Letter to the OCC on the Simplified Strategic Plan Process for Community Banks

To Whom It May Concern:

The American Bankers Association is pleased to comment on the OCC's proposed supplemental guidance that would establish a simplified process for community banks to request that their Community Reinvestment Act (CRA) performance be evaluated pursuant to the CRA strategic plan option rather than the standard CRA performance tests.

The strategic plan option enables a bank to tailor its CRA examination based on the needs of its community and its ability to help address those needs based on its capacity and constraints, product offerings, and business strategy. Strategic plans must be developed with public input and receive regulatory approval.

The proposal aims to make the strategic plan path more accessible and less resource intensive for community banks with up to $30 billion in assets. This flexibility is increasingly important as community banks pursue fintech partnerships and niche lending strategies that often do not align neatly with the traditional CRA framework.

I. Summary of the Comment

ABA supports the OCC’s efforts to make the strategic plan option less burdensome for community banks. We have long maintained that any bank and its community can benefit from the regulatory certainty and flexibility of design that strategic plans provide, and we have consistently advocated for improvements to the strategic plan approval process.  We understand that regulators have implied that community banks should not submit strategic plans for approval because this option was intended for larger or non-traditional institutions. The proposed guidance is an important step forward and signals that the OCC intends to encourage broader community bank use of the strategic plan option.

The proposed guidance provides examples of measurable CRA goals and performance levels that a community bank could incorporate into its proposed strategic plan. These “elective goals” may serve as a helpful reference point for community banks that choose the strategic plan option. 

Download the comment letter to read the full text.