Community Reinvestment Act Threshold Limits Adjusted

On December 29, 2016, the federal bank regulatory agencies announced the updated annual threshold amounts for various terms to be used under the Community Reinvestment Act (“CRA”). Updated threshold limits were announced for the following terms: “small bank”; “small savings association”; “intermediate small bank”; and “intermediate small savings association.” The updated threshold limits are important because institutions which meet the definition of small bank, small savings association, intermediate small bank, or intermediate small savings association are not subject to the more rigorous reporting and testing requirements applicable to large banks and savings associations.

The new threshold limits were announced 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 $1.226 billion.

• “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.

Institutions falling within the above asset threshold limits are not subject to the reporting requirements applicable to large banks and savings associations, unless the institution chooses to be evaluated as a large institution. The new threshold limits will go into effect once they are published in the Federal Register.