United States

Rules for 18-month exam cycle finalized


The Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System (Fed) and the Federal Deposit Insurance Corporation (FDIC) issued the interagency final rules adopting the 18-month extended exam cycle for insured depository institutions, including U.S. branches and agencies of foreign banks, with total assets less than $1 billion and that meet other qualifying criteria.  Previously, only institutions with less than $500 million in total assets qualified for the 18-month exam cycle. The final rules were adopted without changes to the interim final rules published in the Federal Register on Feb. 29, 2016. Additional criteria used to determine an institution’s eligibility for the expanded exam cycle includes:

  • CAMELS composite rating of “1” or “2”
  • Being well-capitalized
  • Being well-managed
  • Have not undergone any change in control during the previous 12 months
  • Not subject to a formal enforcement proceeding or order

The FDIC issued FIL-2-2017 which provides highlights of the final rule.