OCC/Fed/FDIC Raise Asset Threshold for 18-Month Exam Cycle to $6 Billion
An interim final rule from the OCC, Federal Reserve, and FDIC raises the total asset threshold that allows certain well-managed, well-capitalized insured depository institutions and U.S. branches of foreign banks to qualify for an extended 18-month on-site examination cycle. Smaller banks and trust companies that fall below the new threshold may see reduced examination frequency, affecting the pace of supervisory feedback on compliance programs. Fintech-partnered banks and crypto-custody trust companies under the threshold should be aware that less frequent exams do not reduce compliance obligations.
What to do
- Determine whether your institution falls below the new asset threshold, and if so, maintain robust internal audit and compliance monitoring cadences to compensate for potentially longer gaps between on-site regulatory examinations.
Who this affects
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Source
Read the official publicationThis radar entry is educational and does not constitute legal advice. Summaries are AI-assisted and grounded in the linked official source; always verify against the primary source and consult qualified legal counsel for jurisdiction-specific guidance.