FDIC Proposes Amendments to Part 363 Thresholds With Inflation Indexing

On July 15, 2025, the Federal Deposit Insurance Corporation (FDIC) proposed amendments to Part 363 of the Federal Deposit Insurance Corporation Improvement Act (FDICIA), among other regulations. The proposal aims to adjust regulatory thresholds for inflation and reduce the compliance burden on smaller institutions that became subject to requirements originally intended for larger institutions – simply due to inflation rather than changes in their size or risk profile.

Specific to FDICIA Part 363, Annual Independent Audits and Reporting Requirements, the proposal, if passed, would have the following impact:

• Banks with assets between $500 million and $1 billion would no longer be required to file annual audited comparative financial statements and a management report.
• Banks with assets between $1 billion and $5 billion would no longer have an Internal Controls Over Financial Reporting (ICFR) requirement.
• Increase asset thresholds related to audit committee composition requirements generally from $500 million to $1 billion, and from $1 billion and $3 billion to $5 billion.

Implementation Timeline

• A 60-day public comment period will follow the publication date in the Federal Register.
• Changes will take effect at the beginning of the first calendar quarter after the final rule is adopted.
• This marks phase one of a multi-phase effort to review FDIC thresholds. The FDIC is also proposing an indexing methodology for future adjustments, which would automatically occur every two calendar years – or during any intervening calendar year when the cumulative change in the CPI-W exceeds 8% since the last adjustment.

Wolf is monitoring this proposal closely and is here to help you navigate these changes. Contact our team to learn more.