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Financial Institution Letter

Management Interlocks

Interagency Proposed Rule on Thresholds Increase for Major Assets Prohibition of the Depository Institution Management Interlocks Act Rules

Summary:

The FDIC and the other federal financial institution regulatory agencies have jointly issued a proposed rulemaking to raise the thresholds for the Major Assets Prohibition of the Depository Institution Management Interlocks Act (DIMIA) implementing rules.

Statement of Applicability to Institutions with Total Assets Under $1 Billion: This Financial Institution Letter applies to FDIC-supervised financial institutions with total assets over $1 billion.

Highlights:

  • The FDIC, the Office of the Comptroller of the Currency, and the Board of Governors of the Federal Reserve System are issuing a Notice of Proposed Rulemaking (NPR) with a request for comment on a proposal to adjust the major assets prohibition thresholds of the DIMIA rule to fulfill a commitment made in the 2017 Economic Growth and Regulatory Paperwork Reduction Act Report to Congress.
  • Under the existing major assets prohibition, a management official of a depository organization with total assets exceeding $2.5 billion (or any affiliate of such an organization) may not serve at the same time as a management official of an unaffiliated depository organization with total assets exceeding $1.5 billion (or any affiliate of such an organization), regardless of the location of the two depository organizations.
  • The NPR proposes to increase both thresholds in the major assets prohibition rule to a single $10 billion threshold based on general market changes since 1996 when the major assets threshold in DIMIA was amended.
  • The NPR also solicits comments on three alternative approaches to raise the major assets prohibition thresholds. Two are based on market changes, and one is based on inflation adjustments.
  • Comments on the proposed rule and alternative approaches to raise the thresholds are due 60 days after publication in the Federal Register .

Suggested Distribution:

  • FDIC-Supervised Institutions

Suggested Routing:

  • Chief Executive Officer
  • Compliance Officer

Paper copies may be obtained through the FDIC's Public Information Center, 3501 Fairfax Drive, E-1002, Arlington, VA 22226 (877-275-3342 or 703-562-2200).


Additional Related Topics:

  • FDIC Rules and Regulations, 12 CFR Part 348 (Management Official Interlocks)
FIL-88-2018
Attachment(s)

Last Updated: December 20, 2018