Regulatory oversight certainly has its place, but examinations can be burdensome to many institutions, particularly small, well capitalized and well managed ones. And, for those that are floating around the $500 million in assets mark, the difference between a 12 and 18 month exam cycle could provide some welcome relief. In a March 4, 2016 Financial Institution Letter, the FDIC, along with other federal financial regulatory agencies, adopted a number of interim amendments that have effectively increased the total asset size for the extended examination cycle to $1 billion for qualifying banks. So, for those well managed and capitalized institutions out there who skirt the $500 million mark, do not be afraid of crossing that threshold, as the regulators are on your side on this one.
This commentary represents the unique views of Patrick Donnelly, Member of Marcum LLP's Financial Industry Group and is not representative of Marcum LLP, its partners or its employees.
For more detail regarding the adopted amendments and whether your institution qualifies, consult the letter summary at: www.fdic.gov