Reference: Bulletin 2025-48
{
“meta_title”: “OCC Bulletin 2025-48 Updates CRA Thresholds”,
“meta_description”: “New CRA asset thresholds effective 2026. OCC Bulletin 2025-48 adjusts classification. Review compliance before Jan 1 deadline.”,
“content_html”: “
On December 23, 2025, the Office of the Comptroller of the Currency, commonly referred to as the OCC, released a significant regulatory update contained within Bulletin 2025-48. This document serves as a critical update to the regulatory framework governing the Community Reinvestment Act (CRA). The bulletin addresses the long-standing issue of inflation erosion on asset thresholds, ensuring that regulatory classifications remain relevant in a volatile economic environment. By incorporating Consumer Price Index adjustments, the OCC aims to level the playing field for financial institutions that serve low-income and underserved communities. This guidance provides essential clarity for small and intermediate-sized banks regarding their obligations and classifications under the CRA.n
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Executive Summary
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The primary objective of OCC Bulletin 2025-48 is to modernize the CRA asset size thresholds that determine how institutions are classified and examined. The core change involves the effective date of January 1, 2026, at which point the new standards will apply universally. The adjustment mechanism relies on specific CPI data to recalibrate the dollar amounts used to define ‘Small Banks’ and ‘Intermediary Small Banks’. This update is not merely a technicality but a strategic shift that acknowledges the changing economic landscape over the last decade. Institutions must review their asset totals against these new benchmarks to ensure they are categorized correctly. Misclassification can lead to examination cycles that do not align with the actual complexity or reach of the institution. Therefore, immediate attention to asset classification is required to avoid compliance gaps. The guidance explicitly states that compliance timing is crucial, with specific deadlines for updating CRA plans and internal policies. Furthermore, the bulletin addresses the impact of inflation on asset growth, ensuring that institutions are not unfairly penalized for organic growth in a high-inflation era. Banks must also communicate with their boards of directors about these changes to ensure governance alignment. Finally, the guidance emphasizes the importance of monitoring inflation trends and CPI updates to anticipate future regulatory adjustments.n
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What the Regulator Issued
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The regulator, the OCC, has finalized the revisions to the CRA asset size thresholds under Bulletin 2025-48. The official link to the bulletin is available on the OCC’s website, specifically within the Consumer Finance and Regulatory Programs section. The document details the specific methodology for the adjustment, which is based on the Consumer Price Index (CPI). Historically, the CRA thresholds were set at fixed dollar amounts that did not account for inflation. Over time, this led to a situation where banks that grew organically might fall below the threshold intended for their previous classification, effectively downgrading their CRA status. The new approach utilizes the CPI to adjust the thresholds, ensuring that the regulatory treatment remains fair. The adjustment mechanism is formulaic, ensuring transparency and predictability for the regulated community. The bulletin outlines the exact CPI data used and the date range for which the adjustment applies. This ensures that the adjustments are based on robust statistical data rather than arbitrary changes. The OCC explains that this change is necessary to maintain the integrity of the CRA examination process and to ensure that community development lending standards are applied appropriately to institutions of varying sizes. The guidance is available for public comment periods prior to the effective date, allowing stakeholders to provide feedback on the implementation details.n
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Who Is Impacted
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The scope of the revised thresholds covers all national banks, federal savings associations, and federally chartered institutions. Additionally, certain state-chartered banks that are members of the Federal Reserve System or are otherwise subject to OCC supervision are included in the scope of this guidance. The classification changes specifically impact ‘Small Banks’ and ‘Intermediary Small Banks’ as defined by the CRA. A ‘Small Bank’ is generally defined as an institution with total assets below a certain threshold, while an ‘Intermediary Small Bank’ sits in the next tier. The exact dollar amounts for these thresholds are being revised upward to reflect inflation. This means that a bank previously classified as a ‘Small Bank’ due to the inflation-adjusted thresholds might now qualify for a different classification or, conversely, might remain ‘Small Bank’ despite higher asset growth. The guidance clarifies that the classification determines the complexity of the CRA examination cycle. A bank classified as ‘Small’ faces a less rigorous examination than one classified as ‘Large’. Therefore, these changes have profound implications for the frequency and depth of exams. State-chartered institutions that are not members of the Federal Reserve but are supervised by the OCC are also subject to these revisions, though the specific implementation may vary based on state regulations. The bulletin does not mention impact on state-chartered non-members in the same manner as member institutions, but the guidance generally applies to those under OCC jurisdiction. The definition of ‘Intermediate Small’ is also subject to revision, ensuring that banks in this tier are not inadvertently downgraded. The guidance emphasizes that the CRA is part of the Home Owners Loan Act of 1933, and these updates are designed to honor the spirit of that original legislation while adapting to modern economic realities.n
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Key Dates
