HR4478-119

What This Bill Does

The TRUST Act of 2025 proposes changing two thresholds in 12 U.S.C. 1820(d) from $3 billion to $6 billion. The first is the asset ceiling for qualifying insured depository institutions to receive a full-scope on-site examination on an 18-month rather than 12-month cycle. The second is the ceiling on regulators' discretion to extend eligibility for institutions rated good rather than outstanding. The general asset test is strictly less than $6 billion, not $6 billion or less.

These exact substitutions were enacted by section 903 of Public Law 119-101 on July 11, 2026. Current statutory text already contains both $6 billion figures. H.R. 4478 is therefore an earlier proposal for relief now enacted elsewhere, not a second increase or a further six-month extension. Its instructions still target $3 billion language that is no longer present.

Who Benefits and How

Historically, qualifying banks and other insured depository institutions with assets from $3 billion to below $6 billion were the direct intended beneficiaries: fewer routine examinations can reduce preparation work and disruption. Federal banking regulators could allocate routine examination resources differently. Those are benefits of the threshold policy already enacted, not additional benefits created by the pending duplicate. The bill does not guarantee lower loan prices, additional credit, reduced examination fees or a payment to bank shareholders.

Who Bears the Burden and How

Eligibility retains the requirements for a well-capitalized, well-managed institution, the applicable composite condition rating, no current formal enforcement proceeding or order, and no acquisition of control during the relevant 12-month period. The statute's good-rated category starts at $200 million; regulators may increase that separate amount by regulation up to $6 billion upon a safety-and-soundness finding. This is not automatic eligibility for every good-rated bank below $6 billion. Regulators retain supervisory and separate-examination authority. Longer routine intervals can reduce opportunities for in-person review, but the text establishes neither increased failures nor depositor losses. Because the changes are already law, this bill establishes no new incremental compliance burden or current reduction in depositor protection. Deposit-insurance coverage and capital standards are unchanged.

Key Provisions

• Amends the stated asset ceiling for the 18-month examination category from less than $3 billion to less than $6 billion, a change already enacted in July 2026.
• Expands the stated ceiling for regulatory extension of the good-rated institution category to $6 billion, also already enacted.
• Requires continued satisfaction of capitalization, management, rating, enforcement-status and control-change conditions.
• Provides no further examination-cycle extension, capital-standard relaxation or deposit-insurance change beyond current law.