CRA compliance software that reads the loan file, cites the deciding passage beside 12 CFR 25, and lets two named people decide
Every community development activity qualified from its source document, then signed.
See one case, screen by screen ↓CRA compliance software helps a bank's CRA Officer and CRA team qualify community development activities, track lending, investment and service by assessment area, and prepare for the CRA exam. In CRA Compliance, eight agents read each candidate's loan file, prospectus, grant letter or volunteer log and propose whether it qualifies, with the deciding passage beside 12 CFR 25 and the interagency Q&A. A CRA Data Analyst accepts or edits with a reason code, and the CRA Officer signs.
AI use cases in banking: a buyer's guide to agentic AI for bank and credit union operations →
Updated
CRA compliance software is judged on one question per activity: does this loan, investment, grant or volunteer hour count as community development, and where? The answer sits in the source document. A regulatory agreement says how many units are restricted, at what share of area median income and for how long; a fund prospectus says where the money goes; a volunteer log says whether the work used financial expertise. Under 12 CFR 25 and the interagency Q&A, a mixed-income project with fewer than half its units affordable earns only its affordable share, personal-time volunteering does not count, and a loan already reported as a retail loan does not count twice, unless it is a multifamily loan.
Today a CRA Data Analyst finds and reads those pages by hand for about 1,400 candidates a year at a bank of 640 branches, then types the answer into a tracker. Progress against the year's plan is totaled each quarter, so an assessment area that is behind is found in the fourth quarter, too late to source a deal, and over-claimed activities come out at the exam. CRA Compliance puts eight agents in front of that reading, so the analyst and the CRA Officer decide on the passage itself.
Estimated split of an analyst's time on one candidate, by hand and with the agents. The 45 minutes by hand is an estimate for the demo bank; the 'after' column is the analyst reading the agents' cited proposal, about 5 minutes, our arithmetic, kept modest.
Eight agents read, place, qualify and challenge every activity; an analyst accepts and the CRA Officer signs.
CD-2026-1187: a $4.2 million construction-to-permanent loan to Brookfield Commons LP for 84 apartments in the Dayton-Kettering assessment area, where community development lending stands at 71% of plan with 81% of 2026 gone. Here is what happens to it at Corvane National Bank, screen by screen, in the working solution.
Last night the agents read 41 documents, proposed 23 answers, raised 2 second-read challenges and checked 89,214 loans. Danielle Okafor's start page shows 14 qualifications waiting for her signature, the OCC CRA exam on March 8, 2027, and that the volunteer tracking system's nightly file did not arrive, with a Retry button.
Community development lending signed: $441.9 million, 88% of the $501.9 million plan.
The community development docket lists each candidate in plain words, with the agents' answer in one chip, the purpose, the assessment area and the test. 85 are open. The line across the top shows 38 areas against the 2026 plan: 27 on pace, 8 behind, 3 well behind.
Dayton-Kettering is behind: community development lending at 71% of plan.
The recorded regulatory agreement, Section 3, page 3 of 14, restricts 62 of the 84 units to households at or below 60% of area median income for 30 years. Beside it sit 12 CFR 25.12(g), 25.12(h) and Interagency Q&A § __.12(h)-8. The proposal: Qualifies, affordable housing, lending test, full $4,200,000, confidence 0.96.
The Document reader opened 4 documents and 312 pages; the Geography agent placed the property in census tract 0806.00, moderate income; 62 of 84 units is 73.8%, a majority, so the whole loan counts. The loan is also in the HMDA data as a multifamily loan, which the rule allows. The Second-read agent tries to prove it wrong, and here agrees.
Agrees. The restriction is recorded and runs 30 years. Not claimed in any other area or test.
Theo Lindqvist accepted it at 9:12 AM with reason A1, agrees with the agents. Danielle signs at 10:41 AM; the signature records the passage, the rule and the agent versions used. Dayton-Kettering moves from 71% to 84% of plan, $26.9 million of $32.0 million, and the line reads 28 on pace, 7 behind, 3 well behind.
The person who accepted a qualification can never sign it.
Northgate Lofts, Columbus: a $9.8 million loan for 120 apartments, 18 of them restricted to households at or below 80% of area median income for 15 years. Under half the units are affordable, so the agents propose only the share: 15%, or $1,470,000. The Second-read agent agrees and notes the 15-year term.
