H.R. 3230, Financial Institution Regulatory Tailoring Enhancement Act

Bill Summary

H.R. 3230 would change which federal financial regulators oversee financial institutions that have between $10 billion and $50 billion in total assets. Under current law, the Consumer Financial Protection Bureau (CFPB) conducts examinations of and requires reporting from insured depository institutions and insured credit unions with total assets of more than $10 billion. Depending on the type of institution, the Federal Deposit Insurance Corporation (FDIC), the National Credit Union Administration (NCUA), the Office of the Comptroller of the Currency (OCC), or the Federal Reserve assesses compliance for financial institutions with assets below $10 billion. H.R. 3230 would raise that threshold from $10 billion to $50 billion.

The bill also would change certain asset thresholds under the Bank Holding Company Act of 1956; the Truth in Lending Act; and the Economic Growth, Regulatory Relief, and Consumer Protection Act.

Estimated Federal Cost

The estimated budgetary effect of H.R. 3230 is shown in Table 1. The costs of the legislation fall within budget function 370 (commerce and housing credit).

Basis of Estimate

CBO assumes that H.R. 3230 will be enacted by the end of 2025. Enacting the bill would shift some oversight responsibilities from the CFPB to the other financial regulators, which would decrease administrative costs for the CFPB and increase administrative costs for the FDIC, NCUA, OCC, and the Federal Reserve.

In general, CBO expects that the costs of undertaking these oversight activities would not differ much among agencies and that enacting H.R. 3230 would shift about $90 million in administrative costs over the 2026-2035 period from the CFPB to the other financial regulators.

However, the budgetary treatment of administrative costs differs among the affected agencies, and the 2025 reconciliation act lowered the amount that the CFPB may request and receive from the Federal Reserve to fund its operating costs. As a result, CBO estimates that enacting H.R. 3230 would increase direct spending by $37 million, decrease revenues by $18 million, and increase the federal deficit by $55 million over the 2026-2035 period.

Direct Spending

CBO estimates that gross costs for the FDIC, OCC, and NCUA would increase by about $70 million over the 2026-2035 period to oversee additional financial institutions. However, the NCUA and OCC are authorized to collect fees from regulated institutions to cover administrative expenses. After accounting for those fees, CBO estimates that enacting H.R. 3230 would increase net direct spending by $37 million over the 2026-2035 period.

Under current law, the CFPB is permanently authorized to spend amounts transferred from the combined earnings of the Federal Reserve in an amount necessary to carry out its responsibilities, subject to a statutory cap that was lowered by the 2025 reconciliation act. CBO expects that the CFPB will spend all the transferred funds up to its cap in each year over the 2026-2035 period.

CBO estimates that shifting oversight responsibilities to other federal regulators would reduce the CFPB’s administrative costs by about $90 million over the 2026-2035 period, but that reduction would be offset by increased spending on other required administrative activities, resulting in no net budgetary effect.

Revenues

Costs incurred by the Federal Reserve reduce remittances to the Treasury, which are recorded in the budget as revenues. CBO estimates that enacting H.R. 3230 would increase costs for the Federal Reserve by $18 million over the 2026-2035 period to oversee additional financial institutions, and thus decrease revenues by the same amount.

Changes in costs for the Federal Reserve banks have historically resulted in changes to remittances during the same year. However, since fiscal year 2023, the central bank has recorded a deferred asset to account for accrued net losses from expenses in excess of income. As a result, remittances largely have been suspended. In CBO’s projections, remittances from the Federal Reserve will generally be suspended until 2030, and until they resume, most changes in costs incurred by the system will not be recorded as changes in remittances.[1]

Pay-As-You-Go Considerations

The Statutory Pay-As-You-Go Act of 2010 establishes budget-reporting and enforcement procedures for legislation affecting direct spending or revenues. The net changes in outlays and revenues that are subject to those pay-as-you-go procedures are shown in Table 1.

Increase in Long-Term Net Direct Spending and Deficits

CBO estimates that enacting H.R. 3230 would not increase net direct spending by more than $2.5 billion in any of the four consecutive 10-year periods beginning in 2036.

CBO estimates that enacting H.R. 3230 would not increase on‑budget deficits by more than $5 billion in any of the four consecutive 10-year periods beginning in 2036.

Mandates

If the NCUA and OCC increase fees to offset the costs associated with implementing additional examinations required by the bill, H.R. 3230 would increase the cost of an existing mandate as defined in the Unfunded Mandates Reform Act (UMRA) on private entities required to pay those fees. CBO estimates that the incremental cost of the mandate would be small and would fall well below the annual threshold for private-sector mandates established in UMRA ($206 million in 2025, adjusted annually for inflation).

H.R. 3230 contains no intergovernmental mandates as defined in UMRA.

Estimate Prepared By

Federal Costs:

Julia Aman (for the Federal Deposit Insurance Corporation, National Credit Union Administration, and Office of the Comptroller of the Currency)
David Hughes (for the Consumer Financial Protection Bureau)

Revenues: Nathaniel Frentz

Mandates: Lucy Marret

Estimate Reviewed By

Justin Humphrey
Chief, Finance, Housing, and Education Cost Estimates Unit

Joshua Shakin
Chief, Revenue Projections Unit

Kathleen FitzGerald
Chief, Public and Private Mandates Unit

H. Samuel Papenfuss 
Deputy Director of Budget Analysis

Estimate Approved By