ICYMI: OCC follows Fed, FDIC in setting bank asset-size thresholds for CRA in 2022

The Office of the Comptroller of the Currency (OCC) in late December issued its revised asset-size thresholds for banks defined as “small” and “intermediate small” under regulations implementing the anti-redlining Community Reinvestment Act (CRA).

The new thresholds, noted in a Dec. 30 bulletin from the OCC, are the same as those announced two weeks earlier by the Federal Deposit Insurance Corp. (FDIC) and the Federal Reserve.

With the OCC’s changes, effective since Jan. 1 –

  • “Small bank or savings association” means an institution that, as of Dec. 31 of either of the prior two calendar years, had assets of less than $1.384 billion.
  • “Intermediate small bank or savings association” means a small institution with assets of at least $346 million as of Dec. 31 of both of the prior two calendar years and less than $1.384 billion as of Dec. 31 of either of the prior two calendar years.

Financial institutions are evaluated under different CRA examination procedures based upon their asset-size classification, regulators have noted. For example, banks meeting the small and intermediate small bank asset-size thresholds are not subject to the reporting requirements applicable to large banks unless they choose to be evaluated as a large bank, they said.

The asset-size thresholds were adjust up based on changes in the consumer price index.

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