A $3.1 million loan to Lakeview Medical Plaza LLC, a clinic building in a moderate-income tract in Charleston, was proposed as qualifying. The credit memo shows three private practices and no public plan or patient information, so the Second-read agent challenged it and moved it to Needs you.
Ask the relationship manager for evidence, or reject with a reason.
Each area's lending, investment and service tests are shown against this year's plan, with a marker for how much of the year has gone. 28 of 38 are on pace. Toledo is furthest behind on qualified investments at 41%, then Charleston on lending at 48% and Eastern Kentucky on service hours at 52%.
Toledo has $1.9 million of a $4.6 million investment plan. The Plan agent names three pipeline items: $1.8 million in a housing equity fund for 3 tax credit projects in Lucas County, a $500,000 certificate of deposit at a low-income designated credit union, and $400,000 to a home repair loan pool named by 7 of 9 community contacts. Each still goes through the docket and two signatures.
Together $2.7 million: investments would reach $4.6 million, 100% of plan.
Every action by a person or an agent is on the trail with who, what, when, why and the evidence. The examiner pack for the March 8, 2027 exam builds one folder per assessment area: signed activities with their passages and signatures, narratives, the data integrity log, the public file, plan minutes, and the agent, prompt, model and rule versions.
37 overrides this year, each with a reason code.
The same docket, seen by the five people who carry it: what their week looked like, and what it looks like now.
Eight agents read, place, qualify and challenge every activity; an analyst accepts and the CRA Officer signs.
Reads loan files, regulatory agreements, fund prospectuses, grant letters and volunteer logs, turns each candidate into one plain sentence, and quotes the deciding passage with its page.
Geocodes each address and finds the census tract, its income level and the assessment area, or the broader statewide or regional area that includes it.
Proposes Qualifies, Does not qualify or Needs you, with the purpose, the test and the credit, full or pro rata, citing 12 CFR 25 and the interagency Q&A.
Argues against every Qualifies and samples 20% of the rest: the majority test, pro rata credit, financial expertise and personal time, double counting, and broader-area claims.
Recomputes every area's progress against plan after each signature, finds the pipeline and community needs that would close a gap, and proposes next year's plan.
Checks HMDA and CRA small business data before the March 1 filing: tract against the geocoded address, revenue indicator, amount against the note, dates, duplicates and double counting.
Drafts the performance context and assessment area narratives in short, plain sentences, each citing a record, a community contact or public data.
Checks the public file against 12 CFR 25.43, logs every written public comment, and drafts the acknowledgment and the reply.
Signs every qualification. The agents propose; a named person decides.
Ask about any activity, assessment area, rule, data check or public file item, or say what to change. Every answer points to its source, and nothing changes until a person approves it.
Why does Brookfield Commons qualify?
It is affordable housing: the recorded regulatory agreement restricts 62 of the 84 units to households at or below 60% of area median income for 30 years. That is a majority, so the whole $4.2 million counts, and as a multifamily loan it may count as a community development loan even though it is in the HMDA data. Theo Lindqvist accepted it at 9:12 AM; it is waiting for your signature.
Which areas are behind plan, and what would close the gap?
The furthest behind is Toledo: qualified investments at 41% of plan. Three pipeline items, a housing fund, a credit union deposit and a home repair loan pool, add $2.7 million and would bring it to 100%.
Draft a reply to the public comment about the West Third Street branch
The comment asks what services stay on West Third Street and for more affordable rental housing. It relates to CRA performance, so it is filed in the public file with the reply. A reply is drafted and prepared by Theo Lindqvist; it names no private person. It is waiting for your approval.
Build the examiner pack for the OCC exam
One folder per assessment area with every signed activity, its passage, its rule and both signatures, the narratives, the data integrity log, the public file and the committee minutes. Nothing is retyped; it is built from the record.
13 screens from the working solution, on its sample data. Pick one to see it large.
