CRA Giving Is Changing. Is Your Grant Process Ready?

The CRA rulebook has been in motion for years — a major 2023 overhaul that never took effect, a court injunction, a rescission attempt that stalled out, and now a new joint proposal from the OCC and FDIC that reopens documentation requirements, overhead limits, and asset-size thresholds all at once. The comment period is open, and no one outside the agencies knows exactly where it lands.

What's already clear is the direction: more scrutiny on how grant dollars actually get used, not just where they're awarded. The current proposal would tie CRA credit to documented proof that a grant funded community development activity — and could put an entire grant's credit at risk if too much of it covers a nonprofit's overhead. For a bank running a high-volume, high-stakes CRA grant program, that's a different bar than keeping good records because it's good practice. It's keeping an audit-ready file for every dollar, because a rule you don't control could turn on it.

At the same time, proposed changes to asset-size thresholds would shift which banks are even in scope, and by how much — a bank near a new threshold could move in or out of full CRA obligations, and a growing program could mean managing more applications, across more markets and assessment areas, without losing consistency in how each one gets evaluated.

This session is about the part of that equation you can actually control: building a community-development grant process that stays organized and defensible no matter which version of the rule wins.

What you'll learn:

1. Build an Accessible Record of Every Decision: Keep applications, supporting documents, reviewer scores, comments, decisions, and award information together — so you can show exactly how and why a grant was awarded, not reconstruct it after the fact.
2. Handle More Applications Without Losing Consistency: Use structured evaluation and AI-assisted summaries to move a larger volume of applications through review at the same standard, instead of speed costing you consistency.
3. Adjust Without Rebuilding: Update questions, criteria, workflows, and requirements as community-development priorities — and the regulations behind them — change, without starting your process over from scratch.
4. Manage Every Program, Market, and Assessment Area in One Place: Run multiple grant programs across markets and assessment areas on one platform, with each process configurable to its own criteria and requirements.

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