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FDICIA audits for banks nearing $1B

Crossing $1B? Let’s make sure your audit is ready.

As your bank approaches the $1B asset threshold, FDICIA introduces critical changes to your audit requirements. Wipfli helps financial institutions navigate this transition with clarity — avoiding independence issues, audit disruption and regulatory surprises.

The FDIC recently finalized revisions to Part 363 of FDICIA, including raising certain asset thresholds for audit and internal control requirements and indexing them for inflation. While these changes may affect some states but not others, Wipfli stays on top of emerging issues like this and is ready to help clients pivot and remain compliant no matter the outcome.

Why FDICIA changes your audit relationship

At $1B in assets (this threshold will increase in future years to keep up with inflation), FDICIA requires your institution to:

  • Undergo an independent audit of your financial statements.
  • Comply with SEC auditor independence rules, which prohibit your audit firm from performing certain advisory or operational services.
  • Ensure that your audit committee includes a majority of outside directors.

These requirements limit what your existing CPA can do — and many institutions don’t realize it until it’s too late.

Common missteps we help you avoid

  • Continuing advisory relationships with your audit firm post-threshold
  • Failing to separate internal control support from audit functions
  • Delaying transitions and scrambling to find new providers last-minute
  • Overlooking board composition changes required for compliance

How Wipfli supports your FDICIA transition

We work with banks across the country to build scalable, compliant audit strategies:

  • Independence reviews to assess conflicts with current vendors
  • Separation of services to preserve auditor eligibility
  • Audit committee guidance to meet director independence requirements
  • Templates and checklists to speed up your planning process
  • Flexible team structure so audit and advisory support stay aligned but compliant

Whether you’re months away from crossing the threshold or just starting to plan, we’re here to help you prepare with confidence.

Are you audit-ready?
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