New CRA asset-size thresholds for 2019 explained in OCC bulletin

Revised asset-size thresholds that help determine how banks will be evaluated for compliance with the Community Reinvestment Act (CRA) were detailed Monday in the first 2019 bulletin issued to national banks and federal savings banks by the Office of the Comptroller of the Currency (OCC).

The revised thresholds, announced by regulators Dec. 20 and published in the Dec. 27 Federal Register, went into effect Jan. 1.

Financial institutions, the bulletin notes, are evaluated under different CRA examination procedures based on their asset-size threshold amounts. Banks and savings associations meeting the “small” and “intermediate small” institution asset-size thresholds (which are also used by the Federal Deposit Insurance Corp. [FDIC] and the Federal Reserve) are not subject to the reporting requirements applicable to large banks and savings associations unless they choose to be evaluated as a large institution.

The rulemaking adjusts the threshold amounts based on the annual percentage change in a measure of the consumer price index.

The bulletin notes that beginning Jan. 1, 2019, a national bank or savings association that, as of Dec. 31 of either of the prior two calendar years, had assets of less than $1.284 billion is a “small bank” or “small savings association” under the CRA regulations. A small bank or small savings association 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 is an “intermediate small bank” or “intermediate small savings association” under the CRA regulations.

These amounts are up from the $1.252 billion and $313 billion thresholds, respectively, applied in 2018.

OCC Bulletin 2019-1

RR: CRA asset thresholds for small, intermediate small banks revised up for 2019(Dec. 20, 2018)

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