The SMART Act of 2025 aims to provide examination relief for well-managed and well-capitalized insured depository institutions and credit unions with less than $6,000,000,000 in total assets. The bill emphasizes limited-scope examinations for qualifying institutions, led by experienced examiners with minimized duration and conducted at the convenience of the institution. It also requires advance notice of examination issues. Additionally, federal banking agencies and the National Credit Union Administration are mandated to include detailed compliance information and aggregated examination practices in their annual reports to Congress.
Supervisory Modifications for Appropriate Risk-based Testing Act of 2025 or the SMART Act of 2025
This bill limits the scope of certain examinations and combines oversight procedures for certain small depository institutions and credit unions.
Specifically, depository institutions and credit unions that are considered well-capitalized and well-managed (per their most recent examination) with assets of $6 billion or less must receive a limited-scope examination, as determined by the appropriate federal regulator, in the year following a full-scope examination. In addition, upon request by the depository institution or credit union, the regulator must combine separate compliance examinations (e.g., safety and soundness examinations and information technology examinations) and perform them at the same time.
The bill provides exceptions for recently acquired depository institutions and for depository institutions and credit unions subject to certain formal enforcement proceedings or orders.