United States

Eligibility for 18-month exam cycle expanded


The Federal Deposit Insurance Corporation (FDIC), Board of Governors of the Federal Reserve System (Federal Reserve) and the Office of the Comptroller of the Currency (OCC) (collectively, the Agencies) published an interagency interim final rule amending the Agencies' regulations which set forth the requirements for institutions to be eligible for the 18-month (rather than 12-month) on-site examination cycle. The changes implement section 83001 of the Fixing America's Surface Transportation Act (FAST Act) and were effective Feb. 29, 2016.

Under the amended regulations, the following conditions must be met for the extended exam cycle to be applicable:

  • The institution has total assets of less than $1 billion (raised from $500 million).
  • The institution is well capitalized as defined in the appropriate Agencies' regulations.
  • The institution was assigned a CAMELS rating of 1 or 2 for management at the most recent exam.
  • The institution was assigned a CAMELS rating of 1 or 2 as a composite rating at the most recent exam.
  • The institution is currently not subject to a formal enforcement proceeding or order.
  • No person or entity acquired control of the institution during the preceding 12-month period in which a full-scope, on-site exam would have been required.

The broadened eligibility for the 18-month exam cycle is available for insured depository institutions as well as U.S. branches and agencies of foreign banks.