Alert December 29, 2009

Federal Banking Agencies Slightly Decrease Asset-Size Thresholds for 2010 under CRA for Small and Intermediate Small Depository Institutions

The FRB, FDIC, OCC and OTS (the “Agencies”) issued releases concerning small decreases for 2010 in the asset-size thresholds under the Community Reinvestment Act (“CRA”) for small depository institutions (“DIs”) and for small intermediate DIs.  Annual adjustments to these CRA thresholds are made based upon changes in the Consumer Price Index (the “CPI”).  The CPI decreased .98% during the measurement period and, as a result for 2010:

  1. a small DI is deemed to be a DI that had, as of either December 31, 2009 or December 31, 2008, total assets of less than $1.098 billion; and
  2. a small intermediate DI is deemed to be a small DI that had, as of both December 31, 2008 and December 31, 2009, assets of at least $274 million, and that had, as of either December 31, 2008 or December 31, 2009, total assets of less than $1.098 billion. 
The foregoing asset-size threshold adjustments are effective January 1, 2010.