Reminder Of Final Rule Adjusting And Indexing Part 363 Thresholds

In late November 2025, the Federal Deposit Insurance Corporation (FDIC) issued FIL‑54‑2025, which, among other updates, adjusted the asset thresholds under 12 CFR Part 363. Section 36 of the Federal Deposit Insurance Act generally requires insured depository institutions above certain asset levels to undergo an annual independent audit, an assessment of the effectiveness of their internal control over financial reporting (ICFR), and related reporting and audit committee requirements. Part 363 implements Section 36.

Prior to FIL‑54‑2025, any insured depository institution with consolidated assets of $500 million or more at the beginning of its fiscal year was required to submit an annual report to the FDIC or its appropriate federal banking agency. This report included audited comparative financial statements, the independent public accountant's report, and a management report containing a statement of management's responsibilities and an assessment of management's