Banking

The Federal Reserve Board and other federal bank regulators recently announced changes to the asset-size thresholds used to define "small" and "intermediate small" financial institutions under the Community Reinvestment Act (CRA).

The thresholds are updated annually pursuant to CRA rules and are based on changes to the consumer price index (CPI) for urban wage earners and clerical workers. The CPI for the 12 months ending November 2012 was 2.23 percent.

Banks are subject to different CRA exam procedures based upon their asset-size classification. Small and small intermediate institutions do not have to fulfill the same reporting requirements as large banks.

The new thresholds, which became effective January 1, 2013, are as follows:

• A "small bank" or "small savings association" had less than $1.186 billion in assets as of December 31 of either of the prior two calendar years.
• An "intermediate small bank" or "intermediate small savings association" had assets of at least $296 million as of December 31 of both of the prior two calendar years, and less than $1.186 billion on December 31 of either of the prior two calendar years.

The updates are published in the Federal Register, and a list of the current and historical asset-size thresholds is available on the Federal Financial Institutions Examination Council website. The Federal Deposit Insurance Corporation and Office of the Comptroller of the Currency issued the adjusted thresholds in conjunction with the Federal Reserve.

January 23, 2013