FDIC Consultations

Key dates

2026-08-06

FDIC published the notice of proposed rulemaking in the Federal Register

2026-10-05 Deadline

Comments on the proposal must be received by the FDIC

Suggested considerations

• Compliance teams may wish to map current insider-lending policies against the proposed $400,000 and $2,000,000 thresholds to assess operational impact if finalized.
• Firms may wish to review board-approval workflows and escalation triggers so systems can be updated quickly if the proposal is adopted.
• Institutions may wish to evaluate whether existing exception reporting, insider tracking, and credit administration procedures will need revision to reflect periodic indexing rather than fixed thresholds.
• Commenters may wish to submit feedback by the October 5, 2026 comment deadline if the proposed thresholds or indexing methodology would create implementation issues.

What changed

The proposal amends 12 CFR 337.3 for extensions of credit to insiders of FDIC-supervised institutions. It would increase the threshold for certain extensions of credit to executive officers not otherwise specifically authorized by statute from $100,000 to $400,000, and it would increase the threshold for extensions of credit to insiders requiring prior approval by the board of directors from $500,000 to $2,000,000. The FDIC also proposes to establish an indexing methodology to periodically update those dollar thresholds over time.

Key dates

2026-07-31

FDIC Board approved the two notices of proposed rulemaking by notational vote

Suggested considerations

• Compliance teams may wish to review the forthcoming NPRM text and accompanying Financial Institution Letter for specific amendments to CRA and insider-lending requirements.
• Banks may wish to map current CRA policies, monitoring, and documentation against the existing regulation to identify where process changes could be needed if the proposal is adopted.
• Institutions may wish to review insider-credit approval, reporting, and conflict-management controls so they can assess whether the proposal would require policy or system updates.
• Stakeholders may wish to monitor the comment period and prepare submissions if the proposals raise operational, prudential, or conduct concerns.

What changed

The Board approved a proposed update to the FDIC’s **Community Reinvestment Act regulations**, which may affect how covered institutions are evaluated for community reinvestment performance and related compliance expectations. The Board also approved a proposed rule on **extensions of credit to insiders**, indicating possible changes to the FDIC’s insider lending restrictions, governance controls, and related reporting or approval requirements.