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

End the static around bank asset thresholds

September 9, 2026
Reading Time: 5 mins read
FDIC proposes tying agency regulatory thresholds to inflation

By Tyler Mondres
ABA Viewpoint

The House’s bipartisan passage of the Main Street Capital Access Act marks an important shift in the debate over bank regulation. By establishing a process to update and index numerous regulatory thresholds, lawmakers recognized that effective tailoring cannot depend on dollar figures that remain frozen while the economy and banking system continue to grow.

Tyler Mondres is VP for prudential regulation at ABA.

For years, bank regulation has relied on asset thresholds to distinguish between institutions based on size, complexity, and risk. Those thresholds determine which rules apply, when additional supervisory requirements kick in, and how regulators tailor oversight across the banking system. ABA has long argued that asset thresholds are a poor measure of risk. These crude tools are even worse when they are left static.

A $10 billion bank in 2010 is not the same as a $10 billion bank in 2026. Inflation, economic growth and balance sheet expansion gradually erode the real value of fixed dollar thresholds. Over time, more institutions become subject to requirements that were intended for much larger firms, not because their risk profiles have changed, but because the thresholds have not.

This regulatory drift creates three problems. First, it forces banks with limited complexity or risk profiles to absorb compliance and reporting costs intended for much larger and complex entities. Second, it can discourage growth by creating incentives for banks to manage their balance sheets around outdated thresholds rather than community needs, potentially limiting lending and other services. Third, it spreads supervisory and compliance resources thin across a broader range of institutions, making it harder for regulators to focus attention where it is needed most.

ABA has repeatedly highlighted this problem and proposed a simple solution: adjust thresholds for past inaction and index them prospectively to objective economic measures. Doing so would preserve the original policy judgments behind those thresholds while preventing regulatory requirements from expanding to cover more institutions simply because the economy has grown.

Indexing has moved from theory to practice

The first significant development on this issue came in November 2025, when the FDIC issued a final rule to adjust and index a number of key asset thresholds affecting community banks, including their audit and internal control thresholds. The FDIC action represented an important acknowledgment of a basic principle: when policymakers establish a threshold, they should take steps to preserve the threshold’s intended meaning over time.

Since then, the federal banking agencies have incorporated that principle into several major rulemakings:

  • In March 2026, the banking agencies released proposals addressing Basel III capital requirements, the standardized approach, and the GSIB surcharge framework. Each proposal incorporated some form of indexing for key dollar-based thresholds. Notably, the Federal Reserve proposed indexing the GSIB surcharge Method 2 coefficient to nominal GDP. As Federal Reserve Governor Christopher Waller explained, “it is critical to index bank size-related regulatory thresholds . . . to nominal GDP” because “[w]hat matters for assessing the systemic importance of a bank is its nominal size relative to the nominal size of the U.S. economy.”
  • The FDIC has similarly incorporated indexing into other significant rulemakings beyond capital. In June 2026, the agency proposed revising its insured depository institution resolution planning requirements by raising the asset threshold for covered institutions from $50 billion to $100 billion and indexing it for inflation going forward.
  • At the same meeting, the FDIC proposed updating the deposit insurance assessment framework by increasing the threshold separating “small” and “large” institutions from $10 billion to $30 billion and providing for future inflation-based adjustments every four years.

Taken together, these actions show that indexing is no longer confined to a single agency or regulatory regime. It is becoming a recurring feature of bank regulatory policy.

Legislative momentum continues to build

As regulators have increasingly embraced indexing, Congress has begun examining many of the same issues. Members of the House Financial Services Committee have called on regulators to revisit enhanced prudential standards thresholds, while lawmakers on both sides of the aisle have raised questions about whether current thresholds continue to reflect the original policy intent that justified their adoption.

During a recent Senate Banking Committee hearing, Sen. Katie Britt (R-Ala.) highlighted the practical consequences of relying on unchanged thresholds while banks continue to grow alongside the broader economy. Her comments reflected a growing recognition that tailoring frameworks should adapt over time rather than remain fixed indefinitely.

The strongest evidence that indexing has entered the mainstream may be Congress’s recent consideration of the Main Street Capital Access Act, which passed the House with strong bipartisan support.

The legislation does not automatically raise every threshold or prescribe a single indexing methodology. Instead, it creates a prospective process for regulators to study, update, and maintain thresholds. The breadth of the legislative package demonstrates how indexing has evolved from a discussion about a handful of thresholds into a broader framework for maintaining regulatory tailoring over time

Where we go from here

The progress of the past year has been substantial. The FDIC has adopted a permanent indexing framework and the banking agencies have incorporated indexing into other major regulatory proposals; Congress is actively considering legislation that would index numerous banking thresholds; and policymakers increasingly recognize the connection between indexing and effective tailoring. But the work is far from complete.

