Barry Wides, CPA
Managing Director, Artisan Advisors

The following are prepared remarks, delivered by Barry Wides, CPA, at the Wolters Kluwer Innovation Forum on May 28, 2026, in Columbus, Ohio.

Good morning and thank you for the opportunity to speak with such an esteemed group of CRA professionals. I’m Barry Wides, Managing Director at Artisan Advisors, a Chicago-based bank consulting firm. Prior to joining Artisan Advisors, I spent 20 years at the OCC, serving as a Deputy Comptroller in the Bank Supervision Policy Department.

Today, I’d like to provide a perspective on several developments affecting CRA, community development finance, and the broader regulatory environment, as well as discuss emerging opportunities for banks to advance both community impact and business objectives.

Let me begin with a topic that has become a particular passion of mine: helping entrepreneurs establish and build credit so they can grow their businesses and contribute to their communities. I grew up in a family that operated a small HVAC business in Cincinnati. From an early age, I saw firsthand the challenges that small business owners face in obtaining capital, managing cash flow, and building sustainable enterprises. Those experiences have stayed with me throughout my career in banking policy and community development. Today, I am working with the Credit Builders Alliance and its nationwide network of more than 625 nonprofit and CDFI lenders to help connect banks with organizations that provide credit-building products, coaching, and technical assistance to entrepreneurs and small business owners. These partnerships help borrowers who may not currently qualify for traditional bank financing establish credit histories and improve their financial capability, creating a pipeline of future bank customers. The Credit Builders Alliance network reaches approximately 5.6 million predominantly low- and moderate-income individuals annually and supports more than $5 billion in credit activity.

At a time when many community development organizations face funding uncertainty, bank partnerships can play an increasingly important role in sustaining these efforts while helping institutions achieve both their CRA and business objectives.

I am also involved in efforts to expand access to growth capital for more established small businesses through the Small Business Investment Company, or SBIC, program. In that regard, I serve on the Advisory Board of Amplify Community Investments Partners, a limited partner and placement agent focused on SBICs and other community and economic development investment opportunities.

As many of you know, SBIC investments can provide attractive CRA opportunities while supporting small business growth and job creation. Yet many banks continue to underutilize these investments because of uncertainty regarding the regulatory and CRA treatment. During my time at the OCC, my team developed guidance to help banks better understand both the regulatory framework and CRA considerations associated with SBIC investments. I continue to work with institutions seeking to structure these investments in ways that align with both their CRA strategies and investment objectives.

There are also several legislative developments that may further expand community development opportunities for banks. Both House and Senate housing proposals have included provisions that would increase public welfare investment authority from 15 percent to 20 percent of capital for national banks and state member banks. While the legislative process remains ongoing, the inclusion of these provisions in both chambers reflects continued congressional interest in expanding community development investment capacity.

Similarly, Congress recently enacted significant enhancements to several important community development programs. The New Markets Tax Credit program was made permanent at $5 billion annually. The Opportunity Zone program was also made permanent, with additional incentives directed toward rural investments and rehabilitation projects. New Opportunity Zone census tracts will become effective in 2027 under updated eligibility standards. If you would like to dig deeper into these changes, please check out the article on the OZ program. The tax and spending legislation also expanded the Low-Income Housing Tax Credit program by increasing state allocations for 9 percent credits and reducing the private activity bond financing threshold from 50 percent to 25 percent for projects seeking access to 4 percent credits. Collectively, these changes are expected to significantly increase affordable housing production over the coming decade.

Perhaps the most important issue for this audience remains the future of CRA modernization. As you know, the 2023 CRA rule remains tied up in litigation and last summer, the agencies proposed to withdraw that rule and reinstitute the 1995 CRA rule. No action has been taken to finalize that action. As a result, uncertainty remains regarding the long-term direction of CRA regulation.

For now, banks should remain focused on executing sound CRA strategies under the existing framework while maintaining sufficient flexibility to adapt to future regulatory developments.

With new leadership now in place across the federal banking agencies, it would not be surprising to see additional policy developments in this area over the coming year.

Finally, I would like to discuss the OCC’s proposed strategic plan framework for banks under $30 billion in assets. Although directed toward community banks, the proposal contains insights that may be valuable to institutions of all sizes.

The proposal does not fundamentally alter the strategic plan concept. However, it provides significantly more transparency regarding potential performance measures and benchmarks that banks may use when developing CRA goals. Even institutions that do not pursue a strategic plan may find these metrics useful as they evaluate performance management practices and establish internal CRA objectives.

I recently prepared a summary of the proposal and its potential implications, including a discussion of the performance benchmarks identified by the OCC. I would be happy to discuss those observations further during our question-and-answer session.

Let me close with a broader observation.

Throughout my career—whether at Freddie Mac, the Federal Home Loan Bank Board, the FDIC, the OCC, or now in consulting—I have seen regulatory frameworks evolve, supervisory priorities change, and political administrations come and go. Yet the fundamental purpose of CRA has remained remarkably consistent: encouraging banks to help meet the credit and community development needs of the communities they serve.

Whether through partnerships with CDFIs, investments in affordable housing, support for entrepreneurs and small businesses, or innovative approaches to financial inclusion, there remains tremendous opportunity for banks to create meaningful impact while achieving their business and CRA objectives.

Thank you again for the opportunity to join you today. I look forward to your questions and to continuing the conversation. And if I can be of assistance after today’s forum, please feel free to reach out to me at [email protected].

Thank you very much.