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Guide

CRA ratings explained: how to read a bank's CRA rating

Published October 10, 2026. Ratings from the FFIEC interagency CRA ratings file as built on September 12, 2026. Small business lending from the FFIEC CRA disclosure file for 2024.

Short answer: A CRA rating is the public grade a bank's regulator gives its record of meeting the credit needs of the communities where it takes deposits, including low- and moderate-income neighborhoods. There are four grades: Outstanding, Satisfactory, Needs to Improve and Substantial Noncompliance. Of the 4,184 banks with a rating on file in BankingLENS, 3,654 hold a Satisfactory and 486 an Outstanding, so a passing grade tells you little by itself. The grade matters most when it falls below Satisfactory, because that can hold up a branch or a merger, and the detail worth reading is in the written evaluation behind the grade.

What the rating is

The Community Reinvestment Act of 1977 tells the federal banking agencies to assess how well each insured bank helps meet the credit needs of its whole community, including low- and moderate-income neighborhoods, in a way consistent with safe and sound banking. The bank's own regulator does the assessing: the OCC for national banks and federal savings associations, the Federal Reserve for state member banks, and the FDIC for the rest. Since July 1990 both the rating and the written evaluation behind it have been public.

Two things it is not. It is not a lending quota: no rule says how many loans a bank must make or where. Examiners judge what the bank did against what a bank of its size and business could reasonably do in the places it serves, which the evaluations call performance context. And it does not cover everyone who lends. The federal law applies to FDIC-insured banks and savings associations. Credit unions and independent mortgage companies are outside it, although a few states apply their own versions to them.

Four grades, and almost everyone passes

Here is every bank's most recent rating, for the 4,184 of the 4,296 banks in BankingLENS that have one on file.

Most recent CRA rating Banks Share of rated banks
Outstanding48611.6%
Satisfactory3,65487.3%
Needs to Improve431.0%
Substantial Noncompliance1Under 0.1%
All rated banks4,184100%

Source: BankingLENS, from the FFIEC interagency CRA ratings file as built on September 12, 2026. Each bank is counted once, at its most recent examination, and the newest examination in the file is dated June 1, 2026. A rating is on file for 4,184 of 4,296 banks, or 97%.

Nearly nine banks in ten are Satisfactory and about one in nine is Outstanding. Only 44 are below the passing line, and one of those holds the bottom grade.

That distribution is the first thing to understand about the rating. Satisfactory does not separate a bank from its competitors, because nearly all of them have it. Outstanding is a real distinction that takes sustained effort to earn, and some boards set it as a goal for that reason. Anything below Satisfactory is rare enough to say something about the bank: about one bank in a hundred.

How old is the rating?

A rating describes a period that has already ended, and it can be several years old. Of the 4,184 most recent examinations on file, 339 are dated 2026, 1,160 are from 2025 and 1,009 from 2024, so about 60% are from 2024 or later. Another 830 are from 2023, 397 from 2022, 287 from 2021 and 131 from 2020, and 31 are older than that.

There is no single examination schedule. Each agency sets its own cycle, and by statute a bank with $250 million or less in assets is generally examined no more than once every five years if its last rating was Outstanding and once every four if it was Satisfactory. So before reading anything into a grade, check the date and the review period printed on the evaluation. A Satisfactory dated 2021 may describe lending from 2018 through 2020.

The examination depends on the bank's size

Banks are examined under one of three sets of procedures, chosen by asset size. The dollar lines move every January with inflation. These are the ones for 2026.

Type of bank Assets, 2026 thresholds What examiners test
Small bankUnder $412 millionOne lending test: the loan-to-deposit ratio, the share of loans made inside the assessment area, lending to borrowers of different incomes and to businesses and farms of different sizes, the spread of loans across neighborhoods, and the response to complaints.
Intermediate small bank$412 million to under $1.649 billionThe same lending test, plus a community development test covering community development loans, qualified investments and services.
Large bank$1.649 billion or moreThree tests: lending, investment and service. Large banks also collect and report their small business, small farm and community development lending every year.

Thresholds are measured at December 31 of the two prior years. A bank is small if it was under $1.649 billion at either year-end, and intermediate small if it was also at least $412 million at both. Wholesale and limited purpose banks are examined on community development alone, and any bank can ask to be evaluated under a strategic plan it writes and its regulator approves.

For a large bank each of the three tests gets its own grade, and there Satisfactory is split in two: High Satisfactory and Low Satisfactory. The lending test carries the most weight. A large bank cannot be rated Satisfactory overall unless it earns at least a Low Satisfactory on lending.

These procedures are the framework adopted in 1995. A rewrite the agencies finished in 2023 never took effect: a federal court blocked it in March 2024, and in July 2025 the agencies proposed withdrawing it. Banks are still examined under the 1995 rules.

What a low rating costs

The law gives the rating its teeth through applications. When a bank applies to open a branch, move its main office, merge with another institution or buy one, its regulator must take the bank's CRA record into account, and a rating below Satisfactory can be grounds to deny the application or attach conditions to it. The public can comment on those applications, and community groups do.

