OCC: Revision of Small and Intermediate Small Bank and Savings Association CRA Asset Thresholds

Summary

Today the Office of the Comptroller of the Currency (OCC) announces revisions to the asset-size threshold amounts used to define “small bank or savings association” and “intermediate small bank or savings association” under the Community Reinvestment Act (CRA) regulations. The thresholds—which apply to any national bank, federal savings association, or state savings association1 (collectively, bank)—become effective January 1, 2022. This bulletin adjusts the threshold amounts based on the annual percentage change in a measure of the consumer price index and updates the thresholds included in the OCC’s 2021 CRA final rule.2

Note for Community Banks

The bulletin applies to all national banks and federal savings associations subject to evaluation under the CRA.

Highlights

Beginning January 1, 2022, a bank that, as of December 31 of either of the prior two calendar years, had assets of less than $1.384 billion is a “small bank or savings association” under the CRA regulations. A “small bank or savings association” with assets of at least $346 million as of December 31 of both of the prior two calendar years and less than $1.384 billion as of December 31 of either of the prior two calendar years is an “intermediate small bank or savings association” under the CRA regulations.

Background

On June 5, 2020, the OCC issued a final rule that included revisions to asset thresholds (June 2020 rule). Accordingly, for calendar year 2021, the June 2020 rule defined a “small bank” as an institution with assets of $600 million or less in four of the previous five calendar quarters. An institution that exceeded the “small bank” threshold and had $2.5 billion or less in four of the previous five calendar quarters was an “intermediate bank” (12 CFR 25.03 (2020)).3

On December 15, 2021, the OCC published a final rule to rescind the June 2020 rule and replaced it with a rule based on those adopted jointly by the federal banking agencies in 1995, as amended (2021 final rule). This 2021 final rule becomes effective on January 1, 2022.

The 2021 final rule provides that banks are evaluated under different CRA examination procedures based on their asset-size threshold amounts. The OCC is required to publish annual adjustments to the asset-size thresholds based on the year-to-year change in the average of the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPI-W), not seasonally adjusted, for each 12-month period ending in November, with rounding to the nearest million (12 CFR 25.12(u)(2)). The 2021 final rule includes the asset-size thresholds issued by the Board of Governors of the Federal Reserve System and the Federal Deposit Insurance Corporation on December 17, 2020, effective January 1, 2021.4

During the period ending November 2021, the CPI-W increased by 4.73 percent. Because of the CPI-W increase and the issuance of the 2021 final rule, the OCC has adjusted the dollar thresholds detailed in 12 CFR 25.12(u)(1) to reflect the increased CPI-W. Beginning January 1, 2022, a bank that, as of December 31 of either of the prior two calendar years, had assets of less than $1.384 billion is a “small bank or savings association.” A “small bank or savings association” with assets of at least $346 million as of December 31 of both of the prior two calendar years and less than $1.384 billion as of December 31 of either of the prior two calendar years is an “intermediate small bank or savings association.”

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

Further Information

Please contact Emily Boyes, Counsel, Chief Counsel’s Office, at (202) 649-5490; Lauren Zelechowski, Counsel, Chief Counsel’s Office, at (312) 360-8800; or Vonda Eanes, Director for CRA and Fair Lending Policy, Compliance Risk Policy Division, at (202) 649-5470.

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