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Currently, that $50 billion threshold affects only 38 large bank holding companies out of the approximately 6,000 banks in the United States. 1 In other words, it excludes more than 99% of all banks in the United States from enhanced review by the Fed.


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The Dodd-Frank Act requires the Federal Reserve (Fed) to evaluate banks with assets of at least $50 billion more closely than those with fewer assets.

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What should be included in the $50 billion threshold?

The $50 billion threshold is based on total consolidated assets. Several alternate metrics that regulators monitor could potentially be included or excluded from this definition. For example, should the threshold include off-balance-sheet exposures,110 global assets of foreign banks instead of U.S. assets, or assets under custody? ...

Should the $50 billion threshold be modified?

Congress is debating whether to modify the $50 billion threshold because some Members believe that it applies to too many banks that do not pose systemic risk. Bills to amend which banks are subject to enhanced regulation include H.R. 3312/S. 1893, H.R. 10, and S. 2155. ...

How many banks are affected by the $50 billion threshold?

Currently, that $50 billion threshold affects only 38 large bank holding companies out of the approximately 6,000 banks in the United States. 1 In other words, it excludes more than 99% of all banks in the United States from enhanced review by the Fed. ...

What if a bank is above $50 billion?

The first fact to remember is that the $50 billion threshold is merely the beginning of the analysis of what the Fed might -- or might not -- require upon a closer look at an institution above the threshold. Those requirements are based on size, complexity, activities and other factors that lead to varying risk profiles for banks above $50 billion. ...

Should the Fed replace the $50 billion threshold?

One suggestion is to replace the easy-to-understand, easy-to-administer $50 billion threshold with a new, complicated, multi-factor and largely political process. This would effectively eliminate the Fed’s discretion in applying existing law, rendering some systemic risk oversight and enforcement functions ineffective. ...

Is a $50 billion bank treated the same as a $250 billion bank?

In summary, the Fed, in conjunction with the other banking regulators, has used its discretion under the Dodd-Frank Act to tailor enhanced prudential standards so that a $50 billion bank is not treated the same as a $250 billion bank or a $2 trillion bank. ...

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