Fed Announces Updated Small Bank CRA Thresholds

WASHINGTON—The Federal Reserve and the Federal Deposit Insurance Corporation have announced the 2025 updated Community Reinvestment Act (CRA) "small bank" and "intermediate small bank" asset-size thresholds.

The CRA regulations establish the framework and criteria by which the relevant agencies assess a financial institution's record of meeting the credit needs of its entire community, including low- and moderate-income neighborhoods, consistent with safe and sound operations. Financial institutions are evaluated under different CRA examination procedures based upon their asset-size classification. The asset-size thresholds are adjusted annually based on the average change in the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPI-W), which is a measure of inflation, the Fed explained.

As a result of the 2.91% increase in the CPI-W for the period ending in November 2024, the CRA asset-size thresholds for small banks and intermediate small banks are:

  • A small bank is an institution that, as of Dec. 31 of either of the prior two calendar years, had assets of less than $1.609 billion
  • An intermediate small bank is a small institution with assets of at least $402 million as of Dec. 31 of both of the prior two calendar years and less than $1.609 billion as of Dec. 31 of either of the prior two calendar years

These thresholds are in effect from Jan. 1, 2025, through Dec. 31, 2025. A list of the current and historical asset-size thresholds is available here.

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