Current guidance for CRA evals using strategic plan option outlined in bulletin

Guidelines in place now for banking institutions seeking to be evaluated under the Community Reinvestment Act (CRA) using the strategic plan option, or seeking approval to amend an approved CRA strategic plan, were outlined in a bulletin issued Wednesday by the Office of the Comptroller of the Currency (OCC).

Banks may elect to have their performance under the CRA evaluated on the basis of a pre-approved strategic plan that addresses their CRA responsibilities. Under CRA regulations, the strategic plan must be developed in consultation with members of the public, be published for public comment, and contain measurable annual goals. The required contents of a strategic plan and the OCC’s criteria for evaluating a strategic plan are specified in the CRA regulations.

“The CRA strategic plan evaluation option allows a bank to tailor its CRA objectives to the needs of its community and to its own capacities, business strategies, and expertise,” the agency said in Wednesday’s bulletin (2019-39). “Therefore, not all of the factors described in the regulations under other evaluation types would necessarily apply to each strategic plan.”

The bulletin, applicable to national banks, federal savings associations, and federal branches of foreign banking organizations interested in this option, rescinds OCC Bulletin 1996-11, “Community Reinvestment Act: Guidelines for Approval for a Strategic Plan & Wholesale or Limited Purpose Institution”; and Office of Thrift Supervision CEO Memo 268, “Strategic Plan and Wholesale/Limited Purpose Designations Under the CRA.”

The OCC emphasizes that the guidelines do not reflect new requirements but instead summarize the regulator’s process for addressing bank requests for approval or amendment of a CRA strategic plan. The guidelines include information that a bank should provide to substantiate its request; the email address for banks to submit requests; and details on the OCC’s review and approval processes.

OCC Bulletin 2019-39