The rules every activity is qualified against are settings, versioned, approved by the CRA Officer and on the audit trail.
| Setting | Default | Choose from |
|---|---|---|
| Qualification rule set | 12 CFR 25, the 1995 rule as restored in 2021, version 2026.3 | The 2023 interagency rule is kept for reference and never applied |
| Pro rata credit for mixed-income housing | On | Offer the affordable share when under half the units are affordable |
| Broader statewide or regional area | On | Credit activities that include an assessment area |
| Multifamily loans also in HMDA data | Counted as community development loans | As 12 CFR 25.12(h)(2)(i) allows |
| Qualification agent confidence threshold | 0.85 | Below it, the answer is Needs you |
| Second read | Every Qualifies, 20% of the rest | Can only send an item to a person |
| Bulk signing of qualifications | Off by policy | The CRA Officer signs one at a time |
| SLAs | Decide within 15 business days; sign within 5 | Escalations go to the CRA Officer; comment replies within 30 days |
Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.
Sources: 12 CFR part 25 (ecfr.gov) · Interagency Questions and Answers Regarding Community Reinvestment, 81 FR 48506, July 25, 2016 (federalregister.gov) · OCC Bulletin 2025-18, proposed rescission of the 2023 CRA rule (occ.gov) · FDIC, 4,421 insured institutions at Q2 2025 (fdic.gov) · "demo" = seen in the working solution, on its sample data · "target" = design goal, measured in the live solution · "typical" = published figures · "estimated" = our estimate for the demo bank (about 1,400 candidates a year, about 45 minutes each by hand). Corvane National Bank, the organizations and projects, and the people named on this page are fictional: characters and sample data in the working solution.
CRA compliance software helps a bank's CRA Officer and CRA team qualify community development activities, track lending, investment and service by assessment area, and prepare for the CRA exam. In CRA Compliance, eight agents read each candidate's loan file, prospectus, grant letter or volunteer log and propose whether it qualifies, with the deciding passage beside 12 CFR 25 and the interagency Q&A. A CRA Data Analyst accepts or edits with a reason code, and the CRA Officer signs.
Under 12 CFR 25.12, community development covers affordable housing, community services, economic development, and revitalizing or stabilizing low- or moderate-income areas, through community development loans, qualified investments and community development services. The Qualification agent proposes the purpose, the test and the credit from the source document, and the Second-read agent checks the majority test, financial expertise, personal time, double counting and broader-area claims.
When a majority of units are affordable, the whole loan counts; when fewer than half are, only the affordable share counts, as the interagency Q&A allows. In the working solution, 62 of 84 affordable units earn Brookfield Commons full credit for $4.2 million, while 18 of 120 earn Northgate Lofts $1,470,000 of $9,800,000.
12 CFR 25.43 lists what goes in the public file, among them the public's written comments for the current and prior two calendar years with the bank's response, the latest performance evaluation, branch lists with openings and closings, and assessment area maps. The Public file agent checks the file against that list, logs each comment and drafts the reply; the CRA Officer approves before anything is filed.
The 1995 rule, as the OCC restored it in 2021, with the 2016 interagency Q&A. The 2023 interagency rule was enjoined on March 29, 2024 and its rescission was proposed on July 16, 2025, so it is kept for reference and never applied. Rule sets are versioned settings, and each signature records the version used.
Yes. The Data check agent checks every reportable loan before the March 1 filing, such as the census tract against the geocoded address, the revenue indicator and duplicates, and proposes each fix with the document behind it. It never edits a record: the analyst accepts fixes, in bulk where they share a check, and the CRA Officer signs the submission.
Yes. Agents read, place, propose, challenge and draft; they never sign, file, publish to the public file or change a plan. The analyst who accepts a qualification can never sign it, and an internal auditor can read and export everything but approve nothing.
The Agentic Solution Engine builds and deploys it from your requirements and documents, such as your CRA procedures, assessment areas, plan and a sample of past activities, and it goes live once every quality gate has passed. We will walk you through it on your own loan files first.
Every item tested, not 60, and every exception evidenced before the exam.
1-min demoCustomer RemediationEvery affected customer found and paid, and every dollar traced to its end.
1-min demoUDAAP Risk AssessmentMisleading claims, hidden fees and hard exits fixed before launch, not refunded after.
1-min demoWe'll run CRA Compliance on a sample of your own loan files, investments and volunteer logs.