- Potential benefitReduces compliance burden for banks that fall below raised asset-size regulatory thresholds.
- Potential benefitLowers the number of firms subject to enhanced prudential standards and related supervisory costs.
- Potential benefitAligns statutory thresholds with economic growth, reducing unintentional tightening from nominal GDP increases.
TIER Act of 2025
Referred to the House Committee on Financial Services.
The bill raises multiple statutory asset-size thresholds used in banking and financial stability statutes (e.g., $250B→$370B, $100B→$150B, $10B→$15B, $50B→$75B) and requires periodic 5-year adjustments of those thresholds tied to current‑dollar U.S. GDP. It directs the Federal Reserve, OCC, and FDIC to review and, where appropriate, modify rule‑based thresholds every five years, prescribes rounding and publication rules, and requires agency reports to Congress.
Progressives emphasize systemic‑risk and consumer protection loss.
Relative to its intended legislative type, this bill is a clear and concrete statutory amendment package that both updates specific numeric thresholds and establishes a recurring, formula-based indexing process tied to current-dollar GDP.
The bill raises multiple statutory asset-size thresholds used in banking and financial stability statutes (e.g., $250B→$370B, $100B→$150B, $10B→$15B, $50B→$75B) and requires periodic 5-year adjustments of those thresholds tied to current‑dollar U.S. GDP.
It directs the Federal Reserve, OCC, and FDIC to review and, where appropriate, modify rule‑based thresholds every five years, prescribes rounding and publication rules, and requires agency reports to Congress.
The changes primarily affect which bank holding companies, savings and loan holding companies, and financial companies are subject to enhanced regulation and certain FSOC/Title I/Tailoring provisions.
Technically focused and administrable, increasing chances; but substantive impact on financial oversight and need for wider Senate agreement reduce prospects.
Relative to its intended legislative type, this bill is a clear and concrete statutory amendment package that both updates specific numeric thresholds and establishes a recurring, formula-based indexing process tied to current-dollar GDP. It identifies responsible agencies, sets schedules, and prescribes publication and reporting requirements, while allowing some agency discretion for thresholds established by rule.
Progressives emphasize systemic‑risk and consumer protection loss.
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 burdenCould shrink the population under enhanced supervision, potentially increasing systemic risk from larger unregulated fi…
- ConsumersMay reduce regulatory scrutiny of firms serving consumers, possibly affecting consumer protections.
- Potential burdenDelegates significant threshold-setting discretion to agencies, which critics may view as reduced congressional oversig…
Why the argument around this bill splits.
Progressives emphasize systemic‑risk and consumer protection loss.
Skeptical.
Likely to view the bill as a deregulatory shift that narrows the population of firms subject to enhanced oversight and resolution planning.
May accept periodic indexing to avoid accidental coverage creep, but worries the aggregate effect weakens safeguards against systemic risk and reduces protections for consumers and communities.
Cautiously supportive if implemented with safeguards.
Recognizes need to prevent threshold creep and reduce needless compliance costs for smaller institutions, but wants careful oversight, transparency, and contingency mechanisms to preserve financial stability.
Generally favorable.
Likely to view the bill as reasonable tailoring and modernization that prevents over‑broad application of enhanced regulations to institutions that have grown only due to nominal economic growth.
Values predictability and lower regulatory burden.
The path through Congress.
Reached or meaningfully advanced
Reached or meaningfully advanced
Still ahead
Still ahead
Still ahead
Technically focused and administrable, increasing chances; but substantive impact on financial oversight and need for wider Senate agreement reduce prospects.
- No cost or CBO estimate included in text
- Net effect on systemic risk and crisis costs unclear
Recent votes on the bill.
No vote history yet
The bill has not accumulated any surfaced votes yet.
Go deeper than the headline read.
Progressives emphasize systemic‑risk and consumer protection loss.
Technically focused and administrable, increasing chances; but substantive impact on financial oversight and need for wider Senate agreemen…
Relative to its intended legislative type, this bill is a clear and concrete statutory amendment package that both updates specific numeric thresholds and establishes a recurring, formula-based indexing process tied to…
Go beyond the headline summary with full stakeholder mapping, legislative design analysis, passage barriers, and lens-by-lens tradeoff breakdowns.