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#1199603 - 06/11/09 03:11 PM Reguirements for $500M+ bank
lakesider Offline
Member
Joined: Mar 2001
Posts: 73
bixby, OK
Our bank just went over the $500M mark. We are non-publicly held so I don't think Sarbanes-Oxley applies, but what else do I need to be doing? We are regulated by Fed.

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Audit
#1200855 - 06/12/09 08:27 PM Re: Reguirements for $500M+ bank lakesider
Skyline Offline
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Skyline
Joined: Sep 2005
Posts: 589
If you maintain the level for two year ends, then you might want to look into Community Reinvestment Act - Reg BB.
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#1200867 - 06/12/09 08:40 PM Re: Reguirements for $500M+ bank Skyline
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 79,926
Galveston, TX
You also fall under certain requirements of FDICIA.
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#1203763 - 06/18/09 06:15 PM Re: Reguirements for $500M+ bank rlcarey
Auditjg Offline
Member
Auditjg
Joined: Sep 2004
Posts: 67
We are in the same situation and you are now required to complete your own financial statements (our external auditors used to do this and we have been preparing for the last couple of years). You also have to have an Audit Committee that is independent of mgmt. We talked about this a lot with our External Auditors and mgmt can still stay on and attend meetings, however you should have an Executive session that is completely without mgmt and soley outside directors.

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#1203770 - 06/18/09 06:21 PM Re: Reguirements for $500M+ bank Auditjg
Skittles Online
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Skittles
Joined: Sep 2002
Posts: 13,963
TN
This level doesn't change your CRA requirements. Those cut-offs are $250M and $1,000M.
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#1206292 - 06/23/09 06:45 PM Re: Reguirements for $500M+ bank Skittles
Andy_Z Offline
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Andy_Z
Joined: Oct 2000
Posts: 27,546
On the Net
http://www.fdic.gov/news/news/financial/2009/fil09033.html

The FDIC has amended Part 363 of its regulations, which sets forth annual independent audit and reporting requirements for insured institutions with $500 million or more in total assets. The FDIC Board of Directors adopted these amendments in light of changes in the industry; certain sound audit, reporting, and audit committee practices incorporated in the Sarbanes-Oxley Act of 2002; and the FDICís experience in administering Part 363. The amendments also provide clearer and more complete guidance for compliance with Part 363
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#1209189 - 06/29/09 01:06 PM Re: Reguirements for $500M+ bank Andy_Z
lucyc Offline
Diamond Poster
lucyc
Joined: Jul 2007
Posts: 1,072
The effective date is 30 days after the publication date in the Federal Register.

Does anyone know if it's been published yet?

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#1211049 - 07/01/09 11:39 PM Re: Reguirements for $500M+ bank lucyc
DownSouth1 Offline
New Poster
Joined: Jul 2005
Posts: 24
KY
Not published in the Federal Register yet as of today. Attachments to the FIL did refer to some implementation dates. You might want to look over those.

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#1225364 - 07/30/09 09:13 PM Re: Reguirements for $500M+ bank DownSouth1
mmumm Offline
100 Club
Joined: Jul 2008
Posts: 163
Santa Cruz, California
Since the new threshold for intermediate small is $277M does that mean nothing is required once we hit $250M, or is there still something when youhit 250?

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