The proposal would require large banks to document that recipients of community development grants have overhead costs of 15% or less. But the measure also reduces the number of banks that would need to comply with CRA data collection and reporting requirements. The current rule exempts “small” banks – those with less than $412 million in assets – from community development requirements. “Bank capital drives the creation of affordable housing in this country, and they do it because of CRA,” Van Tol said. That hasn’t stopped agencies in the recent past from attempting to push through a CRA revamp alone.