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OCC BULLETIN 2015-10
To: Chief Executive Officers of National Banks and Federal Savings Associations, All Department and Division Heads, All Examining Personnel, and Other Interested Parties

Description: Regulatory Revision of Small and Intermediate Small Bank and Savings Association Asset Thresholds

Summary

On December 29, 2014, the Office of the Comptroller of the Currency (OCC) published in the Federal Register revisions to its Community Reinvestment Act (CRA) regulations that became effective January 1, 2015. The revisions adjust the asset-size thresholds used to define “small bank,” “small savings association,” “intermediate small bank,” and “intermediate small savings association.” The rulemaking adjusts the threshold amount based on the annual percentage change in a measure of the consumer price index. Financial institutions are evaluated under different CRA examination procedures based upon their asset-size classification. Those meeting the small and intermediate small asset-size threshold are not subject to the reporting requirements applicable to large national banks and savings associations.

Note for Community Banks

A national bank or savings association with assets of between $300 million and $305 million as of December 31, 2013, and December 31, 2014, or between $1.202 billion and $1.221 billion as of either of those dates, should review the revisions to asset thresholds described in this bulletin to determine whether its CRA performance evaluation criteria have changed.

Highlights

Beginning January 1, 2015, a national bank or savings association that, as of December 31 of either of the prior two calendar years, had assets of less than $1.221 billion is a “small bank” or “small savings association.” A small bank or small savings association with assets of at least $305 million as of December 31 of both of the prior two calendar years and less than $1.221 billion as of December 31 of either of the prior two calendar years is an “intermediate small bank” or “intermediate small savings association.”

Background

For calendar year 2014, the OCC’s CRA regulations defined a national bank as a “small bank” and a savings association as a “small savings association” if, as of December 31 of either of the prior two calendar years, the institution had assets of less than $1.202 billion. A small bank or small savings association with assets of at least $300 million as of December 31 of both of the prior two calendar years and less than $1.202 billion as of December 31 of either of the prior two calendar years was an “intermediate small bank” or “intermediate small savings association” (12 CFR 25.12(u)(1), 12 CFR 195.12(u)(1)). The regulations provide that the OCC will publish annual adjustments to these dollar figures based on the year-to-year change in the average of the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPIW), not seasonally adjusted, for each 12-month period ending in November, with rounding to the nearest million (12 CFR 25.12(u)(2), 12 CFR 195.12(u)(2)).

During the period ending November 2014, the CPIW increased by 1.60 percent. As a result, the OCC has revised the dollar thresholds detailed in 12 CFR 25.12(u)(1) and 12 CFR 195.12(u)(1) to reflect the increased CPIW. Beginning January 1, 2015, a national bank or savings association that, as of December 31 of either of the prior two calendar years, had assets of less than $1.221 billion is a “small bank” or “small savings association.” A small bank or small savings association with assets of at least $305 million as of December 31 of both of the prior two calendar years and less than $1.221 billion as of December 31 of either of the prior two calendar years is an “intermediate small bank” or “intermediate small savings association.”

For further information about how these revised asset-size thresholds are applied, see the CRA page on the Federal Financial Institutions Examination Council’s Web site.

Further Information

Please contact Margaret Hesse, Senior Counsel, Community and Consumer Law, at (202) 649-6350; Rima Kundnani, Attorney, Legislative and Regulatory Activities Division, at (202) 649-5490; or Bobbie Kennedy, Bank Examiner, Compliance Policy Division, at (202) 649-5470.

 

Amy S. Friend
Senior Deputy Comptroller and Chief Counsel

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