Slightly higher 2020 CRA exam thresholds for smaller institutions adopted by agencies

New asset-size thresholds used to define small- and intermediate small-sized banks and savings institutions under anti-redlining rules take effect Wednesday, the first day of 2020, the federal banking agencies said Monday.

According to a Federal Register notice published by the Federal Deposit Insurance Corp. (FDIC), the Federal Reserve and the Office of the Comptroller of the Currency (OCC), the threshold for small banks and savings institutions will be $1.305 billion; institutions with assets of between $326 million and less than $1.305 billion will be considered intermediate small-sized institutions.

Under the agencies’ respective regulations implementing the Community Reinvestment Act (CRA), the adjustment to the threshold amount is based on the annual percentage change in the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPI-W). Banks and savings institutions falling under the thresholds must have had assets at those levels for either of the prior two calendar years.

Financial institutions are evaluated under different CRA examination procedures based upon their asset-size classification under the agencies’ rules. 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 2020 thresholds are up slightly from 2019, when the thresholds were $1.284 billion and between $321 million and less than $1.284 billion, respectively, for small and intermediate-small financial institutions.

Final rule: 2020 Community Reinvestment Act thresholds