Agencies set slightly higher CRA thresholds for 2018

A “small bank” is one with assets of less than $1.252 billion, and an “intermediate small bank” is one with at least $313 million in assets but less than $1.252 billion, for purposes of community reinvestment rules, the three federal bank regulatory agencies said Thursday.

In announcing the annual asset-size threshold adjustments for Community Reinvestment Act (CRA) regulations, the Federal Reserve, Federal Deposit Insurance Corp. (FDIC) and the Office of the Comptroller of the Currency (OCC) said the adjusted thresholds are effective Jan. 1.

In a joint release, the agencies noted that 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 large institutions.

The thresholds apply to the asset levels of both banks and savings institutions as of Dec. 31 of either of the prior two calendar years.

According to the agencies, the adjustments 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, rounded to the nearest million.

The 2018 thresholds are up slightly from 2017 levels, when “small banks” were defined as those with assets of less than $1.226 billion, and “intermediate small banks” (or savings associations) were defined as those with assets of at least $307 and less than $1.226 billion.

Joint Release/Agencies Release Annual CRA Asset-Size Threshold Adjustments for Small and Intermediate Small Institutions

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