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Financial Services Law Insights and Observations

Agencies release annual CRA asset-size threshold adjustments

Bank Regulatory Federal Issues Agency Rule-Making & Guidance CRA FDIC Federal Reserve Supervision

On December 19, the Federal Reserve Board, FDIC, and OCC announced (see here and here) joint annual adjustments to the CRA asset-size thresholds used to define “small bank” and “intermediate small bank,” which are not subject to the reporting requirements applicable to large banks unless they choose to be evaluated as one. A “small bank” is defined as an institution that, as of December 31 of either of the prior two calendar years, had less than $1.503 billion in assets. An “intermediate small” bank is defined as an institution that, as of December 31 of both of the prior two calendar years, had at least $376 million in assets, and as of December 31 of either of the past two calendar years, had less than $1.503 billion in assets. The joint final rule takes effect on January 1, 2023.