Oklahoma Bankers Association We make bankers better!
In This Issue…
- Happy holidays from us!
- From Adrian’s desk …
- Court reinstates beneficial ownership registry deadline
- Court issues partial injunction against Illinois law restricting interchange fees
- Agencies release annual asset-size thresholds for CRA regulations
- OBA education corner …
Happy holidays from us!
Happy holidays and merry Christmas from your family here at the OBA!
In observance of Christmas, our offices will be closed on Wednesday, Dec. 25. We will re-open at our normal time on Thursday, Dec. 26.
From Adrian’s desk …
By Adrian Beverage
OBA President & CEO
Just a quick short message from my desk today. The holidays are upon us! With that in mind, from my family – as well as my OBA family – I’d like to wish everyone happy holidays and a merry Christmas!
• • •
A last-second addition was made to the Update today, and I encourage our bankers to make note of the information below about the reinstatement of the beneficial ownership registry deadline.
Court reinstates beneficial ownership registry deadline
The U.S. Court of Appeals for the Fifth Circuit on Monday reinstated the enforceability of the Corporate Transparency Act and lifted the nationwide injunction issued by the district court judge earlier this month.
In the process, the court reinstated the Jan. 1, 2025, compliance deadline for most covered businesses to report their beneficial ownership information to the Financial Crimes Enforcement Network as required by the CTA.
Due to the period when the preliminary injunction was in effect, however, FinCEN delayed to Jan. 13 the deadline for most businesses to file their initial beneficial ownership information. Businesses created or registered on or after Dec. 3, 2025, will have an additional 21 days from their deadline to file. Deadlines for companies created or registered on or after Jan. 1, 2025, are unchanged. (Banks are exempt from filing, but many of their business clients are covered.)
The lawsuit in Texas was filed by the National Federation of Independent Business and several of its members. The plaintiffs argued that the CTA exceeded Congress’ authority to regulate interstate commerce, that it violates the First Amendment by compelling speech and infringing freedom of association and that it violates the Fourth Amendment by forcing the disclosure of private information.
Court issues partial injunction against Illinois law restricting interchange fees
A federal judge on Friday ordered a preliminary injunction against enforcement of an Illinois state law restricting interchange fees for national banks and federal savings associations but left the law in effect for Illinois-chartered institutions and credit card networks for now.
The order also leaves the law in effect for out-of-state banks and federal credit unions until the court can review the legal arguments in more detail.
The Illinois Interchange Fee Prohibition Act bans banks, payment networks and other entities from charging or receiving interchange fees in Illinois on the portion of a debit or credit card transaction attributable to tax or gratuity. In August, the American Bankers Association, Illinois Bankers Association and other groups challenged the law in U.S. District Court for the Northern District of Illinois, arguing it violates multiple federal statutes, including the National Bank Act and the Federal Credit Union Act. The OCC filed a rare amicus brief in October in support of the associations’ position.
Agencies release annual asset-size thresholds for CRA regulations
The Federal Reserve Board and the Federal Deposit Insurance Corporation announced on Dec. 19 the 2025 updated Community Reinvestment Act “small bank” and “intermediate small bank” asset-size thresholds.
The CRA regulations establish the framework and criteria by which the relevant agencies assess a financial institution’s record of meeting the credit needs of its entire community, including low- and moderate-income neighborhoods, consistent with safe and sound operations. Financial institutions are evaluated under different CRA examination procedures based upon their asset-size classification. The asset-size thresholds are adjusted annually based on the average change in the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPI-W), which is a measure of inflation.
As a result of the 2.91 percent increase in the CPI-W for the period ending in November 2024, the CRA asset-size thresholds for small banks and intermediate small banks are:
- A small bank is an institution that, as of December 31 of either of the prior two calendar years, had assets of less than $1.609 billion.
- An intermediate small bank is a small institution with assets of at least $402 million as of December 31 of both of the prior two calendar years and less than $1.609 billion as of December 31 of either of the prior two calendar years.
These thresholds are in effect from Jan. 1, 2025, through Dec. 31, 2025. A list of the current and historical asset-size thresholds is available here.
OBA education corner …
Merry Christmas and happy holidays to all out there! While basking in the spirit of the season, take just a little time to look at the upcoming continuing education opportunities for you and your staff in the upcoming new year!
- Current Matters and Common Questions on the Call Report, Jan. 10, webinar — This two-hour webinar is designed to equip call report preparers and reviewers with the insights and tools needed to stay compliant and accurate in 2025.
- Reconsiderations of Value: Regulatory Expectations and How to Put Together Your Process, Jan. 13, webinar — The regulatory agencies, as well as HUD, FHFA, Fannie Mae, and Freddie Mac, recently issued their Final Interagency Guidance on ROVs.
- B2B Payments Trends and Innovations: Strategies for Financial Institutions, Jan. 13, webinar — This webinar will explore the latest trends and innovations in B2B payments, with a particular focus on the strategies financial institutions can employ to optimize their payment processes, integrate instant payments and stay ahead in a competitive market.