FDIC to banks: Loan insiders up to $2M, no biggie?
Published Date: 8/6/2026
Proposed Rule
Summary
The Federal Deposit Insurance Corporation (FDIC) is proposing to increase quantitative thresholds for certain extensions of credit to insiders of FDIC-supervised institutions, as restricted by the Federal Reserve Act and regulations promulgated thereunder. Specifically, the proposal would increase the thresholds for certain extensions of credit to executive officers not otherwise specifically authorized by statute from $100,000 to $400,000; and extensions of credit to insiders requiring prior approval by the board of directors from $500,000 to $2,000,000. The proposal would also establish an indexing methodology to periodically update such thresholds over time.
Analyzed Economic Effects
3 provisions identified: 3 benefits, 0 costs, 0 mixed.
Insider loan caps raised to $400k/$2M
The FDIC proposes to raise two dollar caps: loans to executive officers not otherwise authorized would increase from $100,000 to $400,000, and extensions of credit to insiders that require prior board approval would increase from $500,000 to $2,000,000. The FDIC estimates up to 1,457 FDIC-supervised institutions could be directly affected, out of 2,700 institutions as of March 31, 2026.
Five-year automatic indexing by nominal GDP
The FDIC proposes to automatically update the dollar-based thresholds every five years using seasonally adjusted U.S. nominal GDP. Every five years the FDIC would publish the nominal GDP ratio and updated thresholds, rounding thresholds in the thousands to one significant digit and in the millions to two significant digits, and would not reduce thresholds if nominal GDP declines.
Eliminate $25,000 minimum threshold
The FDIC proposes to remove the current $25,000 minimum dollar-based floor from the three-pronged threshold calculation so that the applicable limits would be the lower of a percent of unimpaired capital and unimpaired surplus or a dollar-based maximum (for example, the lower of 2.5% or $400,000 for executive officers). The change would streamline calculation and compliance.
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