OCC/FDIC Community Reinvestment Act examination proposal

An August 2026 OCC/FDIC proposal to raise the full large-bank CRA examination threshold to more than $10 billion in assets, with comments due October 13, 2026.

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2026-09-18 · housing

A New CRA Proposal Could Spell Trouble for the LIHTC Equity Market

Tax Credit Advisor

The OCC and FDIC proposed on August 12 raising the asset threshold for the full large-bank Community Reinvestment Act examination from $1.649 billion to more than $10 billion, which would move banks between those sizes out of the separate community-development test that has driven bank capital into LIHTC investments. Industry participants told the outlet CRA motivation often raises the price investors pay for housing tax credits by about ten cents per dollar, and that reduced incentives could lower equity pricing. Public comment is due October 13.