Extensions of Credit to Insiders
AI Analysis
The FDIC has proposed to raise and index the dollar thresholds that trigger certain insider-lending restrictions for FDIC-supervised institutions under 12 CFR part 337. The proposal would materially increase the executive-officer cap from $100,000 to $400,000 and the board-approval threshold from $500,000 to $2,000,000, which could broaden lending flexibility but also requires compliance teams to recalibrate controls, approvals, and monitoring.
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. The rule is proposed as a notice of proposed rulemaking, not a final rule, so the existing thresholds remain operative unless and until a final rule is adopted.
Compliance impact
The proposal is significant for insider-lending governance because it would raise quantitative triggers embedded in the Federal Reserve Act framework and FDIC regulations, potentially reducing the number of transactions subject to enhanced restrictions. The FDIC is signaling a structural shift by adding indexing, which means compliance programs may need an ongoing threshold-management process rath
Who is affected
Related regulations
References
AI-generated analysis. May contain errors or omissions — verify with the original FDIC source before acting. Full disclaimer.
What the FDIC said
Notice of proposed rulemaking. The Federal Deposit Insurance Corporation (FDIC) is proposing to increase quantitative thresholds for certain extensions of credit to insiders of FDIC-supervised institutions, as restricted by the Federal Reserve Act and regulations promulgated thereunder. Specifically, the proposal…
Extract from FDIC . Read the full notice at the source for the authoritative text.