FDIC proposes higher insider credit limits for state nonmember banks
The proposal would raise insider credit thresholds for FDIC-supervised state nonmember banks, foreign insured branches and state savings associations, with comments due by Oct. 5 2026.
The Federal Deposit Insurance Corporation is proposing to increase the quantitative thresholds that limit extensions of credit to insiders of FDIC-supervised institutions. The limit for extensions to executive officers not otherwise specifically authorized by statute would rise from $100,000 to $400,000, and the limit for extensions that require prior board approval would increase from $500,000 to $2,000,000. The rule also would establish an indexing methodology to adjust the thresholds periodically.
The rule applies to institutions for which the FDIC is the appropriate Federal banking agency: any State nonmember insured bank, any foreign bank with an insured branch, and any State savings association, as defined in 12 U.S.C. 1813(q)(2) and related provisions.
Comments on the proposal must be submitted on or before October 5, 2026. Submissions may be made through the FDIC website, by email, or by mail to Jennifer M. Jones, Deputy Executive Secretary, at the address listed in the notice. The proposal is identified by RIN 3064-AG26 and appears in the Federal Register as FR Doc No. 2026-15995, Vol. 91, No. 150, page 50730-50738.
The authority for the rule derives from Sections 22(g) and (h) of the Federal Reserve Act, which the FDIC implements through 12 CFR Part 337. The existing regulation requires banks to maintain procedures and records for insider transactions that exceed specified dollar amounts, and the proposed changes would raise those amounts to reflect contemporary banking practices.