H.R. 4437 — SMART Act of 2025

This section establishes examination relief for well managed and well capitalized insured credit unions with $6 billion or less in consolidated assets. Specifically, after a full-scope, on-site examination by the National Credit Union Administration (NCUA), the next examination is a limited-scope examination, as determined by NCUA; and, upon request by the credit union, NCUA must combine two or three of its otherwise separate safety and soundness, consumer compliance, and information technology/cybersecurity examinations. Such relief does not apply if the credit union is subject to a formal enforcement proceeding or order by NCUA; requires NCUA to issue implementing rules within 12 months of enactment, including procedures for limited-scope examinations, reviews of credit unions with material changes in condition/risk or noncompliance, and balancing burden reduction with safety/soundness oversight; and preserves NCUA's authority for off-site monitoring, targeted reviews, or additional full-scope examinations as needed. (Well managed means the credit union received a satisfactory or outstanding composite rating in its most recent examination; well capitalized has the meaning given in 12 U.S.C. §1795.18.)

This section requires, with respect to on-site examinations of insured depository institutions with less than $6 billion in total assets, the appropriate federal banking agency to (1) ensure the examination is led by an examiner with significant experience, to the maximum extent practicable; (2) minimize the number of examiners used and time spent on the examination, to the maximum extent practicable; (3) schedule the examination at a convenient time for the institution, to the maximum extent practicable; and (4) provide advance notice of expected issues, to the maximum extent practicable. The section further requires each federal banking agency to include in its annual report to Congress information on compliance with these requirements and with any prior similar requirements, plus aggregate data on such examinations including average examiner experience (specifically years for examination leaders), average number of examiners used, and average time spent on-site. Similarly, this section imposes parallel examination practice and annual reporting requirements on the National Credit Union Administration for insured credit unions with less than $6 billion in total assets.