November 12, 2025|Client Alerts
FDIC Announces Lengthened Exam Cycle Times, Including Community Reinvestment Act Evaluations
By Michael C. Flynn
The FDIC revised its Consumer Compliance Examination Manual to lengthen the exam schedule and Community Reinvestment Act (CRA) evaluations for many institutions. Absent some regulatory concern, those institutions will face fewer FDIC exams and CRA evaluations.
NEW Examination Schedule
- If a financial institution has less than $350 million in total assets, the longest new examination and CRA evaluation cycle will be 66-78 months not the previous 60-72 months.
- If a financial institution has between $350 million and $3 billion in total assets, the longest new examination and CRA evaluation cycle will be 54-66 months not the previous 24-26 months.
- If a financial institution has more than $3 billion in total assets, the longest new examination and CRA evaluation cycle will still be 24-36.
Impact of Consumer Compliance Ratings and CRA Evaluations
Banks with lower scores will be subject to more frequent exams and evaluations, which, depending on scores and the particular bank, may be as often as monthly to every 12 months.
Other Possible Reviews
For institutions with $3 billion or less in total assets which do not require additional exams or evaluations, the FDIC will conduct a mid-point analysis of the institution to determine if an “intervening supervisory activity”, such as a targeted visitation from the FDIC, is needed.
Buchalter is a leading national law firm, with over 90 years of experience representing large, medium and small financial institutions in regards to transactions, products and regulatory needs.
Buchalter’s Financial Institutions Law and Financial Institutions Regulatory Groups have broad experience in financial services products and federal and state financial regulators. Any attorneys in those groups can assist you in navigating FDIC and other regulatory examinations and inquiries.
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