What does a bank have to do with child care? For rural communities, the answer is: quite a lot.
When a community does not have enough child care, parents can have trouble getting to work. Employers can have trouble finding workers. Child care providers may have long waiting lists or be unable to expand. And communities can have a harder time attracting and keeping families.
That is why First Five Nebraska is paying attention to a proposed change to the federal Community Reinvestment Act (CRA).
Federal regulators are considering whether child care should be clearly recognized as a form of “civic assistance” under the CRA. We believe it should, and we want Nebraska’s child care community to have a voice in the conversation.
Public comments are due October 13.
First, What is the CRA?
The Community Reinvestment Act has been around since 1977. Congress created the law in response to concerns that some communities, particularly those with low- and moderate-income families, were not receiving fair access to credit and investment.
The basic idea is straightforward: Banks have a responsibility to help meet the credit needs of the communities where they do business, including low- and moderate-income communities. Over the years, federal banking regulators have updated the rules that determine how banks receive credit for their community investments. Now those rules are being considered again.
Why is this Coming up Now?
The CRA has gone through several changes in recent years. In 2023, the Federal Reserve, Federal Deposit Insurance Corporation (FDIC) and Office of the Comptroller of the Currency (OCC) issued a major update to the CRA regulations. In 2025, the three agencies proposed rescinding that rule and returning to the 1995 framework.
The latest proposal, issued by the OCC and FDIC on August 12 would make additional changes to the CRA rules, including providing more clarity about activities that may receive CRA consideration.
One of those activities is child care. The proposal specifically includes child care in its definition of “civic assistance.” That creates an opportunity to make sure the final rules recognize the kinds of child care investments that communities actually need.
Why Does this Matter in Rural Nebraska?
Think about a small community with three child care providers. One closes. Another is full. The third wants to expand but cannot afford the cost of a building renovation or additional equipment.
Suddenly, families have fewer options. An employer may have trouble filling an open position. A parent may have to turn down work or reduce hours. That is not just a child care problem. It is a community and economic development problem.
Rural communities often face an additional challenge: finding the financing to solve it. A community may know it needs more child care, but still needs several pieces to come together. A bank might provide financing. An employer might contribute. A local economic development organization might help with planning. Public funding or philanthropy might fill another gap.
The CRA can be one piece of that puzzle.
What Could CRA-Supported Child Care Look Like?
The proposed rule includes child care as civic assistance, but we believe the final rule should make clear that this can mean more than simply financing the construction of a child care center.
It could include support for:
♦ Building, purchasing, renovating or expanding child care facilities
♦ Starting or expanding child care centers and family child care businesses
♦ Equipment and other investments that create additional child care slots
♦ Shared or community-based child care facilities
♦ Partnerships between employers and communities to increase child care capacity
♦ Feasibility studies, business planning and other early development work
♦ Training and other efforts that strengthen the child care workforce
These investments can have a ripple effect. More child care slots can mean more parents able to work. More workers can help local employers. A stronger child care business can create jobs. And a community with reliable child care can be better positioned to attract and retain families.
What About Low- and Moderate-Income Families?
This is an important part of the conversation. The proposed rule connects civic assistance to activities that serve, assist or are reasonably expected to serve low- or moderate-income individuals or families.
But rural child care does not always fit neatly into that model. A child care center may serve families across income levels. A family child care provider may care for children from several different households. A community may need more child care capacity for everyone. That does not mean the investment is not benefiting families with low and moderate income.
When a community adds child care capacity, the benefits can extend across the local economy. A parent can take a job. An employer can hire another worker. A provider can grow a small business. A community can become a stronger place to live and work.
We believe the CRA should recognize that broader community impact.
What Can You Do?
This is where you come in. The OCC and FDIC are accepting public comments on the proposed rule through October 13. Comments should reference Community Reinvestment Act Regulations and Docket ID OCC-2026-0694.
You do not need to be a banking expert. You do not need to understand every part of the proposed rule.
Tell Them What You Know
♦ If you are a child care provider, explain what it takes to start, maintain or expand your business.
♦ If you are a parent, tell them what access to child care means for your ability to work.
♦ If you are an employer, explain how child care affects your workforce.
♦ If you are an economic development or community leader, describe how child care affects your community’s ability to grow.
♦ And if you have worked with a bank or other financial institution on a child care project, tell regulators what that partnership made possible.
Your comment does not have to be long. A few specific paragraphs about your community can be more powerful than a general statement.
A Simple Starting Point
You can use this template and make it your own:
“I am writing to support keeping child care in the definition of “civic assistance” in the proposed Community Reinvestment Act regulations.
I live/work in [community or region], where access to child care is important to families, employers and our local economy.
In our community, [describe the child care situation or challenge].
This affects more than families who need child care. [Describe the impact on parents, employers, providers or the community.]
I support recognizing child care as a community investment under the CRA. This should include support for [facility expansion, provider financing, equipment, workforce development, community partnerships, etc.].
Please retain child care within the definition of civic assistance and provide clear guidance that CRA consideration can include the types of financing and community investments rural communities need to expand and sustain child care.
Thank you for considering my comment.”
Make it personal. Add the name of your community, describe what you are seeing and explain why it matters.
To make your comment, click Submit a public comment through Regulations.gov, read through the comment and click the green “Submit a Public Comment” button at the top to get started.
This is About More Than One Regulation
The CRA will not solve Nebraska’s child care challenges by itself. But it can help create another way for financial institutions to partner with communities on child care solutions.
At First Five Nebraska, we have seen communities across the state increasingly connect child care with workforce development, business growth and economic development. In rural communities especially, those issues are closely connected.
When child care works, parents can work. Businesses can grow. Communities can grow. Child care is infrastructure for the workforce. And in many rural communities, it is infrastructure for the community itself.
That’s a message worth sharing with federal regulators.
The deadline is October 13. Add your voice today!
