Congress·Reported·H.R. 4437

Congress targets fewer, combined exams for well-rated banks and credit unions under $6B in assets

SMART Act of 2025

7 months ago·View on Congress.gov

Part of: Congress Moves to Ease Regulatory Burden for Banks Under $6 Billion

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Stalled

No legislative action in over 90 days.

Legislative Progress

House

Senate

President

Law

Key Points

Congress would let well-managed, well-capitalized banks and credit unions with $6 billion or less in assets get a lighter exam schedule.
After a full, on-site exam, the next exam would be limited in scope, unless the regulator thinks a full exam is needed.
Smaller institutions could ask regulators to combine safety, consumer, and cybersecurity-related exams so they happen at the same time.
The relief would not apply if the institution is under a formal enforcement action, and for banks it also wouldn’t apply after a change in control.
Regulators would have to write rules within 12 months and report to Congress on exam staffing, time spent on-site, and how they’re following the new approach.

EconomyConsumer ProtectionCybersecurity

Impact Analysis

Personal Impact

How this policy affects specific groups of people

Mixed Impacts(2)

Housing Assistance

Neutral

Federal Employee

Neutral

Milestones

3 milestones6 actions

Sep 8, 2025House

Placed on the Union Calendar, Calendar No. 206.

Sep 8, 2025House

Reported (Amended) by the Committee on Financial Services. H. Rept. 119-249.

Jul 22, 2025House

Ordered to be Reported (Amended) by the Yeas and Nays: 53 - 1.

Jul 22, 2025House

Committee Consideration and Mark-up Session Held

Jul 16, 2025House

Referred to the House Committee on Financial Services.

What Happens Next

Projected impacts based on AI analysis

After the bill becomes law

Federal banking agencies and the National Credit Union Administration write new rules for “limited-scope” exams and combined exams.

Smaller, well-run banks and credit unions won’t see the new exam relief until the rules are finalized, because the bill tells agencies to set the procedures first.

Soon after rules take effect

Eligible banks and credit unions begin requesting combined exams (two or three exam types at once).

Instead of separate visits for different exam areas, an institution may have one coordinated exam period, which can reduce repeated disruption but concentrate prep work into one window.

At the next scheduled exam cycle after rules take effect

Alternating exam cycles start after an institution’s next full-scope on-site exam.

For an eligible institution, the next exam after a full on-site exam could be limited-scope, which may reduce time regulators spend on-site unless new risks appear.

In the first annual report cycle after enactment

Agencies include new exam-practices data in their annual reports to Congress.

The public and Congress can see, in the aggregate, whether exams are using fewer examiners, less on-site time, and more experienced exam leaders for smaller institutions.