FDIC approves ICBA-advocated audit threshold adjustments

The FDIC approved a final rule updating Federal Deposit Insurance Corporation Improvement Act audit and reporting requirements to raise thresholds and account for inflation, as advocated by ICBA.

Details: Effective Jan. 1, 2026, the final rule will:

• Increase the Part 363 applicability asset threshold from $500 million to $1 billion.

• Raise the internal control over financial reporting (ICFR) asset threshold from $1 billion to $5 billion.

• Apply minimum audit committee requirements to institutions between $1 billion and $5 billion in total assets, up from the current range of $500 million to $1 billion.

• Increase the threshold for additional audit committee requirements from $3 billion to $5 billion.

• Update the compensation threshold in Part 363 related to the determination of whether a director is considered “independent of management” from $100,000 to $120,000.

• Provide for future adjustments indexed to inflation.