ARTICLE
6 February 2017

US Federal Banking Agencies Release Annual Community Reinvestment Act Asset-Size Threshold Adjustments For Small And Intermediate Small Institutions

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A&O Shearman

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On December 29, 2016, the US Federal Reserve Board, the OCC and the Federal Deposit Insurance Corporation 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.
United States Finance and Banking

On December 29, 2016, the US Federal Reserve Board, the OCC and the Federal Deposit Insurance Corporation 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. The annual adjustments are required by the CRA rules. 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 unless they choose to be evaluated as a large institution. As a result of the adjustments, the definitions of small and intermediate small institutions for CRA examinations will change as follows:

  1. "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 $1.226 billion.
  2. "Intermediate small bank" or "intermediate small savings association" means a small institution with assets of at least $307 million as of December 31 of both of the prior two calendar years and less than $1.226 billion as of December 31 of either of the prior two calendar years.

These asset-size threshold adjustments are effective upon publication in the Federal Register. The joint final rule is available at: https://www.fdic.gov/news/news/press/2016/pr16111a.pdf.

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