ABA Banking Journal
No Result
View All Result
  • Topics
    • Ag Banking
    • Commercial Lending
    • Community Banking
    • Compliance and Risk
    • Cybersecurity
    • Economy
    • Human Resources
    • Insurance
    • Legal
    • Mortgage
    • Mutual Funds
    • Payments
    • Policy
    • Retail and Marketing
    • Tax and Accounting
    • Technology
    • Wealth Management
  • Newsbytes
  • Podcasts
  • Magazine
    • Subscribe
    • Advertise
    • Magazine Archive
    • Newsletter Archive
    • Podcast Archive
    • Sponsored Content Archive
SUBSCRIBE
ABA Banking Journal
  • Topics
    • Ag Banking
    • Commercial Lending
    • Community Banking
    • Compliance and Risk
    • Cybersecurity
    • Economy
    • Human Resources
    • Insurance
    • Legal
    • Mortgage
    • Mutual Funds
    • Payments
    • Policy
    • Retail and Marketing
    • Tax and Accounting
    • Technology
    • Wealth Management
  • Newsbytes
  • Podcasts
  • Magazine
    • Subscribe
    • Advertise
    • Magazine Archive
    • Newsletter Archive
    • Podcast Archive
    • Sponsored Content Archive
No Result
View All Result
No Result
View All Result
Home Community Banking

The best way to index supervisory thresholds

Indexing asset thresholds to account for inflation is a no-brainer — but how to index matters. Indexing to aggregate year-on-year growth in total industry assets provides the most value with the least distortion.

April 30, 2025
Reading Time: 4 mins read
The best way to index supervisory thresholds

Image by Nicholas Cappello

By Tyler Mondres and Hugh Carney
ABA Viewpoint

In a previous Viewpoint on the Trump administration’s approach to inflation, we explored the overlooked issue of indexing regulatory thresholds — that is, how policymakers should adjust financial rules and standards in response to economic growth and inflation. Failing to do so can erode the original intent of thresholds, creating unintended regulatory burden.

Indexing plays a crucial role in maintaining regulatory relevance, reducing unintended constraints on market participants and the public, and ensuring that rules remain appropriately calibrated as the economy grows. While regulators have recognized the importance of revisiting asset triggers (such as for the 18-month exam cycle; see Figure 1), few regulations hardwire in regular adjustments. Those that do typically reference the Consumer Price Index.

This second article in this three-part series explores the strengths of indexing regulatory thresholds to the aggregate size of the banking sector — which would align with the dynamics of the industry more closely than CPI. This was especially clear in 2020 when bank assets surged from pandemic-driven deposits, with annual asset growth peaking two years before inflation, as measured by CPI.

The case for indexing

Asset-size triggers for enhanced (or CFPB) supervision, capital and liquidity requirements, reporting obligations, and monetary thresholds such as deposit insurance protections are often set in fixed nominal terms. When thresholds are set, they reflect the economic landscape and industry composition of that moment. Without adjustments, their real impact shifts over time due to inflation and economic growth.

For banks, this results in regulatory creep, where the heightened standards intended for larger institutions are imposed on their smaller counterparts due to economic expansion. As the banking sector has grown, institutions that would have been considered regional or midsize at the time of implementation are now subject to regulatory frameworks designed for the largest banks.

For bank customers, a lack of inflation adjustment means a gradual erosion of protections like deposit insurance and potentially more expensive credit and other services.

Static thresholds have consequences for regulators as well. Expanding the pool of covered banks beyond the originally intended scope dilutes regulatory efforts, reducing their ability to focus on the largest sources of risk.

Which indexing approach is best?

In existing laws and regulations, inflation adjustments most commonly reference CPI. This approach is effective for monetary thresholds, and would be appropriate for suspicious activity reports, currency transaction reports, or deposit insurance (see figure 2). CPI-based indexing would ensure that these thresholds remain consistent in real dollar terms and maintain purchasing power consistency. However, CPI is not the best method for adjusting asset triggers. While preferable to static thresholds, CPI adjustments focus solely on general price levels without accounting for banking-sector-specific growth patterns.

Figure 2 (click to enlarge)

An alternative approach could be to reference economic growth as measured by gross domestic product. Financial activity often scales with economic expansion, so tying thresholds to GDP could ensure triggers remain proportionate to the size of the broader economy (see figure 3). This approach has two key weaknesses, however. Like CPI, overall economic growth can misalign with banking sector realities. GDP-based adjustments to monetary thresholds could also backfire in the event of stagflation, eroding the real value of deposit insurance protections as well as hindering banks’ ability to stimulate economic activity.

Figure 3 (click to enlarge)

For regulatory thresholds, a more targeted approach would be to adjust asset triggers based on the aggregate size of the banking sector. This would reflect industry dynamics more accurately than CPI or GDP and prevent shifts in the sector’s composition from effectively lowering the limbo bar for regulatory scrutiny.

In 2005, for example, the FDIC set the asset threshold for enhanced audit reporting requirements at $1 billion. At the time, only 7% of banks were covered by this rule. By the end of 2024, nearly a quarter of the industry was subject to these enhanced requirements. If that threshold had been indexed for the size of the industry, only 10% of banks would meet the asset criteria today. This would more closely align with the intended segment of the industry when the threshold was set.

