Agencies raise exam threshold to $6 billion for small banks

The Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System and the Federal Deposit Insurance Corporation issued a joint interim final rule effective September 14, 2026. The rule expands the 18-month on-site examination cycle to qualified insured depository institutions (IDIs) with total assets of less than $6 billion and to U.S. branches and agencies of foreign banks, aligning the schedule with the International Banking Act of 1978.

The authority for the change derives from section 903 of the 21st Century ROAD to Housing Act, enacted July 11, 2026. That statute amended section 10(d) of the Federal Deposit Insurance Act to raise the asset threshold from $3 billion to $6 billion, allowing qualifying IDIs to be examined not less than once during each 18-month period instead of annually.

Public comments must be received by October 14, 2026. Submissions for the OCC should reference Docket ID OCC-2026-0761 and may be filed through Regulations.gov or mailed to the Chief Counsel's Office, 400 7th Street SW, Suite 1E-216, Washington, DC 20219. Comments for the Board should cite Docket No. R-1898 and may be submitted via the Board's proposal portal or mail to Benjamin W. McDonough, Secretary, Board of Governors, 20th Street and Constitution Avenue NW, Washington, DC 20551. FDIC comments should reference RIN 3064-AG33 and can be sent to Jennifer M. Jones, Deputy Executive Secretary, 550 17th Street NW, Washington, DC 20429.

The interim final rule also makes parallel adjustments to the Agencies' regulations governing the examination cycle for U.S. branches and agencies of foreign banks, ensuring consistency with the International Banking Act of 1978. All comments become part of the public record and will be posted without alteration, subject to standard disclosure requirements.