The FDIC revised its Consumer Compliance Examination Manual to lengthen the exam schedule and Community Reinvestment Act (CRA) evaluations for many institutions. Absent some regulatory concern, those institutions will face fewer FDIC exams and CRA evaluations.
NEW Examination Schedule
- If a financial institution has less than $350 million in total assets, the longest new examination and CRA evaluation cycle will be 66-78 months not the previous 60-72 months.
- If a financial institution has between $350 million and $3 billion in total assets, the longest new examination and CRA evaluation cycle will be 54-66 months not the previous 24-26 months.
- If a financial institution has more than $3 billion in total assets, the longest new examination and CRA evaluation cycle will still be 24-36.
Impact of Consumer Compliance Ratings and CRA Evaluations
Banks with lower scores will be subject to more frequent exams and evaluations, which, depending on scores and the particular bank, may be as often as monthly to every 12 months.
Other Possible Reviews
For institutions with $3 billion or less in total assets which do not require additional exams or evaluations, the FDIC will conduct a mid-point analysis of the institution to determine if an “intervening supervisory activity”, such as a targeted visitation from the FDIC, is needed.
