NAHRO Signs-On to National CRA Proposed Rule Comment Letter

September 29, 2026 — Last week, NAHRO signed on to a national comment letter, led by the National Association of Affordable Housing Lenders, elevating priorities for any changes to the Community Reinvestment Act (CRA) to continue supporting affordable housing, community development, and other community benefits. NAHRO encourages other national, state and local organizations to sign on to the letter by October 6, 2026.

The CRA proposed rule published by the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) would make a number of changes to the Act, which will impact community development investment by community banks. The CRA requires the Federal Reserve and other federal banking regulators to encourage financial institutions to help meet the credit needs of the communities in which they do business, including low- and moderate-income (LMI) neighborhoods. However, changes to the CRA could have a major impact on investments in the Low-Income Housing Tax Credit (LIHTC), New Markets Tax Credit, and other programs that promote affordable housing.

Some key points related to the proposed rule:

• Changing the asset threshold of community banks by revising what categorizes as a small bank (less than $1 billion), intermediate bank ($1–$10 billion), and large bank (more than $10 billion) would significantly reduce the number of institutions subject to community development expectations. In small and rural communities, this may have an even larger impact due to the fact that federally insured banks are a key source of financing and investment. As a result of the asset threshold changes, banks with $10 billion or less in assets would be subject to fewer data collection, maintenance, and reporting requirements, which may disincentivize banks from making community development loans and investments in communities;
• Proposing to remove grants from the definition of community development investments could significantly shift CRA investment and reduce the focus on impacts on low- and moderate-income communities; and
• Adding new reporting for grants may impact bank participation or a reduction in grant support.

Comments on the proposed rulemaking are due on October 13, 2026. To submit comments of your own and to view the proposed rule, see here.