2018 CRA Threshold Update

Each year, the asset-size threshold under the Community Reinvestment Act (CRA) is updated based on inflation.  This threshold is important as it determines which CRA test a financial institution will have during their CRA exam.

For 2018, the following thresholds will apply:

  • Large Bank = assets of $1.252 billion or more for each of the prior two calendar years.
  • Intermediate Small Bank = assets of at least $313 million for both of the two prior calendar years but less than $1.252 billion for either of those same years.
  • Small Bank Test = assets of less than $1.252 billion for either of the prior two calendar years.

It should be noted that a bank can be both a small bank and an intermediate small bank.  This is important to understand when working on the required public file.  For example, the public file requires that all small banks include the loan to deposit ratios for each quarter of the prior year.  Based on the definition of a small bank - meaning all banks with assets under $1.252 billion - both small banks and intermediate small banks must comply with this rule.

If you have questions as to which CRA test will apply to your bank or credit union, feel free to contact us here.

2018 Threshold for Small Creditors

2018 HMDA Threshold Changes