ARTICLE
10 September 2018

Regulators Expand Eligibility for Extended On-Site Examination Cycle

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Cadwalader, Wickersham & Taft LLP

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Through an interim final rule, the Office of the Comptroller of the Currency, the Federal Reserve Board and the FDIC (collectively, the "agencies") increased the asset threshold from $1 billion to $3 billion for qualifying insured depository institutions ("IDIs") to be eligible for an 18-month on-site examination cycle.
United States Finance and Banking
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Through an interim final rule, the Office of the Comptroller of the Currency, the Federal Reserve Board and the FDIC (collectively, the "agencies") increased the asset threshold from $1 billion to $3 billion for qualifying insured depository institutions ("IDIs") to be eligible for an 18-month on-site examination cycle. In order to apply for an extended examination cycle, such institutions must have an "outstanding" composite rating. The interim rule will become effective upon publication in the Federal Register.

The agencies issued the interim rule to comply with the Economic Growth, Regulatory Relief, and Consumer Protection Act of 2018, which permits agencies to examine qualifying IDIs with under $3 billion in total assets at least once during each 18-month cycle. According to the agencies, to qualify for an extended 18-month examination cycle, any IDI with total assets under $3 billion must satisfy certain "capital, managerial, and supervisory" standards.

Comments on the interim rule must be submitted within 60 days of publication in the Federal Register.

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