CRA Giving Is Changing. Is Your Grant Process Ready?

On July 31, 2026, the OCC and FDIC jointly proposed the most significant revision to CRA regulations in years — reopening how grant documentation, overhead costs, and bank size thresholds are treated. The proposal would cap a large bank's indirect administrative costs on a qualifying grant at 15%, and would require documentation showing the grant was actually used for a genuine community-development purpose. The comment period runs 60 days from the proposal's Federal Register publication on August 12, 2026, and the rule's final shape is still undecided — the Federal Reserve is not part of this rulemaking.

The National Community Reinvestment Coalition estimates that if the proposed benchmarks were applied broadly, large-bank community development activity could fall from about $102 billion to $31 billion a year, with sixteen states projected to lose at least a third of their currently-evaluated banks. That's a projection under one modeled scenario, not a certain outcome — but it's a clear signal of the direction: more scrutiny on how grant dollars actually get used, not just where they're awarded.

In our recent webinar, CRA Giving Is Changing. Is Your Grant Process Ready?, Reviewr's Halle McCaslin walked through the part of that equation banks can actually control: building a community-development grant process that stays organized and defensible no matter which version of the rule wins. If you missed it live, here's what we covered — and you can catch the full session, including the live demo and audience Q&A, on demand below.

What We Covered

1. Build an Accessible Record of Every Decision - Under the proposed rule, a grant only counts if it can be shown to serve a genuine community-development purpose. We covered how keeping applications, supporting documents, reviewer scores, comments, decisions, and award information together in one record means never reconstructing a grant's history by hand when a question comes in — and how that same organized record holds up whether this proposal takes effect, changes, or is replaced by something else. We also touched on security: banks and credit unions collect sensitive applicant information — tax documents, bank information, financial statements, tax ID numbers — and Reviewr is SOC 2 compliant, keeping that information secured rather than scattered across emails and downloaded PDFs.

2. Handle More Applications Without Losing Consistency - As programs grow, review volume grows with them. We showed how structured scorecards keep every reviewer evaluating the same criteria the same way, and how AI-assisted summaries help reviewers triage a larger applicant pool without lowering the bar — so a program expected to do more with community-development dollars can scale review without losing rigor.

3. Adjust Without Rebuilding - With the rule still an open proposal, flexibility is an advantage. We walked through updating a single question, criterion, or workflow step without rebuilding the whole program — so whatever the final rule requires, the process adapts to it instead of being rebuilt around it, with configuration changes carrying forward automatically into the next cycle.

4. Manage Every Program, Market, and Assessment Area in One Place - Shifting asset-size thresholds could change which requirements apply where. We covered how one platform can manage every program, market, and assessment area a bank is responsible for — each one configurable to its own criteria — so a connected system adapts without a rebuild, and every market stays visible in the same system without losing its own configuration.

5. Prove Impact Without Extra Reporting Work - The proposed rule's documentation requirement calls for proof that a grant funded genuine community-development activity. We demonstrated how supplemental forms capture project outcomes, dollars deployed, and community impact directly against each award — living on the same record as the application and award, not in a separate email or spreadsheet — so reports summarizing funded programs, outcomes, and impact build themselves in real time, with no added effort from the admin team.

What the Live Demo Showed

After walking through the five fixes, we moved into a live look at Reviewr itself — focused on the applicant and judge experience:

• Account creation, eligibility, and matching. Applicants create an account so they can save progress and pick up where they left off, with full visibility into where they stand in the process. A grant eligibility tool asks a short set of screening questions up front — applicants who don't qualify are stopped and exited before writing a full application, while applicants who do qualify can be matched to the grant program that best fits them.
• A flexible, secure application form. We showed the range of question types available — including essays, file uploads, and reference requests — and how that variety makes for both an intuitive applicant experience and a clean, readable report on the back end. For programs that collect references, we highlighted a rating system alongside the written reference itself: since some reference writers are simply better writers than others, scoring the reference helps keep the comparison between applicants fair. All uploaded documents stay SOC 2-compliant and secure.
• A judge experience built for volunteers. Many reviewers are volunteers donating their time, so we focused on keeping their experience simple: everything about a submission — the form, file uploads, references — lives in one tab next to the evaluation form, instead of across ten browser tabs. Personally-identifying information can be redacted where bias is a concern. We also showed an emotion-based rating scale as an alternative to a raw 1-to-5 or 1-to-10 score, since it tends to produce more consistent scoring across reviewers than a plain number scale where everyone's sense of a "4" differs — and for programs that prefer a numeric scale, defining a clear range for each score helps judges apply it consistently.

The Takeaway

Whichever direction the final rule takes, banks that keep their community-development programs organized, documented, and defensible are positioned to meet the moment — for their regulators, and for the communities the program exists to serve. This isn't a smaller program's moment. It's a more important one.

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