Agencies Release Annual CRA Asset-Size Threshold Adjustments for Small and Intermediate Small Institutions
December 29, 2016, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency announced the annual adjustment to the asset-size thresholds used to define Small Bank, Small Savings Association, Intermediate Small Bank, and Intermediate Small Savings Association under the Community Reinvestment Act (CRA). CRA regulations require annual adjustments and financial institutions are evaluated under different CRA examination procedures based upon their asset-size classification.
Those meeting the small and intermediate small institution asset-size thresholds are not subject to the reporting requirements applicable to large banks and savings associations 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), not seasonally adjusted, for each 12-month period ending in November, with rounding to the nearest million.
As a result of the 0.84 percent increase in the CPI-W for the period ending in November 2016, the definitions of small and intermediate small institutions for CRA examinations will change as follows:
- “Small bank” or “small savings association” means an institution that, as of December 31 of either of the prior two calendar years, had assets of less than $1.226 billion.
- “Intermediate small bank” or “intermediate small savings association” means a small institution with assets of at least $307 million as of December 31 of both of the prior two calendar years and less than $1.226 billion as of December 31 of either of the prior two calendar years.
These asset-size threshold adjustments are effective upon publication in the Federal Register. In addition, the agencies will post a list of the current and historical asset-size thresholds on the website of the Federal Financial Institutions Examination Council http://www.ffiec.gov/cra
Anna DeSimone founded Bankers Advisory in 1986 and is a nationally recognized authority in residential mortgage lending. She has received numerous industry awards and has authored more than 40 best practices guides and hundreds of articles.
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