- Potential benefitFewer mid‑sized banks and financial firms would meet statutory triggers for enhanced prudential regulation, likely redu…
- Potential benefitIndexing thresholds to current‑dollar GDP and scheduling periodic reviews could reduce 'regulatory creep' over time and…
- Local governmentsLower regulatory compliance costs for firms newly excluded from enhanced requirements may increase capital available fo…
TIER Act of 2025
Referred to the House Committee on Financial Services.
This bill raises multiple statutory asset-size thresholds found in the Federal Reserve Act, the Bank Holding Company Act, the Dodd-Frank Financial Stability Act of 2010, and related law — for example, raising several $250 billion thresholds to $370 billion, $100 billion thresholds to $150 billion, $50 billion thresholds to $75 billion, and $10 billion thresholds to $15 billion. It also requires the Federal Reserve Board to recalculate specific statutory thresholds every five years using the ratio of current-dollar U.S. GDP (nominal GDP) relative to a 2026 baseline, with rounding rules, public notice, and effective dates.
Whether raising asset-size thresholds meaningfully increases systemic risk (progressives see higher risk; conservatives see mostly relief for appropriately smaller institutions).
As a technical, deregulatory bill with no direct spending, it is the kind of targeted financial‑regulatory change that frequently clears the House when the majority favors regulatory relief; opposition would be primarily policy‑based rather than fiscal.
This bill raises multiple statutory asset-size thresholds found in the Federal Reserve Act, the Bank Holding Company Act, the Dodd-Frank Financial Stability Act of 2010, and related law — for example, raising several $250 billion thresholds to $370 billion, $100 billion thresholds to $150 billion, $50 billion thresholds to $75 billion, and $10 billion thresholds to $15 billion.
It also requires the Federal Reserve Board to recalculate specific statutory thresholds every five years using the ratio of current-dollar U.S. GDP (nominal GDP) relative to a 2026 baseline, with rounding rules, public notice, and effective dates.
The bill directs the Fed, OCC, and FDIC to review and adjust non-statutory regulatory thresholds that implement section 165 of Dodd-Frank on the same five-year cadence, to seek uniformity across agencies, and to report changes to Congress.
On substance the bill is a targeted deregulatory/administrative change with limited fiscal impact and clear implementation steps, which increases its practical tractability. However, because it alters statutory triggers for enhanced prudential regulation and systemic oversight, it raises policy concerns that tend to produce divided votes and make enactment across both chambers and the required consensus harder—particularly in a Senate context.
How solid the drafting looks.
Whether raising asset-size thresholds meaningfully increases systemic risk (progressives see higher risk; conservatives see mostly relief for appropriately smaller institutions).
Who stands to gain, and who may push back.
These are examples from the analysis, not a ranked list of the most-affected groups.
- Potential burdenRaising thresholds and removing some firms from enhanced supervision could leave larger institutions less subject to st…
- ConsumersReduced oversight of some institutions could weaken consumer protections and supervision (e.g., fair‑lending oversight,…
- Potential burdenPeriodic upward indexing tied to nominal GDP could allow thresholds to grow even if financial‑system fragility rises, p…
Why the argument around this bill splits.
Whether raising asset-size thresholds meaningfully increases systemic risk (progressives see higher risk; conservatives see mostly relief for appropriately smaller institutions).
A mainstream liberal/left-leaning observer would likely view this bill as a deregulatory measure that reduces the number of banks and financial firms subject to enhanced prudential supervision.
They would be concerned that raising statutory thresholds and automating upward adjustments tied to nominal GDP could exclude firms that have become systematically important in practice and weaken protections put in place after the 2008 crisis.
They would also note that indexing to current-dollar GDP (which includes inflation) and five-year periodicity could steadily erode regulatory coverage without periodic Congressional review.
A centrist/moderate would view the bill as a pragmatic update to statutory thresholds that may correct outdated dollar cutoffs and reduce unnecessary regulatory burdens on smaller, growing institutions.
They would welcome the predictability of a five-year, GDP-based indexing framework and inter-agency coordination, but would be cautious about unintended reductions in oversight and potential increases in systemic vulnerability.
Centrists would focus on the balance between regulatory relief and financial stability, seeking evidence that risk-based supervision remains effective for entities excluded by higher thresholds.
A mainstream conservative would likely view this bill favorably as a necessary modernization that reduces unnecessary regulatory burdens on banks whose asset sizes have been overtaken by nominal economic growth since the thresholds were set.
They would praise the automatic, rules-based indexing to GDP as a way to avoid politicized or arbitrary expansion of enhanced prudential supervision and to protect community and regional banks from heavy-handed rules designed for very large institutions.
They might argue the bill promotes economic growth, competition, and regulatory predictability while encouraging agencies to harmonize thresholds.
The path through Congress.
Reached or meaningfully advanced
Reached or meaningfully advanced
Still ahead
Still ahead
Still ahead
On substance the bill is a targeted deregulatory/administrative change with limited fiscal impact and clear implementation steps, which increases its practical tractability. However, because it alters statutory triggers for enhanced prudential regulation and systemic oversight, it raises policy concerns that tend to produce divided votes and make enactment across both chambers and the required consensus harder—particularly in a Senate context.
- No congressional budget office (CBO) or independent cost/risk analysis is included in the text; the bill’s effect on regulatory costs, supervisory workload, and systemic risk is uncertain without such estimates.
- The political alignment and priorities of congressional majorities and the executive branch are unknown here; those contextual factors strongly influence whether deregulatory technical bills advance.
Recent votes on the bill.
No vote history yet
The bill has not accumulated any surfaced votes yet.
Go deeper than the headline read.
Whether raising asset-size thresholds meaningfully increases systemic risk (progressives see higher risk; conservatives see mostly relief f…
On substance the bill is a targeted deregulatory/administrative change with limited fiscal impact and clear implementation steps, which inc…
Pro readers get the full perspective split, passage barriers, legislative design review, stakeholder impact map, and lens-based policy tradeoff analysis for TIER Act of 2025.
Go beyond the headline summary with full stakeholder mapping, legislative design analysis, passage barriers, and lens-by-lens tradeoff breakdowns.