2025 Community Reinvestment Act (CRA) Small Business, Small Farm and Community Development Lending Data: What Changed and What to Do Next

The FDIC, Federal Reserve and OCC released the 2025 Community Reinvestment Act small business, small farm and community development lending data on November 5, 2026, acting as members of the FFIEC (OCC News Release 2026-98; FDIC press release). The CRA regulations require the agencies to disclose this data every year. Along with the institution-level data, the FFIEC prepared aggregate reports of small business and small farm lending for every MSA and every county. For a CRA reporter, this is the market your 2025 lending will be measured against.

Key takeaways

• The 2025 CRA aggregate and disclosure reports and flat files are now on the FFIEC CRA data products page, covering 1996 through 2025.
• Reporters originated 8,559,067 small business loans in 2025, about 2% fewer than in 2024, but the dollar amount rose about 4.7% to $270.2 billion.
• Low- and moderate-income tracts received 21.6% of small business loans by count, nearly the same as 2024. Your share in those tracts is the number to set against your market.
• Rerun your assessment area market share and peer comparisons on the 2025 aggregate before you build this year's CRA self-assessment.

Want to see your 2025 CRA lending next to your market? Run a peer comparison in a demo.

What the agencies released on November 5, 2026

The joint release covers three things: small business and small farm loan data reported by each CRA reporter for 2025, community development lending totals, and aggregate reports for each MSA and county. The FFIEC's data products page, updated November 5, 2026, now lists four products running from 1996 to 2025:

• National aggregate reports, the nationwide totals cross-tabulated by loan, applicant and geographic characteristics.
• Aggregate reports by geography, which summarize CRA lending for each MSA.
• Disclosure reports by institution, nationwide and by MSA.
• Flat files that combine all the aggregate and disclosure data for use in statistical software or Excel.

The release also links a fact sheet and a set of 2025 CRA fact sheet tables. Every figure below comes from those tables.

Who reports CRA lending data

Under the CRA regulations, every bank except a small bank reports its small business and small farm loans by March 1 for the prior year (12 CFR 228.42(b), with parallel OCC and FDIC sections). For each geography, the report gives the number and amount of loans at or under $100,000, over $100,000 to $250,000, and over $250,000, plus loans to businesses and farms with gross annual revenues of $1 million or less. Reporters also report the aggregate number and amount of their community development loans.

The fact sheet tables group 2025 banks as small (under $402 million), intermediate small ($402 million to $1.609 billion) and large (above $1.609 billion). Under the regulation, intermediate small banks are a subset of small banks (12 CFR 228.12(u)), so neither group has to report. That is why the dataset is almost entirely large-bank lending. In all, 720 institutions reported for 2025, down from 732 for 2024. Our CRA asset-size thresholds page has the full year-by-year table.

What the 2025 numbers show

Source: 2025 CRA Fact Sheet Tables, Tables 1.1 and 1.2. Tract shares exclude loans where the tract was not reported.

Three things stand out. Loan counts fell while dollars rose, so the average small business loan got bigger. Lending to the smallest firms slipped as a share, from 53.80% of business loans by number in 2024 to 52.36% in 2025. And the split by tract income barely moved: low- and moderate-income tracts took 21.6% of business loans by count in 2025, against 21.5% in 2024.

The data is also concentrated. Large banks with $10 billion or more in assets made 7,490,183 of the 8,559,067 small business originations, or 87.5% by number and 69.0% by dollar amount (Table 3). Large banks under $10 billion made 12.4% by number but 30.3% by amount, so their loans run larger on average. Community development lending totaled 36,892 loans and $184.95 billion, with 646 reporters extending at least one CD loan; large banks made 98.9% of those loans by number (Table 6).

What the release means for your CRA program

The release does not change any rule. What it changes is the comparison. Under the CRA regulations still in force, examiners weigh a bank's lending in its performance context, which includes "the performance of similarly situated lenders" (12 CFR 228.21(b)(5)). The 2025 aggregate reports are the market a 2025 lending test will be read against, so a few things are worth doing now.

1. Pull your own disclosure report and the aggregate for each assessment area. Check that the counts and amounts match what you submitted. A difference here is easier to explain now than in an exam.
2. Recompute market share by tract income. Set your share of small business loans in low- and moderate-income tracts against your share of the whole market in the same county or MSA. A national 21.6% LMI share tells you little; the aggregate for your own markets tells you a lot.
3. Check lending to businesses with revenue of $1 million or less. The national share fell in 2025. If yours fell faster, find out whether it is a product, pricing or channel change.
4. Classify tracts with the right year. Tract income levels come from the FFIEC census file for the same year as the lending data. Our CRA tract income level classifier shows how the four income levels are set.
5. Refresh your peer group. Use the disclosure reports to see who actually lent in your assessment areas in 2025, then compare against lenders of similar size and product mix. Our guide to benchmarking CRA and HMDA lending against peer data covers how to build a peer group that holds up.

The rules may move again. The OCC and FDIC proposed amendments to their CRA rules on August 12, 2026, with comments due October 13, 2026. Until a final rule takes effect, the current regulations govern how this data is collected and used.

Using the 2025 CRA data in Comply

Comply's CRA peer analysis runs on the FFIEC's CRA aggregate and disclosure data, and its CRA Performance Evaluation and Standardized Tables reports use the performance evaluation and market share subsets. Each year RATA converts the new release for Comply and posts a notice in News when the files are ready, as we did for the 2024 data. On-premise users import the file from the support site, and RATA loads it for RATA Hosted Services customers.

With the data loaded, Comply Peer-2-Peer builds the peer comparison, Comply Mapping shades your assessment areas by tract income so gaps are visible on a map, and Comply HMDA/CRA keeps your own CRA and HMDA data in the same database, so your side of the comparison is the data you reported.

Schedule your free demo today

For the CFPB side of this fall's regulatory news, see what the CFPB's semiannual report means for fair lending and HMDA programs. Questions about loading the 2025 files? Contact RATA.

Sources

• Federal Bank Regulatory Agencies Release 2025 Small Business, Small Farm, and Community Development Lending Data
  OCC News Release 2026-98, joint release of the FDIC, Federal Reserve Board and OCC, November 5, 2026. Also issued by the FDIC the same day.
• 2025 CRA Fact Sheet Tables
  FFIEC, November 2026. Read November 10, 2026.
• CRA Data Products
  FFIEC, last updated November 5, 2026. Read November 10, 2026.
• 12 CFR 228.42, Data collection, reporting, and disclosure and 12 CFR 228.21
  Regulation BB as in effect March 29, 2024, eCFR.
• Community Reinvestment Act Regulations, proposed rule
  OCC and FDIC, August 12, 2026.

Photo by Land O'Lakes, Inc. on Unsplash.