Alert December 28, 2010

Federal Banking Agencies Make Annual CRA Adjustment to Definitions of Small and Intermediate Small Depository Institutions

The FRB, FDIC, OCC and OTS jointly released their annual Community Reinvestment Act (“CRA”) asset-size threshold adjustments for small and intermediate small depository institutions.  The annual adjustments are based upon changes in the average of the Consumer Price Index for Urban Wage Earners and Clerical Workers (not seasonally adjusted, for each twelve-month period ending in November, with rounding to the nearest million).  Effective January 1, 2011, a “small bank” or “small savings association” is one that as of December 31 of either of the prior two calendar years  had assets of less than $1.122 billion.  An “intermediate small bank” or “intermediate small savings association” is one that had assets of at least $280 million as of December 31 of both of the prior two calendar years and less than $1.122 billion as of December 31 of either of the prior two calendar years.