The Federal Deposit Insurance Corporation proposed revising insider lending thresholds for FDIC-supervised institutions to reflect economic growth and inflation and align them with the Federal Reserve Board’s proposed Regulation O changes. The proposal would raise the cap for credit to executive officers for purposes not otherwise authorized from USD 100,000 to USD 400,000 and the cap above which insider credit requires prior board approval from USD 500,000 to USD 2 million. The applicable limits would be the lower of 2.5% of unimpaired capital and unimpaired surplus or USD 400,000 for specified executive officer lending, and the lower of 5% of capital and surplus or USD 2 million for insider lending without prior board approval. The FDIC would eliminate the existing USD 25,000 minimum threshold and adjust the dollar caps every five years using nominal gross domestic product, except when cumulative nominal GDP growth is negative. It estimates that up to 1,457 of the 2,700 institutions it supervised as of March 31, 2026, could be directly affected by the increase in the board approval threshold. Comments are due 60 days after the proposal is published in the Federal Register.

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