End of the Line: Regulators Decide to Rescind Final CRA Rule

On March 28, 2025, the Office of the Comptroller of the Currency, Federal Deposit Insurance Corporation and Federal Reserve Board announced their collective intent to issue a proposal (the “”) to rescind the October 2023 final rule (the “CRA Final Rule”), implementing changes to the Community Reinvestment Act (the “CRA”) and reinstate the CRA framework that existed prior to the October 2023 final rule.

The CRA Final Rule was intended to modernize and strengthen regulations implementing the CRA but was strongly opposed by those who argued that the rule exceeded the various banking agencies’ regulatory authority and disincentivized banks from lending in low- and moderate-income communities.

In response to the Rescission Proposal, a variety of trade groups who had formally opposed the CRA Final Rule, including the American Bankers Association and the U.S. Chamber of Commerce, issued the following: 

"We welcome today's announcement from the federal banking agencies that they intend to rescind the 2023 Community Reinvestment Act Final Rule. As we have shown in our ongoing legal challenge, the 2023 effort to modernize the rules around CRA exceeded the agencies' statutory authority and would have created disincentives for banks to invest in their communities. Given the strength of our case and the court's rulings to date, rescinding the rule is the right decision. 

“The co-plaintiffs look forward to learning more about the agencies' plan to rescind the rule. In the meantime, the nation's banks remain committed to complying with the Community Reinvestment Act and achieving our shared goal of supporting local communities and expanding economic opportunities for all Americans.”

Following formal rescission of the CRA Final Rule, banks will return to the same CRA framework that has been in place since the last comprehensive interagency update in 1995. While the future of the CRA remains an open question, the relaxation and rollback of regulation appears to be a consistent theme from the new presidential administration. Once the actual Rescission Proposal is published, we anticipate that we will have a better handle on the future of CRA.