CRA Small Bank Thresholds Announced by FDIC & Federal Reserve

On 12/17/2020, the FDIC and Federal Reserve Board jointly announced the annual adjustment to the asset-size thresholds used to define small bank and intermediate small bank under their Community Reinvestment Act (CRA) regulations.

These annual adjustments are required by the agencies’ CRA rules, but don’t apply to OCC regulated banks - due to the OCC issuing new rules in 2020. FDIC and Federal Reserve-regulated institutions are evaluated under different CRA examination procedures based upon their asset-size classification. Institutions meeting the small and intermediate small institution asset-size thresholds are not subject to the reporting requirements applicable to large banks unless they choose to be evaluated as a large institution.

Annual adjustments to these asset-size thresholds are based on the change in the average of the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPI-W), which saw a 1.29 percent increase for the period ending in November 2020. Therefore, the definitions of small and intermediate small institutions for CRA examinations will change as follows:

  • “Small bank” means an institution that, as of December 31 of either of the prior two calendar years, had assets of less than $1.322 billion.

  • “Intermediate small bank” means a small institution with assets of at least $330 million as of December 31 of both of the prior two calendar years and less than $1.322 billion as of December 31 of either of the prior two calendar years.

These asset-size threshold adjustments are effective January 1, 2021. 

The joint final rule can be found here.

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