Reguirements for $500M+ bank

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.

If you maintain the level for two year ends, then you might want to look into Community Reinvestment Act - Reg BB.

You also fall under certain requirements of FDICIA.

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.

This level doesn't change your CRA requirements. Those cut-offs are $250M and $1,000M.

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 FDIC’s experience in administering Part 363. The amendments also provide clearer and more complete guidance for compliance with Part 363

The effective date is 30 days after the publication date in the Federal Register.

Does anyone know if it's been published yet?

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.

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?