18-month bank exam threshold raised to $6 billion
FED News

18-month bank exam threshold raised to $6 billion

Federal banking regulators have raised the asset threshold for qualifying community banks to receive 18-month on-site examination cycles from $3 billion to $6 billion. The joint interim final rule takes effect immediately, with public comments open for 30 days.

Relief for 207 institutions

Under the joint interim final rule issued by the Federal Reserve, the OCC, and the FDIC, qualifying institutions with less than $6 billion in total assets may undergo full-scope on-site examinations every 18 months rather than annually.

The rule implements Section 903 of the 21st Century ROAD to Housing Act, raising the prior $3 billion limit.

Eligibility requires institutions to be well capitalized, well managed with an outstanding or good composite CAMELS condition, and free of formal enforcement proceedings or recent ownership changes.

The regulators estimate the expansion adds 188 domestic banks and savings associations alongside 19 foreign banking offices, expanding total eligibility to 4,016 institutions.

Balancing burden and supervisory risk

The agencies concluded that extending exam cycles for well-rated institutions with simple profiles does not appreciably increase failure risks.

Regulators will maintain continuous off-site surveillance, including quarterly Call Report analyses, and preserve discretionary authority to conduct on-site reviews whenever conditions warrant.

The interim final rule took effect without prior notice under Administrative Procedure Act exemptions, while establishing a 30-day public comment window.

Sensible relief with minimal downside

Raising the threshold delivers practical compliance relief to 207 well-run lenders without compromising stability.

Robust off-site monitoring ensures that supervisory blind spots remain minimal during the longer intervals.

This targeted adjustment allows regulators to focus examiner hours on higher-risk institutions.

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