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ABA: The American Bankers Association
Regulatory Proposal

OCC, Board, FDIC: Request for Comments on Final Rule Implementing Extended Exam Cycle for More Banks

Published Proposal: August 28, 2018 Comments Due: October 28, 2018 Disposition: Filed

ABA Comments & Analysis

Summary of the Proposal

Implementing a provision in the S. 2155 regulatory reform bill, the federal banking agencies issued joint interim final rules that make qualifying banks with up to $3 billion in assets eligible for an 18-month on-site exam cycle. Prior to S. 2155's passage, only banks with under $1 billion in assets were eligible.

Under the final rules, insured depository institutions, including federal or state branches of foreign banks, qualify if they have an "outstanding" or "good" composite rating. "The agencies believe that extending the examination cycle from 12 months to 18 months for these small IDIs with relatively simple risk profiles should not appreciably increase their risk of financial deterioration or failure," they said. ABA has long advocated for raising the threshold of institutions eligible for an extended exam cycle. 

Agency Material

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