H.R. 4437

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.