Key considerations for crossing the $10 billion threshold
Credit union leaders and industry experts outline challenges and considerations for organizations approaching this major growth milestone.
There’s a magic milestone for financial institutions in the United States—an asset mark that has loomed large since Dodd-Frank was signed into law in 2010. That mark is $10 billion, and once a financial institution hits that mark, a lot of things change: It is subject to annual examination from the Consumer Financial Protection Bureau, receives less interchange income, and may have increased staffing needs that smaller institutions don’t face.
Until July of this year, credit unions at this asset size were also subject to increased testing and supervision from the National Credit Union Administration, but the testing threshold has now been raised to $15 billion.
Currently, only 21 credit unions sit above $10 billion in assets, but a period of steady growth and increased deposits from members who received pandemic payments helped several of those credit unions grow to $10 billion in assets in the past two to three years. Still more have grown well beyond the $1 billion mark.
How Oversight Changes at $10 Billion
At $15 billion in assets, NCUA oversight will shift to NCUA’s Office of National Examinations and Supervision. But when a credit union is smaller than $10 billion, most oversight comes from the regional NCUA regulator.
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