How could changes to bank size definitions affect your community?
We face a national shortage of affordable housing, and scaling banks' lending and investments into affordable housing is key to boosting supply, especially for low- and moderate-income (LMI) families.
What brings banks to the table? The Community Reinvestment Act (CRA) incentivizes large banks and intermediate banks to make community development loans and investments benefiting LMI households and communities in the places where the bank has branches or headquarters. CRA does not incentivize small banks to make loans and investments in affordable housing and community development.
How could federal policy changes impact my community? Use this map to see how changes in the definition of small, intermediate, and large banks would impact the number of banks incentivized to provide community development loans and investments in your state or county.
How are small, intermediate, and large banks defined?
| Banks | Status Quo | Scenario A | Scenario B | Scenario C | Scenario D |
|---|---|---|---|---|---|
| Small | under $412M | under $850M | under $1B | under $5.031B | under $10B |
| Intermediate | $412M to $1.649B | $850M to $3.252B | $1B to $10B | none | $10B to $30B |
| Large | $1.649B and over | over $3.252B | over $10B | over $5.031B | over $30B |
- Status Quo Small under $412M; intermediate $412M to $1.649B; large $1.649B and over
- Scenario A Small under $850M; intermediate $850M to $3.252B; large over $3.252B
- Scenario B Small under $1B; intermediate $1B to $10B; large over $10B
- Scenario C Small under $5.031B; intermediate none; large over $5.031B
- Scenario D Small under $10B; intermediate $10B to $30B; large over $30B
Key Terms
Thin coverage: 1 to 5 banks with community development incentives from CRA include the community in their CRA assessment areas.
Community development desert: no bank with community development incentives from CRA includes the community in its CRA assessment area.
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What counts as covered. A tract is covered when at least one bank with community development incentives from CRA includes it in a CRA assessment area. Thin coverage means 1 to 5 such banks. A community development desert has none. Newly uncovered tracts are covered today and covered by no bank under the selected scenario.
Scenarios. A bank keeps its community development test, and is considered to have community development incentives from CRA, if it clears the small-bank line at both of its last two December call reports. Wholesale, limited purpose, and strategic plan banks keep today's incentives, as Federal Reserve banks do under Maintain Status Quo.
Rural, micropolitan, and metropolitan. Each census tract takes the type of the county it is in, under the Office of Management and Budget's July 2023 metropolitan and micropolitan statistical area delineations (OMB Bulletin No. 23-01). Metropolitan tracts are in a metropolitan statistical area, built around an urban area of at least 50,000 people. Micropolitan tracts are in a micropolitan statistical area, built around an urban area of 10,000 to 49,999 people. Rural tracts are in counties outside both. Of the 85,529 tracts on the map, 71,368 are metropolitan, 8,031 micropolitan and 6,130 rural.
Congressional districts. Each district takes the census tracts inside it; a tract that a district line splits is divided by its 2020 Census block population. "2026 districts" uses the plans for the November 2026 elections in the 10 states that redrew (Alabama, California, Florida, Louisiana, Missouri, North Carolina, Ohio, Tennessee, Texas and Utah) and today's districts elsewhere; "Current districts" uses the 119th Congress plans everywhere. A district's bank count includes every bank whose CRA assessment area includes any tract in the district. Deposit shares are shown for states, metro areas and counties only. Outlines: U.S. Census Bureau cartographic boundaries (2025) and, for the 2026 districts, 2020 Census blocks grouped by the Census Bureau's 120th Congress block assignment files.
One bank held out of coverage. One federal savings bank, part of a member-owned association whose membership is limited to current and former U.S. military members and their eligible families, reports its CRA assessment area as the entire nation. Counting it would place every tract inside an assessment area and overstate the service open to the general public, so it is left out of the coverage figures. It is included in the national count of banks.
Sources. Bank size and universe: FFIEC Call Reports (December 31, 2024 and 2025, and June 30, 2026), FDIC BankFind institution data, and the Federal Reserve's National Information Center. Thresholds: the 2026 CRA asset-size thresholds (OCC, FDIC and Federal Reserve) and the SBA's proposed $5.031 billion size standard (August 2025). Evaluation types: wholesale, limited purpose and strategic plan designations from the agencies and from the banks' CRA performance evaluations. Coverage: FFIEC CRA disclosure assessment areas (2024) and, for banks that do not file them, the counties where the bank operates branches, from the FDIC Summary of Deposits (June 2025). Communities and population: the FFIEC census tract file (income levels and need indicators, built from the U.S. Census Bureau's American Community Survey), the 2020 U.S. Census, and OMB's 2023 metropolitan and micropolitan area delineations. Boundaries: U.S. Census TIGER/Line, clipped to land. The map shows counts only, with no bank names and no tract-level detail.