What changed
In August 2026, the Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation jointly published a proposed rule updating the Community Reinvestment Act (CRA) regulations. The document outlines revisions intended to modernize and clarify existing CRA requirements. As a proposed regulation, it is open for comment and has not yet been finalized or implemented.
Why it matters for compliance testing
This proposed update signals potential shifts in the regulatory framework affecting how covered institutions demonstrate compliance with CRA obligations. For compliance testing teams, understanding these possible changes is important to anticipate adjustments in test design, particularly regarding which populations or activities are subject to evaluation, what evidence may be relevant, and how controls are assessed. Early awareness aids monitoring and preparation without constituting a change in formal test scope.
Possible testing impact areas
Key areas that could be influenced by a final rule include evaluation criteria for community investment and lending activities, definitions of covered populations or geographies, adjustments in evidence requirements such as documentation of policies or procedures, and enhancements in control testing related to CRA compliance. Since the proposal is not final, these represent potential, not mandatory, impact zones.
Evidence and control documentation to map now
Testing teams may find value in inventorying existing evidence categories linked to CRA compliance, such as control descriptions, policies and procedures, monitoring or testing workpapers, population definitions used in current evaluations, and records of issue escalation or exception handling. Mapping these materials can assist in assessing readiness for any future changes without implying immediate revisions.
What not to change yet
Given that the rule is proposed and not finalized, testing programs should avoid altering test parameters, sampling strategies, or evidence requests based on this document alone. Implementing changes before a final rule and corresponding internal policies are issued risks misalignment and non-compliance. Existing tests remain the governing standards until further official updates.
What Rulint should monitor next
Rulint's attention should focus on the publication of the final CRA rule, which will confirm regulatory obligations and effective dates. Additionally, any supplemental agency guidance, supervisory communications, or enforcement activities linked to the new requirements will be important to track. These developments will inform whether and how testing logic should be adapted for compliant and effective monitoring.