Multi-Agency Statement on Supervisory and Enforcement of Consumer Financial Laws

On November 17, the Fed, Consumer Financial Protection Bureau, FDIC, NCUA, and OCC issued a supervisory statement to provide clarity and transparency as to the determination of the total assets of an insured depository institution or an insured credit union for the purposes of supervision and enforcement responsibilities under Sections 1025 and 1026 of the Dodd-Frank Act. The agencies have indicated that they will use the total assets reported in a depository institution’s required quarterly reports of condition, or Call Reports to determine an institution’s asset size for these purposes and that they will follow the FDIC’s deposit insurance assessment methods to determine whether an institution should be classified as a “Large Institution”. Multi-Agency Release. Supervisory Statement.