Success by JazE Edutech / Case Study
Case Study
Replay one regional bank's CRA assessment-area map across the 2023 final rule: facility-based areas, new retail lending areas, and the exam files at each checkpoint.
For banks with $2 billion or more in assets, the 2023 CRA final rule kept branch-based assessment areas — renamed facility-based assessment areas — and added retail lending assessment areas: counties, or entire metro areas, where the bank made at least 100 home mortgage, small business, or small farm loans in either of the prior two years, even with no branch there.
Full written guide, sources, and FAQs
One regional bank's CRA map, before and after the 2023 final rule: three branch-based assessment areas carry over as facility-based areas, and a 100-loan county appears as a new retail lending assessment area. A model delta, grounded in public rule text.
This resource helps readers connect 2023 CRA final rule assessment areas to classroom practice, standards-aware implementation, and responsible next steps for schools and sponsors.
This page is a public-data report with a model at its center. It replays one regional bank's assessment-area map across the transition to the 2023 Community Reinvestment Act (CRA) final rule, map state by map state, so the change reads as a before-and-after map rather than as rule text. The bank at the center of the replay, Kestrel Regional Bank, is a model institution, not a real one, and every figure attached to it is illustrative.
Read the public sources as the authority layer and the model as the demonstration layer. The final rule text, the Federal Reserve's announcements, and agency CRA resources determine what the framework requires; Kestrel's map shows what those requirements look like when they land on an ordinary branch network. Nothing attributed to Kestrel is a market fact, an agency decision, or an outcome any institution has achieved.
For branch-network banks with $2 billion or more in assets, the 2023 final rule kept branch-based geographies and added to them. Existing assessment areas built around main offices, branches, and deposit-taking ATMs continue as facility-based assessment areas, while a retail lending assessment area must be delineated for any county — or entire metropolitan area — where the bank made at least 100 home mortgage, small business, or small farm loans in either of the two prior years.
Kestrel's replay shows the delta on one map. Before the rule, the bank's lending in Hollis County — 176 home mortgage originations in 2024 and 152 in 2025 in the model — sat entirely outside its three branch-based assessment areas. After the rule, those three areas carry over as facility-based areas and Hollis County appears as a fourth polygon, a retail lending assessment area, examined for lending performance with no branch inside it.
Under the legacy framework, an assessment area was built from physical presence: geographies containing the bank's main office, its branches, and its deposit-taking ATMs, drawn as whole metropolitan areas or as contiguous geographies that did not extend arbitrarily beyond where the bank operated. A county could receive substantial lending volume from a bank with no branch inside it and still fall entirely outside that bank's assessment-area lines.
The final rule, released October 24, 2023 and effective April 1, 2024, retains that geographic skeleton for banks with $2 billion or more in assets and formalizes the language around it: facility-based assessment areas for the branch network, retail lending assessment areas for the loan-count triggers, and a four-test evaluation framework — retail lending, retail services, community development financing, and products and programs — that scores performance inside both area types.
The delta is the story: three branch-based polygons before the rule, four after, and the new fourth polygon is drawn around lending the bank already had but had never had examined. The replay below traces that one change and the exam-file trail that accumulates behind it; each step names the decision that moves the map, the map state it produces, and the artifact it files. Every number belongs to the model, so treat the map's before-and-after — not the figures — as the transferable part.
The new layer changes the exam record, not just the map. Retail lending results are scored in each facility-based area and each retail lending assessment area, so a county that never appeared on a public-file map now carries examined lending performance. The rule pairs that scoring with new data collection: covered banks report retail lending data on home mortgage, small business, and small farm loans, with application-level small business and small farm records feeding the evaluation.
The coverage signal cuts both ways. A bank can no longer leave a high-volume lending county outside its evaluated footprint, and a branch-based map alone no longer describes where a bank's community presence is actually measured. For bank teams, the practical finding is that delineation, data preparation, and exam readiness have merged into one workflow with shared artifacts.
SuccessEdu uses the delta replay as training scaffolding for bank teams, sponsor programs, and community partners: walk your own institution through the same four checkpoints using your branch and ATM inventory, your county-level origination counts, and your public file. The exercise turns the rule's language into one shared picture that lending, community-development, and training staff can discuss in a single meeting. It is educational support, not legal or compliance advice.
Four tasks carry the replay back to your own institution, and each has a resource that does one job: confirm your dates with the compliance-date lookup, which maps the rule's schedule by provision; understand the full framework with the 2023 final-rule explainer; see the branchless contrast in the branchless delineation kit; and prepare your reporting with the large-bank data readiness kit. Each task picks up where the replay leaves off — the dates you owe, the framework behind them, the case the rule treats differently, and the data you must be ready to report.
This report is a model replay, not a study of a real institution. Kestrel Regional Bank, its branch counts, its loan volumes, and its county figures are illustrative constructions chosen to expose the rule's mechanics; no agency action, exam result, or outcome is claimed for any bank. Thresholds and delineation duties also depend on each institution's own measurements under the rule, so the checkpoint sequence cannot be copied mechanically.
Implementation is still phasing in: most obligations began with the general compliance date of January 1, 2026, additional provisions phase in during 2027, and agencies continue to publish supervisory and interpretive materials. The 2023 rule has also faced industry legal challenges and agency reconsideration activity, and portions of that schedule or of the requirements may be revised as a result; confirm the rule's current status in the cited Federal Register text and agency announcements before relying on any date. Verify current requirements against the rule text and agency guidance before acting, and consult your own counsel or compliance function for institution-specific decisions.
Every rule-based claim in this report — the facility-based and retail lending assessment-area definitions, the 100-loan county trigger, the $2 billion threshold, and the compliance schedule — comes from the public sources listed below. The Kestrel figures are the report's own model constructions, so they carry no citation: they demonstrate the framework rather than evidence about any institution.
It is the assessment area built from a bank's physical presence — the geographies containing its main office, branches, and deposit-taking ATMs. Banks with $2 billion or more in assets delineate facility-based assessment areas under the new framework, continuing the branch-based approach under updated regulatory language.
A county — or, where the county falls inside a metropolitan area, the entire metro area — becomes a retail lending assessment area when the bank made at least 100 home mortgage loans, at least 100 small business loans, or at least 100 small farm loans there in either of the two prior calendar years, regardless of whether the bank has a branch.
No. For covered larger banks, branch-based areas continue as facility-based assessment areas; the retail lending assessment area is an additional layer, not a replacement.
The rule took effect April 1, 2024, most provisions have a general compliance date of January 1, 2026, and additional obligations phase in during 2027. The compliance-date lookup on this site maps the schedule by provision.
It determines which banks operate under the new framework, including the duty to delineate both facility-based and retail lending assessment areas. Banks below the threshold generally continue under the prior framework with its delineation options.
No. It is a model institution created for this replay, and its branch counts, loan volumes, and county figures are illustrative. Nothing in the report describes an actual bank, exam, or agency decision.
Federal Reserve Board
Office of the Comptroller of the Currency
Federal Reserve Board
Federal Financial Institutions Examination Council
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