FairPlay and NAAHL Publish Interactive CRA Map Highlighting Effects of Proposed Rule Changes

LOS ANGELES, Nov. 2, 2026 /PRNewswire/ -- NAAHL CRA Map, powered by FairPlay AI, gives banks and policymakers clear data on how proposed changes to the Community Reinvestment Act (CRA) would affect communities across the country. The map draws on FairPlay's CRAi platform analytics and the National Association of Affordable Housing Lenders' (NAAHL) federal CRA expertise to show the community-by-community impact of the thresholds under consideration.

Measuring how the proposal would affect communities takes data that is public but scattered across federal agencies and filings. That data includes FFIEC CRA disclosure files, FDIC and FFIEC call reports, the FDIC Summary of Deposits, CRA performance evaluations from the FDIC, OCC and Federal Reserve, and U.S. Census Bureau data. CRAi, FairPlay's AI-powered CRA insights platform, brings those sources together. NAAHL adds the perspective of its members: the banks, community development financial institutions (CDFIs), and other lenders that finance affordable housing and community development across the country.

NAAHL uses CRAi to show its members and policymakers how CRA rules play out in the markets they serve.

The NAAHL CRA Coverage Map, is an interactive tool built on CRAi. The map, which is publicly available, shows how the rule proposed by the OCC and the FDIC would change the number of banks evaluated for community development in each census tract. NAAHL drew on the same analysis in the comments it filed with the agencies on October 13.

The proposal would raise the small-bank threshold from $412 million to $1 billion in assets and the large-bank threshold from $1.649 billion to $10 billion. Banks from $1 billion to $10 billion would become intermediate banks, evaluated under a lending test and a community development test instead of separate lending, investment and service tests. The agencies also asked for comment on a broader set, with small banks defined as those under $10 billion in assets and large banks as those at $30 billion or more.

What the map shows

Under the agencies' proposal, NAAHL estimates that about 400 OCC- or FDIC-regulated banks would move from the large-bank framework into the intermediate category. Those banks hold about 7% of deposits nationwide but reported $25.9 billion in community development loans in 2024, 19% of the national dollar volume.

The broader alternative would reach much further. If the small-bank threshold rose to $10 billion:

• 3,673 banks would be small banks with no community development test, up from 2,288 under current thresholds.
• More than 31 million people live in census tracts where five or fewer banks evaluated for community development.
• More than 2.6 million additional people would live in census tracts where no bank is evaluated for community development.

Banks with less than $30 billion in assets made nearly $53.5 billion in community development loans in 2024, more than a third of community development lending by dollar volume and nearly two-thirds by number of loans. CRA-motivated investors provided about 80% of the equity for Low-Income Housing Tax Credit projects that year.

"Every debate about CRA thresholds ends up counting banks. This map counts people," said Kareem Saleh, founder and CEO of FairPlay. "If the small-bank line moves to $10 billion, more than 2.6 million additional people would live in census tracts where no bank is evaluated for community development. Before regulators draw that line, they should know who ends up on the wrong side of it."

"CRA is an irreplaceable policy that harnesses the power of the U.S. banking system to expand access to housing and economic opportunity," said Sarah Brundage, NAAHL President and CEO. "Blunt changes to CRA may have unintended consequences. Updates to CRA should ensure that we are enhancing the outcomes of CRA for families, not suppressing them. Working with FairPlay, we can now show policymakers, community by community, exactly where these changes would be felt most profoundly."

The map is available at naahl.org/cra-map.

NAAHL also joined more than 475 organizations, covering all 50 states, in a letter urging the OCC and FDIC to keep meaningful community development responsibilities for banks of all sizes.

About FairPlay

FairPlay is the AI enablement company for the financial services and insurance industries. FairPlay specializes in testing, tuning, and validating AI systems and agents, helping institutions deploy AI faster, more profitably, and in full compliance. Its products address the toughest challenges in AI deployment, including Bias Testing, Model Optimization, Model and Agentic Validation, Second Look, and Safe AI Sourcing. FairPlay's work has been featured in The Wall Street Journal, USA Today, Politico, American Banker, and Forbes. In 2023, Fast Company recognized FairPlay as a "World Changing Idea." To learn more, please visit fairplay.ai 

About NAAHL

Founded in 1990, the National Association of Affordable Housing Lenders (NAAHL) is the national alliance of the leading investors and lenders in affordable housing and community development – bringing together banks, CDFIs, and other public, private, and nonprofit lenders. NAAHL's mission is to expand economic opportunity through innovative financing and policymaking for affordable housing and community development. NAAHL's member network uniquely represents the public-private partnership that makes possible affordable housing and community development financing in America.

SOURCE FairPlay