Success by JazE Edutech / Resource Kit
Resource Kit
A field-by-field readiness kit for large-bank CRA data collection: inventory worksheets, a compliance-date runway, QC checklists, and a pre-submission audit flow.
Under the 2023 CRA final rule, large banks — generally those with at least $2 billion in assets — must collect and report loan-level retail lending data (home mortgage, small business, and small farm loans, plus automobile loans for significant retail lenders), annual deposit data, and records for the community development loans, investments, and services they want considered, with most obligations starting January 1, 2026 and the rest on January 1, 2027. Your bank's asset tier at its December 31 snapshot sets exactly which duties apply and when.
Full written guide, sources, and FAQs
A control-tower-style readiness kit that turns the large-bank CRA data collection rules into field inventories, a two-date compliance runway, and a pre-submission audit your team can actually run.
This resource helps readers connect CRA data collection requirements for large banks to classroom practice, standards-aware implementation, and responsible next steps for schools and sponsors.
Under the 2023 CRA final rule, a large bank — generally one with at least $2 billion in assets — builds four data streams rather than one: loan-level retail lending records covering home mortgage, small business, and small farm lending, plus automobile lending if the bank qualifies as a significant retail lender; an annual deposit data report; documentation for every community development loan, investment, and service the bank wants considered; and the recordkeeping that ties it all together. Most obligations begin January 1, 2026, with the remaining provisions following on January 1, 2027.
This kit converts those requirements into an operating routine: a field-by-field data inventory, a compliance-date runway that starts at the December 31 asset snapshot, quality-control checks, and a pre-submission audit flow. It answers the institution-level question — is our collection process exam-ready? — while the loan-level reportability checker answers whether any individual loan belongs in the file.
The kit is built for CRA officers, compliance leads, and data teams at banks that sit above the $2 billion intermediate-bank threshold — or that could cross it, because a bank's category is set by total assets as of December 31 in either of the two preceding calendar years, so a single strong year above the line moves you into the large-bank tier. Internal audit, core-system vendors, and loan operations teams will find the worksheets map cleanly onto their existing quarterly routines.
Everything in the kit is worksheet-first: each piece produces a filled-in sheet your team can place in the exam file, not a summary you have to reinterpret. The four pieces build on each other in order, and each one feeds a stage of the Readiness Control Tower described below.
The kit runs as what we call the Readiness Control Tower: a four-stage board — Map, Build, Verify, File — built into this page as an interactive panel. Each stage carries a visible state that changes on your actions: a stage reads not started until its worksheet is opened on the page, moves to building as fields and owners are claimed, flips to verified when quality-control sampling passes, and reaches exam-ready only after the pre-submission audit signs off. Because the board lives on the page, every state change stays visible — progress is something you can point at, not something a teammate has to remember.
The tower also carries a small significant-retail-lender input: enter your automobile lending's share of retail lending volume over the two-year lookback, and the board flips the automobile block on at 15 percent — mirroring the $2.4 billion worked scenario in the walk-through below. Put the board on the agenda at least quarterly before 2026 and monthly once the January 1, 2026 window opens, so no stream arrives late or unverified.
Work the checklist stage by stage, in order, and resist promoting a data stream until the stage before it reads verified. The six moves below cover every domain the large-bank rules touch and every compliance date that governs them — treat any unchecked move as an open risk sitting in the exam file.
Worksheet 1 is a table, not prose: one row per data domain — residential mortgage, small business, small farm, automobile, deposits, and community development loans, investments, and services — and one column each for the source system, required fields, named owner, activation date, and status. Mark each row red for unmapped, amber for building, and green for verified, and the color pattern tells you at a glance which systems will actually deliver in January.
The runway half of the worksheet works the same way. Your December 31 asset snapshot fixes the category; January 1, 2026 switches on the core collection duties — home mortgage, small business, and small farm loan data, the annual deposit report, and community development recordkeeping — while January 1, 2027 brings the second wave, led by automobile loan data for banks that qualify as significant retail lenders. Re-run the significant-retail-lender test every cycle — a $2.4 billion bank whose auto lending sits at 11 percent of retail volume skips auto fields today, but one strong auto year pushing that share to 15 percent or more turns the block on for the January 1, 2027 wave.
This kit is one piece of a connected set of CRA reporting resources on SuccessEdu. Use the tools to answer point questions and the guides for the rule's mechanics; use this kit when the question becomes institutional — who owns each field, and is every stream ready by its date?
This kit is educational. It is not legal, compliance, tax, or regulatory advice, and it does not guarantee any CRA rating, examination outcome, or regulatory treatment — CRA treatment depends on institution-specific facts and examiner review. Thresholds, dates, and data rules can change through amendments and supervisory guidance. Confirm current requirements with your primary federal regulator and your own compliance and legal teams before collecting, submitting, or filing anything.
Under the 2023 final rule, banks fall into small (below $600 million), intermediate ($600 million to $2 billion), and large (at or above $2 billion) categories, with the thresholds adjusted annually. Your category is set by total assets as of December 31 of the two preceding calendar years, so crossing a threshold in either year moves you into the larger tier.
Most large-bank collection and reporting obligations begin January 1, 2026, with the remaining provisions — including automobile loan data for significant retail lenders — beginning January 1, 2027. Because your category comes from the December 31 snapshot, the December 31, 2025 balance sheet effectively determines what your bank owes in the first year. For the dates that apply to your own tier and provisions, use the compliance-date lookup.
No. The rule builds home mortgage reporting on data your bank already collects under Regulation C (HMDA), layering CRA-specific reporting on top rather than asking for a duplicate collection stream. Keep the two mappings aligned so HMDA edits and CRA reporting do not drift apart.
No. Automobile lending data applies when a bank qualifies as a significant retail lender in that product line, which the rule measures by the product line's share of retail lending volume over a two-year lookback. Banks below the line should re-run the test each cycle, because a single strong auto year can turn the requirement on.
Large banks submit CRA retail lending data to the Consumer Financial Protection Bureau — the same agency that administers HMDA data submissions — while the Federal Reserve retains supervisory and examination authority. Treat the submission as a rehearsal-worthy event: test the file format before the real filing window and archive the confirmation.
The checker answers a loan-level question: whether one specific small business loan belongs in your CRA data. This kit answers the institution-level question: whether every stream, system, and deadline in your collection process is exam-ready across all four data domains and both compliance dates.
Federal Reserve Board
Federal Reserve Board
Federal Financial Institutions Examination Council
Consumer Financial Protection Bureau
Federal Deposit Insurance Corporation
Walk one small business loan through the reportability gates: product, size, and borrower revenue decide whether it must be reported for CRA. See which thresholds apply and which data points the file should capture.
A decision worksheet, exam-file checklist, and note templates that walk a single PPP loan file to one of two CRA outcomes — reported small business lending or documented community development financing.
A weighted, evidence-based scorecard that turns your must-have requirements into a ranked vendor shortlist — plus the printable selection memo your committee can file.