The consequence reaches the parent company too. A financial holding company cannot start new financial activities, or acquire a company engaged in them, while any of its insured banks is rated below Satisfactory.

Lending volume alone does not protect the grade. Evidence of discriminatory or other illegal credit practices can lower a rating that the numbers would otherwise support, which is why a fair lending problem and a CRA downgrade can arrive together.

Read the evaluation, not only the grade

Every examination produces a written performance evaluation, and it is public. The FFIEC's interagency rating search lists every rating since 1990, each agency publishes the evaluations for the banks it supervises, and every bank keeps its latest one in a CRA public file. Two Satisfactory banks can look very different inside that document. These are the parts worth reading.

Income levels in an evaluation have fixed meanings. Low income is under 50% of the area's median income, moderate is 50% to under 80%, middle is 80% to under 120%, and upper is 120% or more. The same four bands classify census tracts.

CRA lending data is a different thing from the rating

The rating exists for almost every bank. The lending data does not. Only large banks must report their small business and small farm loans each year, and for 2024 that was 731 institutions, fewer than one bank in five. What they report is published by county, which makes it the best public record of who lends to small businesses in a given market.

It needs careful reading, because in this data a small business loan means a small loan, not a small borrower: any business loan with an original amount of $1 million or less. In 2024 the reporting banks originated 8,734,262 of them for $257.8 billion, and the table shows where that count comes from.

Loan size at origination Loans Share of loans Dollars Share of dollars
$100,000 or less8,300,19995.0%$114.7 billion44.5%
Over $100,000 to $250,000243,5262.8%$40.6 billion15.7%
Over $250,000 to $1 million190,5372.2%$102.5 billion39.8%
All small business loans8,734,262100%$257.8 billion100%
Of those, to businesses with revenue of $1 million or less4,700,00253.8%$89.1 billion34.6%

Source: BankingLENS, from the FFIEC CRA disclosure file for 2024. Originations only: purchased loans are reported separately and are left out.

Nineteen loans in twenty were for $100,000 or less. That band is dominated by business credit cards from a handful of national issuers, and it buries the lending most people mean by the phrase. A community bank's forty loans of $400,000 each are real small business lending, and they vanish in a count of 8.7 million. Read the three size bands separately, and use the revenue line when the question is about small firms: 53.8% of the loans, but 34.6% of the dollars, went to businesses with $1 million or less in revenue.

Frequently asked questions

What are the four CRA ratings?

Outstanding, Satisfactory, Needs to Improve and Substantial Noncompliance. They have been public since July 1990. Large banks also receive a grade on each of their lending, investment and service tests, where Satisfactory is split into High Satisfactory and Low Satisfactory.

What is a good CRA rating?

Satisfactory is the passing grade and by far the most common: 3,654 of the 4,184 banks with a rating on file in BankingLENS hold one, and 486 hold an Outstanding. Only 44 are below Satisfactory. Because nearly every bank passes, the grade alone says little, and the written evaluation is where two Satisfactory banks can be told apart.

What happens if a bank gets a Needs to Improve rating?

Its regulator takes the rating into account when the bank applies to open or move a branch or to merge with or acquire another institution, and a rating below Satisfactory can lead to a denial or to conditions. A financial holding company whose bank is rated below Satisfactory also cannot begin new financial activities or buy companies engaged in them until the rating is restored.

How often is a bank examined for CRA?

There is no single schedule. Each agency sets its own cycle, and by statute a bank with $250 million or less in assets is generally examined no more than once every five years if it is rated Outstanding and once every four years if it is rated Satisfactory. In the ratings on file here, about 60% of the latest examinations are dated 2024 or later, and several hundred date from 2020 through 2022.

Does the CRA apply to credit unions?

No. The federal law covers FDIC-insured banks and savings associations. Credit unions and independent mortgage companies are not examined under it, although a few states apply their own versions to them.

Where can I find a bank's CRA performance evaluation?

The FFIEC's interagency CRA rating search lists every rating since 1990, and the OCC, the Federal Reserve and the FDIC each publish the written evaluations for the banks they supervise. Every bank also keeps a CRA public file, which includes its latest evaluation, and must make it available on request.

What counts as a small business loan in CRA data?

A loan to a business with an original amount of $1 million or less. It is a definition by loan size, not by the size of the borrower. The data separately counts loans to businesses with gross annual revenue of $1 million or less, which in 2024 were 53.8% of reported loans by number.

Where these numbers come from

Ratings come from the FFIEC interagency CRA ratings file as built on September 12, 2026, with each examination matched to the bank's current charter. Lending figures come from the FFIEC CRA disclosure file for 2024. Asset thresholds and rules are the federal ones in effect in October 2026. In BankingLENS the bank scorecard shows each bank's CRA examination rating and, as a preview, who lends to small businesses in its counties. You can see a real bank ranked against its FFIEC peer group on the sample scorecard, or open your own bank in the dashboard. Plans that cover your state or every bank start at $29 a month (pricing).

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