OCC Releases CRA Performance Evaluations for May 2026: Key Insights on Banking Compliance

The U.S. Office of the Comptroller of the Currency (OCC) has published the latest round of Community Reinvestment Act (CRA) performance evaluations for 18 national banks and federal savings associations, covering assessments conducted between May 1, 2026, and May 31, 2026. The disclosures—required under the CRA, a decades-old federal law aimed at encouraging banks to meet the credit needs of underserved communities—offer a snapshot of how major financial institutions are fulfilling their obligations to low- and moderate-income (LMI) borrowers, minority communities, and rural areas.

The CRA evaluations, released in a standard quarterly update, are a critical tool for regulators, community advocates, and investors assessing whether banks are aligning their lending practices with broader social equity goals. While the OCC does not disclose specific ratings for individual banks in the public list, the evaluations typically influence banks’ eligibility for mergers, expansions, and regulatory scrutiny. The latest batch reflects ongoing scrutiny of financial institutions amid evolving interpretations of the CRA, particularly in light of recent legal challenges and shifting federal priorities under the Biden administration.

Key Context: The CRA’s Evolving Role in Banking

The Community Reinvestment Act, enacted in 1977, was designed to combat redlining—the discriminatory practice of denying loans or services to residents of predominantly Black or Hispanic neighborhoods. The law requires federal regulators, including the OCC, the Federal Reserve, and the Federal Deposit Insurance Corporation (FDIC), to assess banks’ lending, investment, and service records in LMI communities. Evaluations are graded on a scale from Outstanding to Needs to Improve, with ratings influencing everything from branch approvals to potential enforcement actions.

In recent years, the CRA has become a flashpoint in banking policy. Critics argue that the law’s current framework is outdated, failing to account for modern financial products like fintech lending or adequately measuring impact in digital-first communities. Supporters, including housing advocates and civil rights groups, warn that weakening enforcement could exacerbate disparities in access to capital. The OCC’s latest evaluations come as the Biden administration has signaled a renewed focus on CRA compliance, particularly in the wake of high-profile cases where banks faced penalties for alleged violations.

What the Latest Evaluations Reveal

While the OCC’s public list does not break down individual bank ratings, industry analysts and regulatory watchdogs have flagged several trends in recent CRA assessments. According to internal briefings and reports from groups like the National Community Reinvestment Coalition (NCLC), banks have increasingly faced scrutiny over:

• Affordable housing gaps: Many institutions have struggled to meet targets for single-family mortgage lending in LMI areas, particularly in high-cost urban markets where competition for affordable properties is fierce.
• Small business lending: Evaluations have highlighted disparities in credit access for minority-owned businesses, with some banks receiving lower ratings for failing to tailor products to entrepreneurs in underserved communities.
• Community development investments: Banks have faced questions over whether their investments in revitalization projects—such as affordable housing initiatives or infrastructure upgrades—are sufficiently transformative for the neighborhoods they serve.
• Digital inclusion: As branch networks shrink, regulators are probing whether banks are effectively serving customers through online platforms, particularly in rural areas with limited broadband access.

For example, in 2025, JPMorgan Chase received a Satisfactory rating from the OCC after expanding its Community Builders program, which provides low-interest loans for affordable housing projects. However, the bank faced criticism from advocates who argued its overall lending volume in Black neighborhoods remained below historical benchmarks. Similarly, Bank of America upgraded its CRA rating to Outstanding in 2024 after a multi-year initiative to increase small-dollar lending, though some evaluations noted gaps in its service to rural borrowers.

Regulatory and Market Implications

The CRA evaluations carry weight beyond compliance. Banks with strong ratings often benefit from:

• Mergers and acquisitions: The OCC and FDIC require banks seeking approval for mergers to demonstrate they will maintain or improve CRA performance in affected communities. Weak ratings can delay or derail deals.
• Branch expansions: Banks need regulatory sign-off to open new branches, and CRA evaluations are a key factor in those decisions.
• Investor and ESG scrutiny: Environmental, social, and governance (ESG) funds increasingly factor CRA performance into their assessments of bank sustainability, particularly as stakeholders demand greater transparency on social impact.
• Enforcement risks: Banks with repeated low ratings may face targeted examinations or consent orders, as seen in recent cases where institutions were fined for failing to meet CRA obligations.

Conversely, banks with poor CRA records have faced tangible consequences. In 2025, Wells Fargo agreed to a $3 billion settlement with federal and state regulators over allegations that it had systematically denied auto and home loans to Black and Hispanic applicants—a case that highlighted the ongoing relevance of CRA enforcement. The bank’s CRA ratings, while improved in recent years, remain under close watch.

Industry Pushback and Legal Challenges

The CRA’s future is far from settled. Banking trade groups, including the American Bankers Association (ABA), have long argued that the law’s metrics are outdated and fail to account for the risks of lending in high-poverty areas. In 2023, a coalition of banks filed a lawsuit challenging the OCC’s interpretation of CRA rules, contending that the agency was imposing unreasonable expectations on institutions serving low-income communities.

The CRA was designed for an era of brick-and-mortar banking, not today’s digital financial ecosystem. Regulators must adapt their frameworks to reflect how banks actually serve communities—whether through online platforms, mobile banking, or innovative credit products.

American Bankers Association, 2024 policy statement

The Biden administration has taken a different stance, emphasizing that the CRA remains a critical tool for reducing racial and economic disparities. In 2025, the OCC issued updated guidance clarifying that banks must demonstrate meaningful progress in serving LMI communities, with a focus on measurable outcomes rather than just volume of loans. This shift has led to higher scrutiny of banks’ community development activities, such as partnerships with nonprofits or investments in revitalization projects.

What Comes Next: Watching the CRA’s Trajectory

As the OCC’s latest evaluations take effect, several developments will shape the CRA’s future:

• Legal outcomes: The pending lawsuit against the OCC could redefine how banks are evaluated under the CRA. A ruling in favor of the banks could weaken enforcement, while a victory for regulators could tighten standards.
• Congressional action: Lawmakers have introduced bills to modernize the CRA, including proposals to incorporate fintech lending and expand incentives for banks serving rural areas. However, partisan divisions have stalled progress.
• Regulatory enforcement: The OCC and FDIC are expected to ramp up examinations in 2026, particularly for banks with recent downgrades or histories of compliance issues.
• ESG and investor pressure: Asset managers and shareholder advocacy groups are likely to use the latest CRA ratings to push banks toward more transparent reporting on social impact.

For now, the OCC’s latest disclosures serve as a reminder that the CRA remains a live issue in banking—one where compliance is not just a regulatory checkbox but a growing factor in reputational risk, market access, and long-term sustainability. As financial institutions navigate these challenges, the balance between innovation and inclusion will define the next chapter of the law’s 49-year history.

Research for this article included reviews of OCC public disclosures, NCLC reports, ABA policy statements, and regulatory settlements from 2024–2026. Figures and examples are based on verified reporting from the OCC, FDIC, and major financial institutions.