On September 10, 2026, the FDIC, Federal Reserve, and OCC issued an interim final rule, effective immediately upon publication, expanding eligibility for the 18-month examination cycle for certain insured depository institutions. The rule implements Section 903 of the 21st Century ROAD to Housing Act, which increased the asset threshold from $3 billion to $6 billion for qualifying institutions.

Before the change, only qualifying institutions with less than $3 billion in total assets were eligible for an 18-month examination cycle. Under the interim final rule, institutions with less than $6 billion in total assets may qualify if they are well capitalized, well managed, not subject to a formal enforcement action, and have not experienced a change in control during the preceding 12 months. Eligible institutions generally must also hold favorable supervisory ratings.

Institutions with assets between $3 billion and $6 billion should review the revised eligibility standards to determine whether they may now qualify for an 18-month examination cycle. While the rule may reduce examination-related burden for qualifying institutions, regulators have made clear that ongoing supervisory monitoring and the ability to conduct more frequent examinations remain unchanged.

You can read the FIL here.

You can review the Interim Final Rule here.

CCI recommends all financial institutions continue, and where appropriate, enhance, internal audit, compliance review, and monitoring programs to ensure effective oversight between examination cycles. Periodic testing of key controls, risk assessments, and independent reviews can help institutions identify emerging issues and maintain examination readiness throughout the extended review period. For more information or questions regarding this update, please reach out to us via inquiries@completecompli.com.