About 83% of CRA “covered” lenders do not report lending under CRA
On November 13, the Federal Bank Regulatory Agencies announced the availability of the 2024 CRA lending activity of 731 lenders who reported data on their small business and small farm lending, as well as their community development lending activity. This represents a small increase (10 additional lenders) compared to 2023. Of the reporting lenders, 61 were below the mandatory reporting threshold for 2025 ($1.564 billion in assets) and therefore reported on a voluntary basis. This gives those institutions the option to be examined under the “Large Bank” examination standards.
There are approximately 4,300 institutions that are “covered” (i.e., have CRA responsibilities) under the Community Reinvestment Act, but about 3,600 — or roughly 83% — do not report under the Regulation. Although only about 17% of banks report CRA data, the agencies estimate (using Call Report information) that these institutions account for approximately 77.6% of all outstanding small business loans by dollar volume.
In terms of lending volume, the data show that 9,106,208 small business loans were originated or purchased during 2024. Loan originations accounted for 95.9% of the total activity (originations plus purchases) by count and 93.2% by dollar value. The number of small business loans represents an increase of about 8.1% compared to the activity reported for 2023.
The release date itself is somewhat surprising, since for years the data has not been released until mid-December of the following year. This latest release is therefore about six weeks ahead of schedule.
The availability of the 2024 Aggregate & Disclosure data will now allow the completion of CRA performance analyses that have been delayed pending the release of market data. In an interesting contrast, the CFPB — which is responsible for processing and releasing the annual HMDA data — typically makes that data available within two months after it is reported by lenders on March 1. The agencies have never explained why the release of the annual CRA data does not occur until almost ten months after it is reported by banks. This long delay impedes timely CRA performance analysis, slowing both the identification of potential performance shortcomings and lenders’ ability to initiate corrective actions.
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