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What Is the Retail Lending Test? The Interactive Loan-Line Counter That Rules Which Loans Count

Run any loan through the CRA Retail Lending Test loan-line counter: see if it counts, which major product line it feeds, and which benchmark buckets it fills.

banks

Quick answer

The Retail Lending Test is how the 2023 CRA rule scores a large bank's lending across defined retail loan categories — closed-end and open-end home mortgages, multifamily, small business, small farm, automobile, credit card, and other consumer loans. A loan counts when it fits a category and was originated or purchased during the evaluation period, and it feeds the test's benchmark buckets when the property or borrower sits in a retail lending assessment area, while wholesale, warehouse, and construction-only loans are excluded.

  1. Confirm bank size status: Confirm the bank meets the large bank definition, generally $2 billion or more in assets as adjusted annually, since the Retail Lending Test applies to large banks under the 2023 rule.
  2. Select the product family: Choose the loan's product family, from closed-end mortgages to credit cards, so the counter can map it to a candidate retail loan category.
  3. Check purpose and security: Check that the purpose and lien status match the category, for example a 1-4 family dwelling behind a home mortgage loan.
  4. Flag excluded structures: Flag wholesale, warehouse, and construction-only structures, which the counter routes straight to the Excluded list.
  5. Confirm origination or purchase: Confirm whether the bank originated or purchased the loan, since the 2023 rule counts both in retail lending volume.
  6. Map the assessment area: Map the property or borrower location to a retail lending assessment area to decide whether the loan feeds the test's benchmark metrics.
  7. Read the benchmark buckets: Read which benchmark buckets the loan feeds: borrower distribution, geographic distribution, and lending volume.
  8. Document the determination: Document the determination in the loan file so examiners can trace how each loan was classified.

Use the interactive calculator or simulator below.

Full written guide, sources, and FAQs

Summary

A loan-by-loan eligibility console for the 2023 CRA Retail Lending Test: pick the product and its attributes, and the counter rules whether it counts, where it is excluded, and which benchmark buckets it feeds.

This resource helps readers connect CRA retail lending test to classroom practice, standards-aware implementation, and responsible next steps for schools and sponsors.

Run a Loan Through the Counter

The Retail Lending Test is how the 2023 CRA Final Rule measures how well a large bank serves retail borrowers and communities through its lending. Rather than one blended score, the rule organizes lending into defined major product lines — closed-end home mortgage loans and small business and small farm loans lead the list — and scores borrower mix, geographic spread, and volume against benchmarks the agencies publish. The loan-line counter on this page runs a single loan through those counting rules, gate by gate, so teams can see exactly why a line qualifies.

Choose the product family, purpose, borrower, security, amount, assessment-area location, and origination status. The counter returns three things in real time: whether the loan counts as a qualifying retail loan, which major product line it feeds, and which benchmark buckets it fills. It is a training and triage instrument built on the rule's counting mechanics, not a prediction of any rating.

Which Loans Count as Qualifying Retail Loans

Under the 2023 rule, the retail loan categories are closed-end home mortgage loans, open-end home mortgage loans, multifamily loans, small business loans, small farm loans, automobile loans, credit card loans, and other consumer loans. A loan that fits one of these categories is a candidate for the test, and the rule counts both loans a bank originates and loans it purchases during the evaluation period. The counter maps your selection to one of these categories before anything else.

  • Closed-end home mortgage loans: loans secured by 1-4 family dwellings for purchase, refinance, or home improvement.
  • Open-end home mortgage loans: home equity lines secured by 1-4 family dwellings.
  • Multifamily loans: financing for residential properties of five or more units.
  • Small business and small farm loans: business- or farm-purpose lending to those borrowers.
  • Consumer loans: automobile, credit card, and other consumer categories, which feed the test only when the consumer line is evaluated.

Which Loans Do Not Count

Three structures fail the first gate. Wholesale loans extend credit to other financial institutions for resale rather than to a community borrower. Warehouse lines fund another lender's inventory of loans awaiting sale. Construction and development loans sit outside the retail loan categories the test evaluates. When any of these is selected, the counter flips the determination chip to Excluded and stops further scoring.

Category fit is not the end of the story. A genuine retail loan can still fail to feed the test's benchmarks when the property or borrower sits outside the bank's retail lending assessment areas, and consumer-category loans only feed the test when the consumer major product line is being evaluated. The counter labels each of those states separately so nothing is silently dropped.

  • Wholesale loans: excluded as extensions of credit to other institutions for resale.
  • Warehouse loans: excluded because they finance another lender's inventory, not a community borrower.
  • Construction and development loans: outside the retail loan categories the test evaluates.
  • Loans outside retail lending assessment areas: still retail loans, but they do not feed the assessment-area benchmarks.

The Seven Facts the Counter Asks For

The counter asks for seven attributes that mirror the questions examiners ask first about any loan file. Product family decides the candidate category. Purpose and security confirm the fit, for example a 1-4 family dwelling behind a home mortgage loan. Borrower type separates households from business and farm entities. Amount, assessment-area location, and origination status decide which benchmark buckets the line can feed.

  • Product family: the loan's base structure, from closed-end mortgages to credit cards.
  • Purpose and lien status: the reason for the loan and what secures it.
  • Borrower type: individual household, business, or farm entity.
  • Amount, location, and origination status: size, assessment-area presence, and whether originated or purchased.

