January 1st is a day when a lot of changes become effective in the compliance world. New year, new rules. The regulatory agencies recently announced the asset-size thresholds for CRA was adjusted and will become effective January 1, 2013.
These thresholds determine whether an institution is classified as a small bank, intermediate-small bank or large bank for CRA purposes. For either of the prior two calendar year-ends (December 31, 2012 & December 31, 2011):
- A “small bank” or “small savings association” means assets less than $1.186 billion.
- An “intermediate small bank” or “intermediate small savings association” means assets of at least $296 million but less than $1.186 billion.
- A “large bank” or “large savings association” means assets of $1.186 billion or more.
We’ve never understood why these definitions have to be so confusing. Here’s a much easier way to explain it:
|If a bank. . . .||Then it is. . . .|
|has assets under $296 million||a Small Bank|
|has assets of $296 million but less than $1.186 billion||an Intermediate Small Bank|
|has assets of $1.186 billion or more||a Large Bank|