- Effective Jan. 7, 2026, the Fed and FDIC raise the CRA small-bank asset threshold to $1.649B (from $1.609B) based on a 2.51% CPI-W increase through Nov. 2025.
- Intermediate small banks are those with at least $412M in assets in both prior years but under $1.649B in either year.
- The thresholds apply through Dec. 31, 2026 under legacy CRA rules because the 2023 CRA final rule remains enjoined.
- Banks near the cutoffs may shift CRA exam categories, changing compliance burden and community lending/investment expectations.
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The recent update by the Federal Reserve Board and the Federal Deposit Insurance Corporation (FDIC) adjusts the Community Reinvestment Act (CRA) classification thresholds for 2026—specifically for “small banks” and “intermediate small banks”—to reflect inflation calculated via the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPI-W). The CPI-W increase of 2.51 % through November 2025 drives the new thresholds.
Under the legacy CRA regulations (in effect because the October 2023 CRA final rule remains enjoined), a ‘‘small bank’’ is any bank that had assets of less than $1.649 billion as of December 31 of either of the prior two calendar years. Meanwhile, ‘‘intermediate small bank’’ status applies to those that had assets of at least $412 million in both of the prior two years but remained under $1.649 billion in either year.
The effective date for the new thresholds is the latter of January 1, 2026 or the date of publication in the Federal Register—specifically, these thresholds apply starting January 7, 2026 and run through December 31, 2026.
Strategically, this raises implications for several stakeholders. Banks edging near the thresholds may now fall into new categories, altering their CRA performance evaluations—potentially affecting community lending obligations, examiner scrutiny and compliance resource allocation. Smaller banks may benefit from lower burden but risk being grouped with larger institutions if assets grow. Conversely, banks near or above the $1.649 billion mark could lose small bank status, increasing regulatory expectations. Community development groups and low- and moderate-income (LMI) neighborhoods may observe shifts in how credit needs are addressed. The continued injunction against the October 2023 CRA final rule also maintains regulatory uncertainty, especially for institutions planning long-term strategy around staffing, investment, or compliance in anticipation of a reformed CRA framework.
Open questions remain: will additional inflation-driven adjustments occur mid-year if CPI-W data becomes available (notably, October 2025 data was missing due to government shutdown)? Will the enjoined CRA final rule be reinstated or replaced, and how soon? How will banks above or near the threshold reallocate compliance resources, and how will examiners adapt to shifting compositions of small vs intermediate banks?
Supporting Notes
- The CPI-W increased by 2.51 % for the period ending in November 2025.
- The new “small bank” asset threshold is $1.649 billion as of December 31 of either of the prior two calendar years.
- The new “intermediate small bank” threshold is an institution with assets of at least $412 million in both preceding years, and less than $1.649 billion in either year.
- The previous thresholds for 2025 were a small bank under $1.609 billion and intermediate small bank between $402 million and $1.609 billion.
- The thresholds are effective from the later of January 1, 2026 or Federal Register publication—specifically January 7, 2026—through December 31, 2026.
- The institution of the legacy CRA regulation (rather than the October 2023 CRA final rule) remains in effect due to ongoing litigation enjoining the final rule’s implementation.