First, regulators should conduct a comprehensive review of material asset-based thresholds throughout the banking rulebook. Similar institutions should not face dramatically different treatment simply because some thresholds are indexed, while others remain frozen in time.

Second, the agencies should revisit major tailoring thresholds that have not been updated since their adoption. The original policy intent behind those thresholds may remain sound, but preserving those judgments requires keeping the thresholds aligned with economic reality.

Third, policymakers should continue refining the methodology used for indexing. As ABA has previously argued, not every threshold serves the same purpose. Indexing to nominal GDP would help ensure that thresholds remain proportionate to the size of the broader economy. Unlike inflation, which measures only price levels, nominal GDP captures the aggregate value of goods and services produced, aligning more closely with the critical role of the financial services sector in driving economic growth.

Finally, indexing should become a standard part of all rulemakings. When agencies establish a new threshold, they should simultaneously determine how that threshold will be maintained over time.

From a debate to a framework

Only a few years ago, indexing was largely absent from discussions about bank regulation. Today, it is shaping major regulatory and legislative proposals. The idea that effective tailoring requires thresholds that retain their meaning over time is firmly established in the policy conversation.

The task ahead is to ensure that indexing becomes a permanent feature of the regulatory framework.

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

Author

Tyler Mondres

Tyler Mondres

Tyler Mondres is senior director of economic research at ABA and a frequent contributor on economic and fintech topics to the ABA Banking Journal.

Related Posts

Podcast: Creating seamless customer experiences

Podcast: Creating seamless customer experiences

ABA Banking Journal Podcast
September 30, 2026

How does First Horizon Bank's growing regional bank franchise meet consumers' digital needs? 

Justice Department announces indictments in alleged nationwide ATM jackpotting scheme

OFAC issues sanctions tied to ATM jackpotting crimes

Compliance and Risk
September 30, 2026

OFAC imposed sanctions on 10 targets with alleged ties to the Tren de Aragua transnational criminal organization for its role in organizing a series of ATM jackpotting thefts across the U.S., orchestrated in part by one of the...

ABA to FCC: Protect critical calls to bank customers

FCC votes to revise ‘revoke all’ rule and ‘provided number’ condition

Compliance and Risk
September 30, 2026

The FCC voted to revise the “revoke all” rule and “provided number” condition, both of which have made it more difficult for banks to communicate by phone and text message with their customers. ABA has long called for...

Reid to lead Freddie Mac

Fannie Mae, Freddie Mac announce ABA-backed UAD 3.6 policy exceptions

Mortgage
September 30, 2026

Freddie Mac and Fannie Mae announced that they are providing a temporary policy exception for lenders that cannot meet the Uniform Appraisal Dataset, or UAD, 3.6 mandatory implementation deadline of Nov. 2. The announcement was made in coordination...

ABA survey: Americans strongly support prohibiting crypto companies from offering yield-like rewards for holding stablecoin

New rule establishes procedures for reviewing state stablecoin regulations

Newsbytes
September 30, 2026

The Treasury Department published an interim final rule establishing the forms and procedures used by a federal committee that reviews state stablecoin regulatory regimes.

ABA, associations urge Congress to overturn CFPB credit card late fees rule

ABA, associations seek passage of Fair Credit Reporting Act reform

Compliance and Risk
September 30, 2026

Before the end of the current Congress, the House should pass legislation to align the Fair Credit Reporting Act with other financial consumer protection laws by capping statutory damages in class action lawsuits, eliminating punitive damages and limiting...

NEWSBYTES

OFAC issues sanctions tied to ATM jackpotting crimes

September 30, 2026

FCC votes to revise ‘revoke all’ rule and ‘provided number’ condition

September 30, 2026

Fannie Mae, Freddie Mac announce ABA-backed UAD 3.6 policy exceptions

September 30, 2026

SPONSORED CONTENT

Beyond the Portfolio: The Wealth Manager’s New Role in a Multigenerational World

Beyond the Portfolio: The Wealth Manager’s New Role in a Multigenerational World

September 17, 2026
Banking Technology at a Strategic Crossroads

Banking Technology at a Strategic Crossroads

September 8, 2026
Taming AI Agent Sprawl: A Playbook for Consumer Lending

Taming AI Agent Sprawl: A Playbook for Consumer Lending

September 1, 2026
Grow Public Deposits Without the Operational Burden End Fragment

Grow Public Deposits Without the Operational Burden End Fragment

September 1, 2026

PODCASTS

Podcast: Creating seamless customer experiences

September 30, 2026

Podcast: Telling a different kind of story about community banks

September 28, 2026

Podcast: Making the jump from a high performer to a high-performing leader

September 16, 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.