TRUST Act of 2025
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Would double the asset-size threshold — from $3 billion to $6 billion — that allows well-managed, well-capitalized insured banks and thrifts to be examined by federal regulators on an 18-month cycle rather than the standard annual cycle, reducing the examination burden for a new tier of mid-sized institutions.
What this bill would do
What it would do
The bill would amend Section 10(d) of the Federal Deposit Insurance Act to raise the maximum total-asset level at which a qualifying insured depository institution may receive less frequent federal safety-and-soundness examinations. Under current law, institutions with less than $3 billion in total assets that are rated well-capitalized and well-managed at their most recent examination may be examined on an 18-month cycle rather than annually. This bill would extend that option to institutions with less than $6 billion in total assets meeting the same criteria.
The bill would not change the underlying well-capitalized or well-managed standards that an institution must meet to qualify, nor would it alter the 18-month examination interval itself. It simply expands which institutions are eligible for that longer interval by updating two parallel dollar-figure references in the statute.
Key provisions
- 1Would raise the asset-size ceiling for 18-month examination eligibility from less than $3 billion to less than $6 billion in total assets for well-capitalized, well-managed insured depository institutions.
Who would be affected
Insured depository institutions — primarily community and regional banks and thrifts — with total assets between $3 billion and $6 billion that carry well-capitalized and well-managed ratings from their most recent federal examination. Federal banking agencies, including the FDIC, that schedule and conduct safety-and-soundness examinations for these institutions would also be affected.
Why it matters
For banks and thrifts in the $3 billion–$6 billion asset range, qualifying for 18-month examination cycles would reduce the time, cost, and management attention devoted to federal examinations. Regulators would also be freed to concentrate examination resources on higher-risk institutions rather than routinely scheduling annual reviews at lower-risk mid-sized banks.
What would change
Changes to existing law
Amends Federal Deposit Insurance Act, 12 U.S.C. § 1820(d) (Sec. 2)
Raises the total-asset threshold for 18-month examination cycles from $3 billion to $6 billion in two parallel provisions.
Agencies directed to act
How implementation would work
The change is largely self-executing: once enacted, federal banking agencies would apply the new $6 billion threshold when scheduling examination cycles. No rulemaking or new agency guidance is required by the bill. Institutions currently above $3 billion but below $6 billion that hold well-capitalized and well-managed ratings would become immediately eligible for the 18-month cycle; agencies would incorporate them into extended schedules through normal examination planning processes.
Legislative status & sources
Latest action
Received in the Senate and Read twice and referred to the Committee on Banking, Housing, and Urban Affairs.
Official CRS summary
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This bill permits additional small insured depository institutions that are considered well-capitalized and well-managed (per their most recent examination) to qualify for less frequent examinations conducted by federal financial regulators. Specifically, the bill raises the maximum asset level that qualifies an institution for less frequent examinations from less than $3 billion to less than $6 billion.
Legislative subjects
Bank accounts, deposits, capital; Banking and financial institutions regulation; Corporate finance and management; Federal Deposit Insurance Corporation (FDIC); Finance and Financial Sector; Performance measurement
Committee report
H. Rept. 119-252