Policy considerations

Each approach to indexing has trade-offs. Both CPI and GDP-based adjustments are simple and reflect price level changes or economic growth, respectively. However, they do not account for industry-specific trends. Adjustments tied to changes within the banking sector ensure appropriate thresholds within the industry but fail to capture (and may even encourage) the growth of less regulated nonbanks in financial services.

While there is room for debate over the optimal indexing reference, the worst approach is no adjustment at all — continuing to use static regulatory requirements that create regulatory drift and unintended expansions of oversight and regulation. The table below highlights how regulatory drift has occurred at thresholds across the bank size spectrum and how indexing could help reverse these unintended consequences. Periodic reviews and adjustments to threshold levels should be built into the rulemaking process.

The third and final article in this series will explore how policymakers could best implement regular indexing.

Tyler Mondres is senior director for prudential regulation at ABA. Hugh Carney is EVP for financial institutions policy and regulatory affairs at ABA.

ABA Viewpoint is the source for analysis, commentary and perspective from the American Bankers Association on the policy issues shaping banking today and into the future. Click here to view all posts in this series.

Tags: ABA ViewpointTailored regulation
ShareTweetPin

Related Posts

CFPB issues decision on TILA preemption of state laws

Federal court partially upholds Illinois interchange fee law

Legal
February 10, 2026

A federal court in Illinois partially upheld a first-of-its-kind state law restricting interchange fees for debit and credit card payments, striking down only the portion of the law that restricts the sharing of certain data obtained in transactions....

CFPB claims ‘complex’ pricing drives up cost of financial products

Democrats urge courts to stop efforts to ‘dismantle’ CFPB

Legal
February 10, 2026

Nearly 200 Democratic and independent members of Congress this week filed an amicus brief urging the courts to halt what they said is the Trump administration’s attempt to dismantle the CFPB.

ABA, groups urge FHA to improve loss mitigation options for borrowers

FHFA finalizes repeal of fair lending rule

Mortgage
February 10, 2026

FHFA has repealed a 2024 final rule that codified many of its existing practices and programs regarding fair housing and fair lending oversight of Fannie Mae, Freddie Mac and the Federal Home Loan Banks.

What do bank marketers have in store for 2024?

Loans to non-depository financial institutions: new granularity and a rapidly growing segment

Commercial Lending
February 10, 2026

These entities play a central role in credit intermediation outside the traditional banking system.

Fed’s Waller remains unconvinced of need for CBDC

Fed’s Waller seeking ‘middle lane’ on ‘skinny’ master accounts

Compliance and Risk
February 9, 2026

Federal Reserve Governor Christopher Waller provided an update on the feedback the Fed received about a proposal to create “skinny” accounts for payment services, acknowledging that banks and financial technology firms want conflicting things from the proposed service.

ABA, groups urge FHA to improve loss mitigation options for borrowers

ABA backs bank-related provisions in housing bill

Community Banking
February 9, 2026

ABA voiced support for several provisions in a legislative package intended to boost housing availability in the U.S., including language to raise supervisory thresholds for community banks and to encourage new bank formation. The House later passed the...

NEWSBYTES

Federal court partially upholds Illinois interchange fee law

February 10, 2026

Business inventories rose in November

February 10, 2026

New York Fed: Household debt reached nearly $19T in Q4

February 10, 2026

SPONSORED CONTENT

How Instant Payments Can Accelerate B2B Payments Modernization

How Instant Payments Can Accelerate B2B Payments Modernization

February 3, 2026
Digital Banking: The Gateway to Customer Growth and Competitive Differentiation

Digital Banking: The Gateway to Customer Growth and Competitive Differentiation

February 1, 2026
Planning Your 2026 Budget? Allocate Resources to Support Growth and Retention Goals

Why Every Digital Interaction Defines Your Brand Experience

February 1, 2026
Seeing More Check Fraud and Scams? These Educational Online Toolkits Can Help

Seeing More Check Fraud and Scams? These Educational Online Toolkits Can Help

November 1, 2025

PODCASTS

Podcast: How the SCAM Act would encourage platforms to go after scammers

February 4, 2026

A new kind of ‘community bank’ for small businesses

January 22, 2026

Podcast: A Lone Star banking perspective

January 15, 2026

American Bankers Association
1333 New Hampshire Ave NW
Washington, DC 20036
1-800-BANKERS (800-226-5377)
www.aba.com
About ABA
Privacy Policy
Contact ABA

ABA Banking Journal
About ABA Banking Journal
Media Kit
Advertising
Subscribe

© 2026 American Bankers Association. All rights reserved.

No Result
View All Result
  • Topics
    • Ag Banking
    • Commercial Lending
    • Community Banking
    • Compliance and Risk
    • Cybersecurity
    • Economy
    • Human Resources
    • Insurance
    • Legal
    • Mortgage
    • Mutual Funds
    • Payments
    • Policy
    • Retail and Marketing
    • Tax and Accounting
    • Technology
    • Wealth Management
  • Newsbytes
  • Podcasts
  • Magazine
    • Subscribe
    • Advertise
    • Magazine Archive
    • Newsletter Archive
    • Podcast Archive
    • Sponsored Content Archive

© 2026 American Bankers Association. All rights reserved.