SMART Act of 2025
Key claim: The SMART Act of 2025 would require limited-scope examinations in the year after a full-scope exam and allow combined compliance examinations, upon request, for well-capitalized, well-managed depository institutions and credit unions with $6 billion or less in assets.
Abstract
(HR4437 · 119th Congress) Supervisory Modifications for Appropriate Risk-based Testing Act of 2025 or the SMART Act of 2025 This bill limits the scope of certain examinations and combines oversight procedures for certain small depository institutions and credit unions. Specifically, depository institutions and credit unions that are considered well-capitalized and well-managed (per their most recent examination) with assets of $6 billion or less must receive a limited-scope examination, as determined by the appropriate federal regulator, in the year following a full-scope examination. In addition, upon request by the depository institution or credit union, the regulator must combine separate compliance examinations (e.g., safety and soundness examinations and information technology examinations) and perform them at the same time. The bill provides exceptions for recently acquired depository institutions and for depository institutions and credit unions subject to certain formal enforcement proceedings or orders. Latest action (2026-05-13): Received in the Senate and Read twice and referred to the Committee on Banking, Housing, and Urban Affairs.
Why this matters
The SMART Act would reduce the supervisory burden on community banks and credit unions at or below $6 billion in assets by cutting a full-scope examination to a limited-scope review in alternate years and permitting a single combined compliance exam. For small depositories, this changes the frequency and depth of routine federal supervision; for regulators (FDIC, OCC, Federal Reserve, NCUA), it constrains examination cadence except for recently acquired institutions or those under enforcement action. Status: introduced in the House and referred to Senate Banking.