FDIC Proposes to Increase Extensions of Credit to Insiders

On July 31, 2026, the FDIC issued a proposed rule that would adjust certain lending thresholds for executive officers and other insiders of FDIC-supervised institutions. Federal laws currently set strict parameters for lending to these individuals and their related interests at FDIC-supervised institutions.

According to the FDIC, the proposed rule would raise and index certain dollar-based thresholds to align the thresholds with those proposed by the Board of Governors of the Federal Reserve under Regulation O. Specifically, the proposed rule would:

  • Increase the maximum amount of credit that an FDIC-supervised institution may extend to one of its executive officers, for purposes other than those specifically authorized by statute, from $100,000 to $400,000; 

  • Increase the maximum amount of credit that an FDIC-supervised institution may extend to one of its insiders, with any aggregate lending beyond this limit requiring approval by the board of directors, from $500,000 to $2,000,000;

  • Establish an indexing methodology to automatically adjust such thresholds every five years to reflect the cumulative change in economic growth and inflation since the prior adjustment; and

  • Simplify the method for determining the lending limit applicable to a given institution.

The FDIC stated that updating these thresholds will reduce burden on FDIC-supervised institutions, as the thresholds have become steadily more restrictive over time. In addition, the FDIC said that the changes will standardize compliance and avoid disparate treatment between FDIC-supervised institutions and other insured depository institutions. 

Read the FDIC’s press release here.

The proposed rule can be found here.

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