ICBA Advocates Asset Threshold Adjustments to FDICIA Requirements

Sep 17, 2019
ICBA sent a letter to FDIC Chairman Jelena McWilliams requesting the FDIC amend the part 363 regulations regarding the FDICIA reporting requirements.

Specifically, ICBA requested that only institutions with total assets of $1 billion or more (currently, the asset threshold is $500 million) be subject to the part 363 requirements regarding audited financial statements.

ICBA also proposed that institutions with total assets of $5 billion or more (currently, the asset threshold is $1 billion) be subject to the requirement of having internal control assessments by management and external auditors.

ICBA said that consolidation in the banking industry and the effects of inflation warrant a significant adjustment to these thresholds.

Furthermore, since the SEC has proposed a broader exemption from the SOX 404(b) internal control attestation requirements for publicly held companies, the FDIC should also adjust its asset thresholds to exempt more banks from the FDICIA internal control requirements, ICBA wrote.

Read ICBA Comment Letter