CRA asset thresholds for small, intermediate small banks revised up for 2019

Asset-size thresholds used to define “small” and “intermediate small” banking institutions for Community Reinvestment Act (CRA) requirements are rising $32 million and $8 million Jan. 1 based on growth in the consumer price index over the past year, the three federal banking agencies said Thursday.

The increases, announced by the Federal Reserve Board, Federal Deposit Insurance Corp. (FDIC), and Office of the Comptroller of the Currency (OCC), are due to a required annual adjustment based on the average of the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPI-W), not seasonally adjusted, for the 12-month period ending in November.

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 2.59% increase in the CPI-W for the period ending in November 2018, the definitions of small and intermediate small institutions for CRA examinations will change as follows:

  • “Small bank” or “small savings association” means an institution that, as of Dec. 31 of either of the prior two calendar years, had assets of less than $1.284 billion.
  • “Intermediate small bank” or “intermediate small savings association” means a small institution with assets of at least $321 million as of Dec. 31 of both of the prior two calendar years and less than $1.284 billion as of Dec. 31 of either of the prior two calendar years.

Joint Final Rule; Technical Amendment (Federal Register notice)

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