CRA threshold increases to $1.2 billion

“Small banks” are defined as those with assets of less than $1.226 billion, and “intermediate small banks” (or savings associations) are defined as those with assets of at least $307 and less than $1.226 billion, according to revised Community Reinvestment Act (CRA) thresholds issued today by federal bank regulatory agencies.

The Federal Deposit Insurance Corporation (FDIC), Federal Reserve and the Office of the Comptroller of the Currency (OCC) issued the new threshold in a joint release.

Financial institutions meeting the small- and intermediate-small institution asset-size thresholds are not subject to CRA reporting requirements applicable to large banks and savings associations unless they choose to be evaluated as a large institution, according to the joint release.

Annual adjustments to the CRA asset-size thresholds is required under rules governing CRA, an “anti-redlining” law for mortgage lending. According to the FDIC, annual adjustments to the asset-size thresholds are based on the change in the average of the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPI-W), not seasonally adjusted, for each 12-month period ending in November, with rounding to the nearest million. For the period ending November, 2016, the CPi-W increase was 0.84%.

The “small bank” threshold means an institution that, as of Dec. 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 Dec. 31 of both prior two calendar years and less than $1.226 billion as of Dec. 31 of either of the prior two calendar years.

The asset-size threshold adjustments are effective upon publication in the Federal Register.