EXTENDED EXAMINATION CYCLE

On August 23, 2018 the Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (the agencies) issued interim final rules to allow qualifying insured depository institutions (generally those that are well capitalized and well managed) with less than $3 billion in total assets to benefit from an extended 18-month on-site examination cycle (up from the previous 12-month cycle).

Prior to enactment of the EGRRCPA, only qualifying insured depository institutions with less than $1 billion in total assets were eligible for an 18-month examination cycle. The agencies estimate that the interim final rules will increase the number of banks and savings associations that may qualify for an extended 18-month examination cycle by approximately 420 (227 of which are supervised by the FDIC, 100 by the OCC, and 93 by the Board), bringing the total number to 4,798 banks and savings associations.

The overburdened agencies have reportedly “jumped the gun” by contacting some financial institutions, immediately after enactment of EGRRCPA, and pushing back planned examination dates.

The interim final rule is effective immediately upon publication in the Federal Register, which is expected soon.

A copy of the interim final rule is available at:  https://www.federalreserve.gov/newsevents/pressreleases/files/bcreg20180823a1.pdf

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