Regulatory Considerations for Banks Crossing the $10 Billion Threshold
The Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank) brought sweeping regulatory changes to the United States' financial system. As a result, the $10 billion consolidated asset threshold ("the threshold") came into focus as banks had to consider the regulatory implications of crossing the threshold. More recently, the Economic Growth, Regulatory Relief, and Consumer Protection Act, signed into law in 2018, marked the first significant reform to specific provisions implemented by Dodd-Frank and has changed the regulatory view on small to midsize banks as certain regulatory requirements of the past are no longer required for institutions crossing the threshold in assets, e.g., DFAST requirements. Although each prudential bank regulator views this asset threshold differently from a supervisory perspective, institutions are tasked with understanding their new regulatory scope, which includes heightened expectations from the regulators and regulatory compliance changes. Many processes are much of the same, but there are several notable changes your institution can expect.