On July 6, 2018 the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (the agencies) issued a statement regarding the immediate impact of the Economic Growth, Regulatory Relief and Consumer Protection Act (EGRRCPA).
The statement provides information on rules and associated reporting requirements that the agencies jointly administer and that EGRRCPA immediately affected. The agencies will take the described positions in the interim rule until the agencies amend their regulations to incorporate EGRRCPA’s changes. Certain amendments took effect on the day of EGRRCPA’s enactment, whereas other provisions will take effect at a later date.
Limited information is available on a couple compliance issues:

  • Exam Cycle – EGRRCPA increases the total asset threshold for well-capitalized insured depository institutions to be eligible for an 18-month examination cycle from $1 billion to $3 billion, making an 18-month examination cycle available to a larger number of “1-rated” institutions, and authorizes the agencies to make corresponding changes for “2-rated” institutions. The agencies intend to engage in rulemaking to implement these provisions.
  • Appraisals in Rural Areas – EGRRCPA provides an exemption to the appraisal requirements for certain transactions with values of less than $400,000 involving real property or an interest in real property that is located in a rural area, as specified in section 103 of EGRRCPA. This exemption was effective upon EGRRCPA’s enactment. The agencies are reviewing the statutory provisions to determine whether further action is necessary.

The interagency statement is available at
For more information about EGRRCPA refer to our recent blog articles:

A recording of a detailed presentation on EGRRCPA is available at: