TRUST Act of 2025: Changing Bank Examination Schedules
July 17, 2025
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Where This Stands
Currently in_committee. The next step in the legislative lifecycle is Floor Vote.
Version history
Only one version on file - nothing to compare yet. As later stages (committee substitute, engrossed, enrolled) are captured, the redline appears here.
View official text →The Frame
This bill changes the frequency of federal oversight for mid-sized banks, potentially reducing the regulatory burden for institutions with assets between $3 billion and $6 billion.
Potentially affected actors named in the source documents. Mention is not a position.
Insured depository institutions with $3B-$6B in assets
These banks would become eligible for a less frequent federal examination cycle.
Federal banking agencies
These agencies would be required to adjust their examination schedules for institutions meeting the new asset threshold.
Current stage: in_committee.
Floor Vote.
Summary
Key Facts
- The bill increases the asset threshold for qualifying insured depository institutions from $3 billion to $6 billion.
- Qualifying institutions under the new $6 billion threshold would be eligible for federal examinations at least once every 18 months.
- The bill amends Section 10(d) of the Federal Deposit Insurance Act (12 U.S.C. 1820(d)).
- The bill is formally titled the 'Tailored Regulatory Updates for Supervisory Testing Act of 2025'.
Frequently Asked Questions
What banks are affected by this bill?
How does this change the current examination schedule?
Why It Matters
This bill changes the frequency of federal oversight for mid-sized banks, potentially reducing the regulatory burden for institutions with assets between $3 billion and $6 billion.
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.”
MEHLMAN CONSULTING, INC.
on behalf of NORTHERN TRUST
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.
Expansion of Regulatory Relief
The bill continues a trend of raising asset thresholds to reduce the frequency of federal oversight for mid-sized financial institutions.
Connected Entities
Analysis Score
0–100- Significance45How 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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