The Federal Reserve Board and the Federal Deposit Insurance Corporation (FDIC) updated the Community Reinvestment Act (CRA) “small bank” and “intermediate small bank” asset-size thresholds for 2026.
The CRA establishes the criteria for relevant federal agencies to assess a financial institution’s record of meeting the credit needs of its entire community, including low- and moderate-income neighborhoods. Further, the financial institutions are evaluated under the CRA based upon their asset-size classification.
The asset-size thresholds are adjusted annually based on the average change in inflation, as measured by the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPI-W).
Thus, as a result of the 2.51 percent increase in the CPI-W for the period ending in November 2025, the CRA asset-size thresholds for small banks and intermediate small banks have been altered accordingly.
Specifically, a small bank is an institution that, as of December 31 of either of the prior two calendar years, had assets of less than $1.649 billion. In addition, an intermediate small bank is categorized as a small institution with assets of at least $412 million as of December 31 of both of the prior two calendar years and less than $1.649 billion as of December 31 of either of the prior two calendar years.
These new thresholds go into effect starting around January 1, 2026 or the date of publication in the Federal Register, whichever is later.