The SMART Act of 2025 would change how federal agencies examine some banks and credit unions. It applies to insured depository institutions and insured credit unions with $6,000,000,000 or less in consolidated assets that are "well managed" and "well capitalized." After a full-scope, on-site exam, the next scheduled exam for such institutions would be a limited-scope exam. Institutions could ask to combine separate safety and soundness, consumer compliance, and IT/cybersecurity exams so two or three are done at the same time. Federal banking agencies and the National Credit Union Administration must issue rules within 12 months to set procedures for limited-scope exams, for reviewing institutions that have material changes or compliance failures, and to balance streamlining with oversight. The bill keeps agency authority to do off-site monitoring, targeted reviews, or extra full-scope, on-site exams if needed. Definitions in the bill say a consumer compliance exam is the check for Federal consumer financial law, and ‘‘well managed’’ means the institution was found well managed and its composite condition was satisfactory or outstanding at the most recent exam.
If you use a small bank or credit union that meets the rules, that institution may have fewer or narrower on-site exams. The institution can also request combined exams to reduce separate reviews. Agencies can still step in with full exams or extra checks if they find problems or see major changes. Members and customers should expect that oversight remains possible even if routine exams are narrowed.
No publicly available information.
The bill says it seeks to reduce regulatory burden on certain well managed and well capitalized institutions and to streamline the examination cycle while maintaining sufficient oversight. Supporters would point to the bill language that allows limited-scope and combined examinations to reduce unnecessary regulatory burden.
No publicly available information.