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Financial Services Law Insights and Observations

OCC announces adoption of 18-month examination cycle final rule

Agency Rule-Making & Guidance Federal Reserve FDIC OCC EGRRCPA Examination

Agency Rule-Making & Guidance

On January 17, the OCC announced, together with the Federal Reserve Board and the FDIC, the final rule amending regulations governing eligibility for the 18-month on-site examination cycle, pursuant to the Economic Growth, Regulatory Relief, and Consumer Protection Act. The final rule was published without change from the interim rule issued in August 2018 (covered by InfoBytes here). The final rule allows for qualifying insured depository institutions with less than $3 billion in total assets (which is an increase from the previous threshold of $1 billion) to be eligible for an 18-month on-site examination cycle. The agencies reserve the right to adopt a more frequent schedule than 18 months for qualifying institutions if deemed “necessary or appropriate.” The final rule is effective January 28.