Fed, FDIC raise asset-size thresholds for ‘small,’ ‘intermediate small’ banks for CRA exam purposes

The asset-size thresholds that determine what is a “small” or “intermediate small” bank for Community Reinvestment Act examination purposes will increase on Jan. 1 under action announced Thursday by the Federal Reserve and Federal Deposit Insurance Corp. (FDIC).

As of Jan. 1, a bank will be considered a small bank in 2021 if it had total assets of less than $1.322 billion as of Dec. 31 of either of the prior two calendar years, the agencies said. It will be considered an intermediate small bank if it had assets of at least $330 million but less than $1.322 billion as of Dec. 31 of either of the two prior calendar years.

The changes raise the upper and lower thresholds from this year’s $326 million and $1.305 billion, respectively.

Financial institutions are evaluated under different CRA examination procedures based upon their asset-size classification, and the asset-size thresholds are adjusted yearly. Those meeting the small and intermediate small institution asset-size thresholds, the agencies noted, are not subject to the reporting requirements applicable to large banks unless they choose to be evaluated as a large institution.

The action announced Thursday is 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. This index rose 1.29% for the period ending in November 2020.

Agencies release annual CRA asset-size threshold adjustments for small and intermediate small institutions

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