SMART Act of 2025: Reducing Bank and Credit Union Examination Burdens
May 12, 2026
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The Frame
This bill changes the oversight process for community banks and credit unions with under $6 billion in assets, potentially reducing their administrative costs by streamlining how federal regulators conduct safety, compliance, and cybersecurity examinations.
Potentially affected actors named in the source documents. Mention is not a position.
Insured depository institutions
Institutions with under $6 billion in assets may see changes to the frequency and structure of their federal examinations.
Insured credit unions
Credit unions with under $6 billion in assets may see changes to the frequency and structure of their federal examinations.
Federal banking agencies
These agencies are required to update their rulemaking and examination procedures within 12 months.
Last recorded activity May 12, 2026.
Next step not available in the current record.
Summary
Key Facts
- Applies to insured depository institutions and credit unions with $6 billion or less in consolidated assets that are 'well managed' and 'well capitalized'.
- Mandates alternating between full-scope, on-site examinations and limited-scope examinations.
- Allows eligible institutions to request that safety, consumer compliance, and cybersecurity examinations be combined into a single event.
- Excludes institutions currently subject to formal enforcement proceedings or orders.
- Excludes institutions that have undergone a change in control since their last full-scope examination.
- Requires federal banking agencies and the NCUA to issue implementing rules within 12 months of enactment.
- Preserves the authority of regulators to conduct off-site monitoring or additional full-scope exams if deemed necessary for safety and soundness.
- Defines 'well managed' as having received a satisfactory or outstanding composite condition rating in the most recent examination.
Frequently Asked Questions
Does this bill stop regulators from checking on banks?
Which institutions qualify for these changes?
What happens if a bank is currently under an enforcement order?
Why It Matters
This bill changes the oversight process for community banks and credit unions with under $6 billion in assets, potentially reducing their administrative costs by streamlining how federal regulators conduct safety, compliance, and cybersecurity examinations.
News Coverage
Lobbying Activity
1607 STRATEGIES, LLC
on behalf of American Fintech Council
2026
“Issues related to fintech and banks-as-a-service, earned wage access, fintech legislation, and online lending. Issues related to earned wage access. H.R.940, FAIR Exams Act, all provisions. H.R. 4437, Supervisory Modifications for Appropriate Risk-based Testing Act of 2025 (SMART Act of 2025), all provisions. H.R. 4478, Tailored Regulatory Updates for Supervisory Testing Act of 2025 (TRUST Act of 2025), all provisions.”
1607 STRATEGIES, LLC
on behalf of American Fintech Council
2026
“Issues related to fintech and banks-as-a-service, earned wage access, fintech legislation, and online lending. Issues related to earned wage access. H.R.940, FAIR Exams Act, all provisions. H.R. 4437, Supervisory Modifications for Appropriate Risk-based Testing Act of 2025 (SMART Act of 2025), all provisions. H.R. 4478, Tailored Regulatory Updates for Supervisory Testing Act of 2025 (TRUST Act of 2025), all provisions.”
1607 STRATEGIES, LLC
on behalf of American Fintech Council
2025
“Issues related to fintech and banks-as-a-service, earned wage access, fintech legislation, and online lending. Issues related to earned wage access. H.R.940, FAIR Exams Act, all provisions. H.R. 4437, Supervisory Modifications for Appropriate Risk-based Testing Act of 2025 (SMART Act of 2025), all provisions. H.R. 4478, Tailored Regulatory Updates for Supervisory Testing Act of 2025 (TRUST Act of 2025), all provisions.”
1607 STRATEGIES, LLC
on behalf of American Fintech Council
2025
“Issues related to fintech and banks-as-a-service, earned wage access, fintech legislation, and online lending. H.R.940, FAIR Exams Act, all provisions. H.R. 4437, Supervisory Modifications for Appropriate Risk-based Testing Act of 2025 (SMART Act of 2025), all provisions. H.R. 4478, Tailored Regulatory Updates for Supervisory Testing Act of 2025 (TRUST Act of 2025), all provisions.”
Sponsors
Discoveries
Patterns POLISCOPE noticed across the record. These are observations to investigate, not conclusions.
Standardization of Examination Relief
The bill creates a uniform approach to examination relief across both the banking and credit union sectors by amending the Federal Deposit Insurance Act and the Federal Credit Union Act simultaneously.
Connected Entities
Sources
www.govinfo.gov
Analysis Score
0–100- Significance60How much this matters to a regular citizen
- Controversy20Intensity of disagreement among stakeholders
- Entertainment5Compellingness for a non-policy-wonk reader
- Buzz15Current news / social attention level
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