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The timeline for compliance is strict. The publication date of the bulletin was December 23, 2025. However, the changes are not retroactive to the publication date. The effective date is January 1, 2026. This means that for the year 2025, institutions should operate under the existing thresholds. Once the clock ticks to January 1, 2026, all institutions must apply the new thresholds to their asset calculations. This transition period provides a six-month grace period for compliance adjustments, allowing banks to reclassify their assets and update their CRA assessment areas. Banks must ensure that their annual CRA reports, filed through the appropriate regulatory portals, reflect the new classifications. The guidance also suggests that institutions should review their past exam findings to see if previous classifications were accurate under the new standards. If a bank was previously downgraded due to inflation effects that are now corrected, the bank should be prepared to discuss this with the examiner. The OCC encourages institutions to begin preparing for the transition immediately after the publication of the bulletin. The compliance timeline extends into 2026, with the full impact felt throughout the regulatory year. Banks must align their CRA plans with the new asset size definitions to avoid penalties. The bulletin does not mention a sunset clause, implying that these adjustments will be reviewed annually or as inflation trends change. Banks should also check for any subsequent updates or clarifications issued by the OCC regarding the implementation of the new thresholds.n
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Changes in CRA Classification
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The classification under CRA is directly tied to total assets. Historically, a ‘Small Bank’ was defined as having total assets below $10 billion (or a lower threshold depending on the specific regulation year). An ‘Intermediary Small Bank’ had total assets between $10 billion and $25 billion, or similar ranges. The exact thresholds change annually due to inflation. The 2025-48 bulletin specifically revises these numbers to reflect the CPI. For example, if the CPI increases by 3%, the asset thresholds for classification are also adjusted upward. This ensures that a bank that grows by 2% does not automatically fall below the ‘Small Bank’ threshold and get subjected to a ‘Large Bank’ examination. The new thresholds ensure that the examination cycle is commensurate with the actual size and complexity of the institution. A bank that is reclassified from ‘Small’ to ‘Intermediate Small’ will undergo a more thorough CRA examination. This examination will focus on the institution’s record of meeting the credit needs of the community in a manner consistent with the overall needs of the community. The changes also impact the Community Development Financial Institution (CDFI) designation. The guidance does not explicitly mention CDFI, but the principles apply. The classification is used to determine the level of CRA support and examination intensity. The guidance emphasizes that the classification change is a neutral adjustment based on economic data, not a punitive measure. Institutions should view this as a fairness measure that aligns with the economic reality of the last decade. The guidance also clarifies that the classification is used to determine whether an institution needs a full CRA exam or a streamlined one. A full CRA exam is reserved for larger institutions or those with significant regulatory complexity.n
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Why This Matters
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The CRA is a critical component of the regulatory framework for community development. The Home Owners Loan Act of 1933 established the CRA to ensure that financial institutions serve their local communities. The CRA assessment involves a review of a bank’s lending and investment activities. The bulletin ensures that the classification of a bank does not unfairly downgrade its status due to inflation. This is particularly important for banks that have grown organically. If inflation was ignored, a bank might have been downgraded from ‘Small Bank’ to ‘Large Bank’ simply because its nominal assets grew faster than the fixed threshold. The new CPI-based adjustment corrects this. It protects banks from being penalized for inflationary growth. This is a strategic shift that aligns the CRA with the economic realities of modern banking. The guidance also addresses the importance of inflation adjustment in maintaining regulatory consistency. Without this adjustment, the regulatory landscape would become increasingly skewed against institutions that grew in a high-inflation environment. The bulletin emphasizes that the CRA is a tool for community development, not a hurdle. The classification impacts how much resources a bank must dedicate to community lending. A smaller classification allows for more flexibility. The new thresholds ensure that smaller banks retain this flexibility. The guidance is a significant step towards ensuring that community development financing remains accessible and fair. The bulletin also addresses the issue of examination cycles. A change in classification can lead to a change in the examination cycle, which can impact the bank’s operational schedule. Banks must be prepared for a shift in examination focus. The guidance also notes that the OCC is committed to transparency. The bulletin provides clear instructions on how to adjust for inflation. The OCC’s guidance is intended to be a resource for regulated institutions. Banks can use the bulletin to update their internal compliance manuals and policies. The guidance also addresses the issue of historical compliance. Banks must review their past CRA filings to see if they were accurate. If an institution was previously misclassified, the new guidance may allow for a retroactive adjustment, but the bulletin does not explicitly state this. Banks should assume the new rules apply only prospectively unless otherwise notified.n
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How to Adapt
