In late December 2025, the Office of the Comptroller of the Currency (OCC) proposed supplemental guidance to simplify the strategic plan option for banks with less than $30 billion in assets (“community banks”).
Today, the same strategic plan option is available to all banks that elect to be assessed for Community Reinvestment Act (CRA) performance under an approved strategic plan (as an alternative to an examination under applicable tests). The OCC proposed simplifying the strategic plan process specifically for community banks (those with assets of less than $30 billion) in an effort to make this option more accessible and less resource-intensive for these institutions. The OCC anticipates that more banks will choose the strategic plan option using the simplified approach.
What does the proposed guidance include? Here are some highlights:
- Standardized methods for banks to develop and submit proposed strategic plans for approval (including the Simplified Strategic Plan Form and formalized consultations with the OCC);
- More clarity and practical guidance on drafting measurable goals (using pre-defined “elective” or tailored “custom” goal options, or a combination); and
- A simplified public participation process.
The OCC will accept comments until February 20, 2026.
Takeaways: A formal retraction of the 2023 CRA modernization rule is still pending. In the interim, the OCC’s proposal is an example of how regulators may seek to streamline CRA compliance through guidance, among other clarifications and initiatives intended to make regulatory compliance easier for community banks.
The OCC posed a number of specific questions on the proposed elective and custom goals; activity category goals (community development lending, retail lending, investment, services); weighting methodology; and the Simplified Strategic Plan Form. Banks that submit comments on the proposed guidance have an opportunity to contribute to an improved compliance framework under existing CRA regulations.
Question(s):
- Are you an OCC-supervised community bank? If you are not regulated by the OCC, how might this streamlined approach by the OCC impact your institution’s CRA goal setting?
- Does your bank operate under an approved strategic plan, or have you previously worked at an institution under a strategic plan?
- Based on the categorical questions asked by the OCC, would your bank be more likely or less likely to elect the simplified strategic plan option?
