstances than a bank serving a rural community. That’s why national averages often don't tell the whole story. What institutions really need is a way to compare themselves against peers with similar market characteristics, operating footprints, and opportunities. That kind of benchmarking is what CRAi provides. It helps institutions create lending strategies that are realistic and achievable rather than pursuing metrics that may not fit their market.
Q: Where do institutions have the greatest opportunity to improve CRA performance?
Craig Crabtree: The biggest opportunity is often identifying lending and investment activities that create meaningful community impact while also aligning with business objectives. Many institutions already have capital available. The challenge is knowing where to deploy it for the greatest impact. Whether it's affordable housing, community development projects, or support for CDFIs, the most successful lenders are making decisions based on data, market opportunities, and a clear understanding of what is likely to matter most during an exam.
For many institutions, CRA has traditionally been viewed as a cost center. But with the right data, technology, and market intelligence, it can become a source of growth and competitive advantage. When institutions have greater visibility into qualifying opportunities, community needs, and peer performance, they're in a much stronger position to deploy capital strategically in ways that benefit both the communities they serve and the institution itself.
Q: Proposed changes from the FDIC and OCC have created uncertainty across the industry. What should CRA officers and lending teams be doing right now?
Craig Crabtree: The first priority is continuing to comply with the rules that exist today. At the same time, institutions should be evaluating how proposed changes from the FDIC and OCC could affect their CRA strategy. They should be asking questions such as: Would our assessment change under a different framework? How would peer comparisons shift? Are there community development opportunities we should be evaluating now? The most future-ready institutions aren't waiting for a final rule. They're using data to model potential outcomes so they can make informed decisions when the next regulatory shift arrives.
Q: Kareem, speaking of regulatory shifts, you've said before that institutions shouldn't build their strategy around every regulatory swing. Why?
Kareem Saleh: As we have all seen over the past decade, and most recently in the 2026 election cycle, the political pendulum never stops swinging, and the regulatory compliance pendulum tends to swing with it. We've seen major CRA revisions proposed, delayed, challenged, rescinded, and revised again and again over the years. Institutions that chase every shift often end up spending enormous time reacting instead of building long-term capability.
The better approach is to build a strategy that works under a variety of regulatory scenarios. The fundamentals remain consistent: understand your market, identify qualifying opportunities, benchmark yourself against peers, and make informed decisions about capital deployment.
The right technology can help lenders model proposed changes and prepare for different outcomes, but the goal isn't to predict the next regulatory cycle. The goal is to create a stronger CRA program no matter how and when the pendulum swings.