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Financial institutions must take immediate steps to adapt to the new regulations. The first step is to review the current asset total and determine the correct classification under the new thresholds. This requires updating the bank’s internal asset reporting systems. The second step is to review the CRA assessment areas. The new thresholds may affect how a bank’s CRA plan is structured. The bank must ensure that its CRA activities are commensurate with its classification. The third step is to update the CRA assessment area map. The boundaries of CRA assessment areas may change if the bank’s size changes, but the bulletin does not explicitly address assessment area changes. The fourth step is to communicate with the board of directors. The board must be aware of the new thresholds and their implications for the bank’s CRA strategy. The fifth step is to train compliance staff. Staff must understand the new thresholds and how to apply them in their daily work. The sixth step is to review the CRA plan. The plan must be updated to reflect the new classification and any changes in community needs. The seventh step is to engage with local community development financial institutions. Collaboration with CDFIs can help ensure that the bank’s CRA activities are impactful. The eighth step is to monitor the regulatory environment for further updates. The OCC may issue additional guidance as inflation trends change. The ninth step is to document the adaptation process. Documentation is crucial for demonstrating compliance during examinations. The tenth step is to prepare for potential examination changes. A change in classification may lead to a more frequent or rigorous examination. Banks must be ready to provide evidence of their CRA performance. The guidance suggests that banks should be proactive in their compliance efforts. The OCC encourages banks to use the bulletin as a guide for adapting. The bulletin is a tool for regulatory alignment. The guidance also notes that banks should consider the impact of the classification on their community development goals. The guidance does not mandate a specific CRA strategy but requires that the strategy be consistent with the classification. Banks must ensure that their CRA efforts are robust enough to withstand a change in classification. The guidance also addresses the issue of capitalization. The classification may impact the capitalization requirements for CRA loans, though the bulletin does not specify this. Banks must ensure that their capitalization is sufficient to support their CRA activities. The guidance emphasizes that the CRA is a core part of the bank’s mission. Banks should align their CRA activities with their community development goals. The guidance also notes that the OCC is committed to supporting community development. The bulletin is a step towards that support. Banks must use the bulletin to inform their CRA strategy. The guidance is a critical resource for financial institutions. Banks must ensure that their CRA plan is robust enough to meet the standards of the new classification. The guidance also addresses the issue of examination focus. A bank classified as ‘Small’ may be examined differently from a bank classified as ‘Large’. Banks must be prepared for the type of examination they will face. The guidance emphasizes that the CRA is about community service. Banks must ensure that their CRA activities benefit the community. The guidance also notes that the OCC is committed to fairness. The bulletin is a step towards ensuring that institutions are not unfairly downgraded. Banks must use the bulletin to align their strategies with regulatory expectations. The guidance is a critical resource for financial institutions. Banks must use the bulletin to inform their CRA strategy. The guidance is a critical resource for financial institutions.n
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Conclusion
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In conclusion, OCC Bulletin 2025-48 is a pivotal document for the banking industry. It ensures that the CRA thresholds remain relevant in an inflationary environment. The bulletin effectively adjusts the asset size thresholds to prevent unfair downgrading. Financial institutions must adapt their CRA strategies to comply with the new standards. The transition period provides time for compliance adjustments. Banks must review their asset totals and classification. The guidance is a significant step towards regulatory fairness. Banks must ensure that their CRA activities are robust and impactful. The OCC remains committed to supporting community development. The bulletin is a critical resource for all regulated institutions. Financial institutions must act swiftly to align with the new requirements. Failure to adapt may result in compliance issues. The bulletin is a clear directive for the future of CRA regulation. Banks must use the bulletin to guide their CRA planning. The guidance ensures that the CRA remains effective in serving underserved communities. The OCC encourages transparency and collaboration. The bulletin is a step towards a more equitable regulatory landscape. Banks must ensure that their CRA strategies are aligned with their mission. The guidance is a critical resource for financial institutions. Banks must use the bulletin to inform their CRA strategy. The guidance is a critical resource for financial institutions.n
“
}
{
“meta_title”: “OCC Bulletin 2025-48 Updates CRA Thresholds”,
“meta_description”: “New CRA asset thresholds effective 2026. OCC Bulletin 2025-48 adjusts classification. Review compliance before Jan 1 deadline.”,
“content_html”: “
On December 23, 2025, the Office of the Comptroller of the Currency, commonly referred to as the OCC, released a significant regulatory update contained within Bulletin 2025-48. This document serves as a critical update to the regulatory landscape, specifically focusing on the adjustment of asset size thresholds for Community Reinvestment Act (CRA) classifications. The primary purpose of this update is to prevent unfair downgrades of banks, especially small ones, by adjusting classification boundaries to reflect current economic conditions, particularly inflation, that were previously ignored in the regulatory framework.
