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WBK Industry News - Federal Regulatory Developments

Community Reinvestment Act Threshold Limits Adjusted

The federal bank regulatory agencies have announced updated annual threshold amounts used to define regulated institutions under the Community Reinvestment Act (CRA).

These threshold amounts are tied to annual changes in the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPI-W).

Institutions that meet the definition of small bank, small savings association, intermediate small bank, or intermediate small savings association—the thresholds for each of which were adjusted—are not subject to the more rigorous reporting and testing requirements applicable to large banks and savings associations.

The new threshold limits took effect on January 1, 2018, and represent an increase of 2.11 percent over last year’s announced thresholds, as follows:

  • “Small banks” or “small savings associations” are institutions that, as of December 31 of either of the prior two calendar years, had assets of less than $1.252 billion.
  • “Intermediate small banks” or “intermediate small savings associations” are small institutions that had assets of at least $313 million as of December 31 of both of the prior two calendar years and less than $1.252 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 an institution chooses to be evaluated as a large institution.

The FDIC announcement can be found here: https://www.fdic.gov/news/news/press/2017/pr17100.html.

The 2018 CRA Asset Threshold Federal Register Notice can be found here: https://www.fdic.gov/news/news/press/2017/pr17100a.pdf.