ICBA Press Release Banner 2020

Washington, D.C. (Sept. 27, 2021) — The Independent Community Bankers of America (ICBA) today called on the Federal Deposit Insurance Corp. to raise regulatory asset thresholds to account for industry consolidation, rising inflation, and a swell of deposits caused by COVID-19 stimulus efforts.

In today’s letter, ICBA asked the FDIC to permanently raise the audit and reporting requirement asset thresholds under Part 363 of its regulations, which have not been adjusted in years. These requirements impose excessive regulatory burdens on many community banks.

“When the FDIC Improvement Act was enacted, Congress intended to exempt small depository institutions from the rigors of independent annual audits and reporting requirements,” ICBA President and CEO Rebeca Romero Rainey said. “Because the FDIC has not made frequent or regular adjustments to the part 363 asset thresholds to keep pace with industry changes, the current limits no longer provide a meaningful exemption to community banks.”

Specifically, ICBA asked the FDIC to:

  • Raise the asset threshold for part 363 requirements on audited financial statements from $500 million to $1 billion.
  • Raise the threshold for internal control assessments for management and external auditors from $1 billion to $5 billion.

ICBA said the regulatory updates are needed because:

  • The smallest community banks are confronting the thresholds given industry consolidation, inflation, and a surge in deposits due to COVID-19 stimulus.
  • Temporary reporting relief related to the COVID-19 pandemic is scheduled to expire Dec. 31.
  • The regulatory requirements are costly and burdensome for small community banks.
  • The FDIC has not updated the regulatory deposit thresholds since 1993 and 2005.

For more information, visit icba.org.

About ICBA
The Independent Community Bankers of America® creates and promotes an environment where community banks flourish. ICBA is dedicated exclusively to representing the interests of the community banking industry and its membership through effective advocacy, best-in-class education, and high-quality products and services.

With nearly 50,000 locations nationwide, community banks constitute 99 percent of all banks, employ more than 700,000 Americans and are the only physical banking presence in one in three U.S. counties. Holding more than $5.8 trillion in assets, over $4.8 trillion in deposits, and more than $3.5 trillion in loans to consumers, small businesses and the agricultural community, community banks channel local deposits into the Main Streets and neighborhoods they serve, spurring job creation, fostering innovation and fueling their customers’ dreams in communities throughout America. For more information, visit ICBA’s website at www.icba.org