As stated in the Office of the Comptroller of the Currency press release, those that meet 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 opt to be evaluated as a large institution.

On December 29, 2016, the federal bank regulatory agencies 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) regulations, which are required by the CRA rules. Financial institutions are evaluated under different CRA examination procedures based on their asset-size classification.

As stated in the Office of the Comptroller of the Currency press release, those that meet 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 opt to be evaluated as a large institution. Meanwhile, 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. Due to 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” refers to 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.

The asset-size threshold adjustments are effective upon publication in the Federal Register, and the federal bank regulatory agencies will post the current and historical asset-size thresholds on the Federal Financial Institutions Examination Council website.

For Further Information

If you have any questions about this Alert, please contact Mark D. Belongia, any of the attorneys in the Bank and Financial Institution Representation Practice Group or the attorney in the firm with whom you are regularly in contact.

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