Federal Bank Regulatory Agencies Release CRA Asset-Size Thresholds for Small and Intermediate Small Institutions

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On December 22, 2015, the Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation and Office of the Comptroller of the Currency (collectively, Agencies) announced the annual adjustment to the asset-size thresholds used to define small bank, small savings association, intermediate small bank and intermediate small savings association under the Community Reinvestment Act (CRA) regulations. Financial institutions are evaluated under different CRA examination procedures based upon their asset-size classification. Those meeting the small and intermediate small institution asset-size thresholds are not subject to the reporting requirements applicable to large banks and savings associations.

The definitions of small and intermediate small institutions for CRA examinations will change as follows:

  • “small bank” or “small savings association” means an institution that, as of December 31 of either of the prior two calendar years, had assets of less than $1.216 billion; and
  • “intermediate small bank” or “intermediate small savings association” means a small institution with assets of at least $304 million as of December 31 of both of the prior two calendar years, and less than $1.216 billion as of December 31 of either of the prior two calendar years.

These asset-size threshold adjustments were effective January 1.

In addition, the Agencies are making technical edits to 12 CFR 25.42, 228.42, and 345.42 to remove obsolete references to the Office of Thrift Supervision and to 12 CFR 563e in the CRA rules. Finally, the Agencies are updating the citations in the CRA regulations to reference Regulation C and Regulation Z, located at 12 CFR 1003 and 12 CFR 1026, respectively.

Read the press release here.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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