Is the U.S. Military an LMI Community for CRA?

The GoVA Foundation is a 501(c)(3) non-profit with a creative way to empower the military community through financial education, while helping banks earn CRA consideration during their evaluations. The Foundation offers scholarships that connect military members with free access to high-quality, certified courses on a broad range of financial literacy topics. Banks can sponsor these scholarships, which supports the military community and helps banks earn CRA consideration. 

The Community Reinvestment Act (CRA) is a government initiative encouraging banks to serve all communities in their banking footprint and to donate or make improvements to the Lower-Moderate Income (LMI) areas they serve. In return for community investment and service, banks are evaluated by the regulatory agencies. There is no across-the-board three-year cycle. Frequency depends on size and rating: under the Gramm-Leach-Bliley Act, a bank with $250 million or less in assets rated Satisfactory may be examined no more often than every 48 months, and one rated Outstanding no more often than every 60 months. Through this process, banks earn consideration for qualifying activities, which is important to a bank’s overall performance evaluation.

Which CRA rules apply, as of August 2026. Banks are evaluated under the 1995 CRA regulations, reinstated by the OCC in 2021. The agencies adopted a modernized final rule in October 2023, but a federal court enjoined it in March 2024 and it has never taken effect. The FDIC and OCC issued a proposal to amend the 1995 framework on July 31, 2026, which is pending. 

The military is an often-overlooked part of the LMI community. The GoVA Foundation focuses on the military community by offering free scholarships for financial resources to service members, Veterans, and their spouses. When banks sponsor these scholarships, they serve the needs of the military community, while qualifying for CRA consideration. 

Is the U.S. military an LMI community for CRA? 

The military community is diverse, especially when including Veterans and spouses. While 1% of all American adults are currently serving in active-duty military jobs, around 7% of all living Americans served at one point. Including their spouses, the military community comprises 10% of the entire population.  

Not every service member or Veteran will qualify as an LMI category, but large portions of the military community can be defined as LMI either because of their gross household income, or because they live in an LMI census tract. Military families do not get to choose where they are stationed, and military base pay is based on rank, not geographic location. Families sent to a high cost-of-living location will have fewer affordable choices for housing, childcare, groceries, and other essentials.  

Younger enlisted service members, in particular, are likely to qualify as LMI: 

• About 49% of active-duty enlisted members are 25 years of age or younger, per the 2023 Demographics Profile of the Military Community from DoD Military Community and Family Policy (Exhibit 2.43, September 2023 data) 
• The four lowest paygrades (E-1 to E-4) account for 527,621 of 1,038,909 active-duty enlisted members, just over half (Exhibit 2.04, same report) 
• Due to frequent moves and job changes, the unemployment rate for military spouses was 20% in the 2024 Survey of Active Duty Spouses, several times the civilian rate  
• 25% of the military population experienced food insecurity in 2018 and 2020, according to the USDA Economic Research Service, against 10% of a demographically equivalent civilian population 
• About 5% of infants and children eligible for WIC (Women, Infants, and Children) in 2021 lived with a family member who had ever served in the U.S. Armed Forces 

In its 2025 Military Family 360 Survey, the Military Family Advisory Network classified 10,089 respondents against 2025 HUD income limits using reported household income, family size, and location. Among currently serving military families, 27.1% fell into the low, very low, or extremely low income categories. Among enlisted families that figure was 34.1%, and among junior enlisted families (E-1 to E-3) it was 57.2%.

MFAN used convenience sampling and states that its findings represent the experiences of survey respondents rather than a generalizable estimate of the military population.

Clearly, there are large portions of the military community who qualify as LMI and would benefit from additional outreach or community programs. Service members and Veterans live in every state, plus U.S. territories. Thanks to GoVA’s digital membership platform, banks can now serve this portion of the LMI population directly, focusing on those within their assessment areas. 

How GoVA partners with banks to serve LMI military members 

In March 2024, the Office of the Comptroller of the Currency’s Community Affairs team provided GoVA with CRA training and technical assistance. GoVA has co-hosted financial education events with the OCC, FDIC, and Federal Reserve, and has participated as a guest at two FTC events. GoVA is a partner in the BBB Institute for Marketplace Trust program.

This does not constitute endorsement or approval of GoVA by any federal agency.

The GoVA Foundation runs a 3-part community outreach program that supports the LMI members of the military community. Banks can support any portion of this program to earn CRA consideration during their evaluations.

1. The Edge: financial literacy for the military community

Designed to equip service members, Veterans, and spouses with essential financial tools, GoVA’s digital membership platform, The Edge, offers free access to a range of financial resources. From credit counseling to budgeting tools and insights into financial products like mortgages, The Edge covers a variety of topics for sound financial decision-making. 

By sponsoring scholarships to The Edge, banks fund financial education for military families in the communities they serve. Members use the tools and courses on their own terms, at their own pace, and for their own goals. That activity is documented on the GoVA platform and reported to the sponsoring bank as community development service.  

A sponsored scholarship gives a military-affiliated member unlimited access to The Edge for one year, including every financial tool and course on the platform. Scholarships are funded through the GoVA Foundation, which sets current pricing and can scope a package to the assessment areas a bank needs to reach. 

2. Homeownership Assistance

The GoVA Foundation supports military members navigating the complexities of homeownership. By familiarizing military families with VA Loan benefits and providing personalized education, the Foundation helps them see that homeownership is attainable and understand what it takes to get there. 

Banks can partner on this initiative by offering closing cost assistance programs for VA Loan applicants in low- to moderate-income (LMI) communities. GoVA does not route, refer, flag, rank, or hand off members to any bank. Members decide for themselves whether and where to apply, and a bank’s assistance program is simply available to those who qualify.

3. Volunteering for Digital Literacy

Banks can empower their communities and earn CRA consideration through volunteer initiatives. The Foundation collaborates with numerous non-profits and community partners on projects that support the military community. By engaging bank employees in their area of expertise for financial education or training, banks can earn CRA consideration while reinforcing their commitment to improving the community. 

LMI impact reporting on CRA military programs 

To assist banks with preparing for CRA examinations, the GoVA platform produces quarterly data and reports detailing the project’s impact on LMI individuals.  

Data is gathered from scholarship users through a combination of tracking and reporting strategies, including:  

• Automatic data tracking showing the courses and tools scholarship users engage with on The Edge  
• Aggregated reports on credit scores, financial stress, and credit card debt  
• Mandatory sign-up data that captures user address and county for census tract documentation  
• Personal outreach to gather household income and additional metrics as required   

The following LMI reporting metrics are available on a quarterly basis:  

• Number of new members using the scholarships who are part of the LMI community and tied to the military   
• Total number of users registered for the scholarships through each bank 
• Scholarship user data about geographic location and census tract  
• Metrics on member improvements after participating in The Edge platform, such as increased credit scores, decreased financial stress, and reduction of credit card debt  

Additional reporting data can be discussed, based on each bank’s CRA evaluations.   

GoVA Foundation is seeking a Community Reinvestment Act (CRA) investments from bank partners to support our Military Community Empowerment Project, providing scholarships for low-to-moderate income (LMI) individuals from the military community to access digital financial literacy programs, and Homeowner Assistance Initiatives for LMI applicants seeking a VA Loan.    

The project allows banks to fund financial education for the military portion of the LMI communities inside their assessment areas. Funding financial literacy and homeownership readiness for military families is community development activity, and GoVA supplies the quarterly reporting a bank needs to present it at examination.   

To learn more about this program, visit GoVAFoundation.org or contact us at info@govafoundation.org.