Compliance Bulletin

Federal Banking Agencies Expand Eligibility 18-Month Exam Cycle
April 25, 2016

The federal banking agencies (OCC, Federal Reserve Board, and the FDIC) jointly issued interim final rules under authority of section 83001 of the Fixing America’s Surface Transportation Act or FAST Act. Section 83001 raises the threshold for banks eligible for expanded examination cycles from $500 million to a new maximum of $1 billion in total assets. The bank has to be well capitalized and have a CAMELS composite rating of 1 or 2 and be well managed (Management rating of 1 or 2). Previously only composite rated 1 banks were eligible. Section 83001 also raised the asset threshold for smaller banks eligible for an 18-month examination cycle from $100 million to $200 million.  This threshold may be increased by the agencies to $1 billion. See CBA’s Regulatory Compliance Bulletin for more information.