On December 17, the OCC announced its proposed guidance introducing a “simplified strategic plan process” for community banks to comply with the CRA. The OCC stated that the new process aims to reduce regulatory burden and clarify requirements for community banks, allowing them to tailor their OCC CRA examinations according to their capacity, product offerings, and business strategy. The proposed guidance outlined the use of a standardized form, provided examples of measurable goals for lending, investment and services, and explained that community banks may use these elective goals or develop custom goals based on their circumstances. The OCC also noted that the process would streamline public participation requirements and allow for case-by-case waivers of certain regulatory requirements, such as data reporting, when appropriate.

The OCC emphasized that the simplified process does not impose new requirements but instead offers an optional, less burdensome alternative for community banks seeking CRA compliance. The agency requested public comments on the proposed guidance be submitted within 60 days following its publication in the Federal Register. Specifically, the proposal seeks input on the clarity and appropriateness of the elective goals, the weighting methodology for measurable goals, and whether the degree of optionality is sufficient.