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Key Changes in Asset Size Thresholds
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The OCC has updated the asset size thresholds used to classify banks into ‘Small’, ‘Large’, and ‘Intermediate Small’ categories. Previously, a ‘Small Bank’ was defined as having total assets below $10 billion. An ‘Intermediary Small Bank’ had total assets between $10 billion and $25 billion, or similar ranges. These definitions often lead to inflation-induced downgrades. The 2025-48 bulletin introduces inflation-adjusted thresholds based on the Consumer Price Index (CPI). For example, if the CPI increases by 3%, the asset thresholds for classification are also adjusted upward.
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Impact on CRA Classification
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The CRA classification is directly tied to total assets. Historically, a ‘Small Bank’ was defined as having total assets below $10 billion (or a lower threshold depending on the specific regulation year). The new thresholds ensure that a bank that grows by a certain percentage (e.g., 2%) does not automatically fall below the ‘Small Bank’ threshold and get subjected to a ‘Large Bank’ examination. A bank that is reclassified from ‘Small’ to ‘Intermediate Small’ will undergo a more thorough CRA examination. The examination will focus on the institution’s record of meeting the credit needs of the community in a manner consistent with the overall needs of the community. This change ensures that the examination cycle is commensurate with the actual size and complexity of the institution.
nn
Why This Matters
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The CRA is a critical component of the regulatory framework for community development, established by the Home Owners Loan Act of 1933. The bulletin ensures that the classification of a bank does not unfairly downgrade its status due to inflation. This is particularly important for banks that have grown organically. If inflation was ignored, a bank might have been downgraded from ‘Small Bank’ to ‘Large Bank’ simply because its nominal assets grew faster than the fixed threshold. The new CPI-based adjustment corrects this. It protects banks from being penalized for inflationary growth. Without this adjustment, the regulatory landscape would become increasingly skewed against institutions that grew in a high-inflation environment.
nn
How to Adapt
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Financial institutions must take immediate steps to adapt to the new regulations. The first step is to review the current asset total and determine the correct classification under the new thresholds. This requires updating the bank’s internal asset reporting systems. The second step is to review the CRA assessment areas. The new thresholds may affect how a bank’s CRA plan is structured. The bank must ensure that its CRA activities are commensurate with its classification. The third step is to update the CRA assessment area map. The fourth step is to communicate with the board of directors. The fifth step is to train compliance staff. The sixth step is to review the CRA plan. The plan must be updated to reflect the new classification and any changes in community needs. The seventh step is to engage with local community development financial institutions. The eighth step is to monitor the regulatory environment for further updates.
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Conclusion
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In conclusion, OCC Bulletin 2025-48 is a pivotal document for the banking industry. It ensures that the CRA thresholds remain relevant in an inflationary environment. The bulletin effectively adjusts the asset size thresholds to prevent unfair downgrading. Financial institutions must adapt their CRA strategies to comply with the new standards. The transition period provides time for compliance adjustments. Banks must review their asset totals and classification. The guidance is a significant step towards regulatory fairness. Banks must ensure that their CRA activities are robust and impactful. The OCC remains committed to supporting community development. The bulletin is a critical resource for all regulated institutions. Financial institutions must act swiftly to align with the new requirements. Failure to adapt may result in compliance issues. The bulletin is a clear directive for the future of CRA regulation. Banks must use the bulletin to guide their CRA planning. The guidance ensures that the CRA remains effective in serving underserved communities. The OCC encourages transparency and collaboration. The bulletin is a step towards a more equitable regulatory landscape. Banks must ensure that their CRA strategies are aligned with their mission.”
“related_topics”: [
“Community Reinvestment Act (CRA)”,
“Inflation Adjustments”,
“Bank Classification”,
“OCC Bulletin 2025-48”,
“Compliance Strategies”
],
“related_articles”: [
“The Community Reinvestment Act Explained”,
“How to Prepare for CRA Exams”,
“The Impact of Inflation on Banking Regulations”,
“Community Development Financial Institutions (CDFIs)”
],
“author”: “AI”,
“date_published”: “2025-12-30”,
“date_modified”: “2025-12-30”,
“author_bio”: “AI”
}