Reading the Line: Chip, Badge, and Buckets

The output panel holds three linked views that update as you toggle inputs, and the read that matters is which buckets fill, not a single pass-fail verdict. Three benchmark buckets — borrower distribution, geographic distribution, and lending volume — light when a qualifying loan sits inside a retail lending assessment area. They dim when a condition blocks the fill: a consumer-category loan keeps its buckets dark until the consumer major product line is elected, and a qualifying loan booked outside your retail lending assessment areas leaves the assessment-area buckets dark because those benchmarks are scored inside them. They go fully dark on the Excluded path, where no structure qualifies. The determination chip echoes the state — Counts, Conditional, or Excluded — and the product-line badge names the major product line the loan feeds or, on any dark path, the reason no buckets can fill.

Lit buckets mean the loan belongs in a retail loan category and is feeding the test's benchmark math; they do not predict performance, because benchmarks compare your distributions and volumes against published reference points. The states to resolve before an exam are the conditional ones: a consumer loan waiting on the election, or a qualifying loan booked outside your assessment areas.

Where the Counter Stops

The counter applies the 2023 rule's category definitions and counting logic in simplified form. It does not compute performance scores, weights, or rating conclusions, and it does not know your bank's actual assessment-area delineations, elections, or evaluation periods. Treat every output as an illustrative estimate for training and triage, not a compliance determination.

Implementation context matters. Compliance dates under the 2023 CRA Final Rule generally began January 1, 2026. Implementation expectations have shifted since the rule was finalized; confirm current compliance dates and requirements with your primary regulator before acting on any determination. Thresholds and category definitions are also adjusted over time.

  • No performance scoring: the tool rules on category and bucket fit only.
  • No bank-specific facts: delineations, elections, and evaluation periods stay with your records.
  • Illustrative estimates only: outputs are educational examples, not regulatory answers.

Where This Counter Sits in the CRA Library

This counter is the loan-level layer of a broader CRA qualification library. SuccessEdu's CRA library gives bank teams exam-ready tools and plain-language explainers like these, so a lending, compliance, or community development staff member can move from one loan decision to the full exam framework without leaving the cluster. Use the test-by-test anatomy study to see where retail lending sits among qualified activities, the interactive rating qualifier to connect lending results to the exam framework, and the 2023 Final Rule explainer for the timeline and data changes behind these categories. The small business loan reportability checker covers the data-collection side of the same loan files.

  • Qualified-activity anatomy: how each CRA test recognizes activity, including retail lending.
  • Rating qualifier: how lending, services, and community development feed the overall rating.
  • 2023 Final Rule explainer: tests, timelines, and data changes in one guide.
  • Small business loan reportability checker: whether a loan enters CRA data collection.

Disclaimer

This tool and page are educational resources from SuccessEdu and do not constitute legal, regulatory, or compliance advice, nor a determination of CRA treatment, performance, or rating for any bank or loan. Regulatory interpretations vary with bank facts, assessment-area maps, and agency guidance, and agencies may change how the 2023 rule is implemented. Validate every determination against the current regulation and your regulator's guidance before relying on it.

Common Questions

Does the Retail Lending Test apply to every bank?

No. The test is the lending evaluation framework the 2023 rule applies to large banks, generally those with $2 billion or more in assets, a threshold adjusted annually. Smaller and intermediate small banks continue under different evaluation approaches, and wholesale and limited-purpose institutions are largely exempt from standard CRA exams. Confirm your bank's status before counting loans.

Do purchased loans count toward the Retail Lending Test, or only new originations?

Under the 2023 rule, both originated and purchased loans count in retail lending volume, which is a shift from earlier frameworks that leaned on originations. The counter asks for origination status so each determination mirrors how the loan actually entered your book.

What are the major product lines in the test?

Closed-end home mortgage loans and small business and small farm loans are the lines evaluated by default. Open-end home mortgage loans are a related retail loan category whose treatment follows elections in the rule, and consumer loans — automobile, credit card, and other consumer categories — join the evaluation when the bank elects them or when the rule's significance conditions are met.

Why do wholesale and warehouse loans not count?

Because both extend credit to other financial institutions rather than to retail borrowers in the community. The test measures lending that reaches households and small businesses, so loans that simply finance another lender's resale inventory sit outside every retail loan category.

What happens to a qualifying loan located outside our assessment area?

It remains a retail loan in its category, but it generally does not feed the borrower, geographic, and volume benchmarks that are scored inside your retail lending assessment areas. Delineation is why the counter treats location as a separate gate rather than folding it into category fit.

How do multifamily loans count?

The 2023 rule treats multifamily loans as their own retail loan category. The multifamily benchmarks are built around where the properties sit (low- and moderate-income census tracts) and how many units are affordable, rather than around borrower demographics. A multifamily loan that is primarily for a qualifying community development purpose may also be evaluated on the community development side, so coordinate the two tracks to avoid double counting.

Can this tool replace examiner guidance or legal review?

No. It is an educational illustration of counting mechanics under the 2023 rule, built with simplified assumptions. Examiners apply official procedures, your bank's actual assessment areas, and agency guidance that continues to evolve. Use the counter to train and triage, then validate against the current regulation.

Next Steps

Sources

Community Reinvestment Act — Federal Reserve Board

Board of Governors of the Federal Reserve System

12 CFR Part 25 — OCC CRA Regulations (eCFR)

Electronic Code of Federal Regulations

Community Reinvestment Act — OCC

Office of the Comptroller of the Currency

Community Reinvestment — FDIC

Federal Deposit Insurance Corporation

Community Reinvestment Act — FFIEC

Federal Financial Institutions Examination Council

FFIEC CRA Data Collection

FFIEC / Consumer Financial Protection Bureau

Related Success Resources

What Counts as a Qualified CRA Activity? Test-by-Test Anatomy

A model blueprint that dissects one illustrative bank-school financial education partnership against the CRA qualification tests — with an interactive Qualification Anatomy Lab that toggles the specimen's components on and off, and a five-factor scorecard you run on your own program.