thresholds in the revised rule. It’s possible for some institutions to change categories between now and Jan. 1, 2026, so it will be important to understand your institution’s growth trajectory. • Once you understand the asset size category your institution will fall into, you’ll want to have the regulatory exam guides available to understand what required tests your institution will be subject to in future regulatory exams and what tests would be optional for compliance. • Once you understand the tests that will apply, you’ll need to understand what geographies your institution will be evaluated on. This is especially important to identify early, since there could be geographies you’re not evaluating for CRA compliance today that you will need to evaluate in the future to understand your institution’s CRA performance. • Once you understand the new tests and geographies, you’ll use the processes you’re likely familiar with today to move forward: Evaluate how your institution is currently performing and use that self-assessment to formulate future action plans for improved CRA compliance. Whether working through Sec. 1071 small business data collection or understanding the revised CRA regulation, plan ahead; the changes are complex. Make sure you engage experts you trust to provide the support and expertise you need to successfully comply. Plante Moran is one of the nation’s largest audit, tax, consulting and wealth management firms. Company founders called Plante Moran a “grand experiment.” And while a lot has changed in 100 years, the culture and values have not. Learn more by visiting www.plantemoran.com. Reliable expertise. We have extensive experience and technical expertise in the financial institutions industry. Our professionals are prepared to help you address any challenge and leverage every opportunity. Ryan Abdoo, partner ryan.abdoo@plantemoran.com Scott Petree, partner scott.petree@plantemoran.com plantemoran.com 15 Colorado Banker
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