FDICIA compliance

This content was originally published on the website of Washington State Association of Counties.

Artificial Intelligence (AI) is no longer a futuristic concept reserved for research labs or tech giants in Silicon Valley. Today, AI is becoming a practical and powerful tool for local governments across the country—helping to boost efficiency, reduce costs, and elevate the quality of public services. 

When people think of technology in local government, they often picture modest upgrades: digital kiosks at city hall, online form submissions, or automated customer service portals. While these improvements are helpful, they only scratch the surface of what’s possible. They’re incremental steps in a world that increasingly demands bold, transformative change. 

Traditionally, local government hasn’t been seen as a pioneer of innovation—and that’s okay. But the landscape is shifting. Rising service demands, workforce shortages and their expectations of the workplace, and tight budgets require new and innovative ways of doing business. While it’s natural to feel uncertain about AI, avoiding it will put your organization at a disadvantage. 

The real question isn’t if local governments should engage with AI—it’s how to do it thoughtfully and strategically. Embracing AI doesn’t mean replacing people; it means empowering them. In fact, as technology becomes more integrated into our daily work, human creativity, critical thinking, and leadership are more important than ever.

How does AI translate to the public sector? 

AI can support local governments in tackling complex, everyday challenges. For example: 

• Revenue forecasting: AI-powered tools can help municipalities navigate economic uncertainty by identifying trends and improving budget accuracy. 
• Workforce planning: AI systems can optimize staffing levels to match service demands, helping reduce unnecessary costs while maintaining service quality. 
• Infrastructure maintenance: Public Works departments can use AI to analyze road usage and wear patterns, enabling proactive maintenance and smarter resource allocation. 

AI excels at analyzing data and surfacing insights—but it can’t set a vision or lead change. That’s the role of human leadership. Now more than ever, local governments need to think creatively and act strategically. Delaying key initiatives—like modernizing outdated systems or developing a long-term strategic plan—due to short-term budget concerns can hold communities back. Failing to plan is increasingly becoming more costly than taking action. Holding off on AI until you feel completely comfortable with it is not a viable strategy; forward-thinking municipalities are already realizing its benefits. 

By embracing innovation and focusing on the future, local governments can turn today’s challenges into tomorrow’s opportunities. The needs of your constituents are evolving, and so too must the capabilities of the governments that serve them. AI is not a replacement for real people doing real work—it’s a tool to help them do that work even better.  

How BerryDunn can help

The human aspect of projects can often be forgotten in the maze of regulatory changes and legal requirements with which organizations and government entities must comply. Whether we work with you from project inception or come in to refocus an initiative already underway, our team has the background to understand your needs, and the depth of project experience and technical expertise necessary to provide the guidance and support you need.

BerryDunn is not affiliated with any specific software vendor, allowing us to be truly objective. We stay abreast of the best solutions in the market, as well as industry best practices, emerging trends, and updates in the software vendor community. Our independence allows us to provide objective system consulting services and offer recommendations that serve your organization’s best interests. Learn more about our team and services. 

"The National Recreation and Parks Association’s (NRPA) Conference is just around the corner, and the annual conference can really be overwhelming, especially for first-year attendees," shares Rich Neumann, manager with BerryDunn's Parks, Recreation, and Libraries team. "Here you have direct access to the brightest minds in our industry exploring the hottest trends in parks and recreation." With the conference approaching (September 16-19 in Orlando), our team of consultants and former practitioners shares their proven strategies for navigating this landmark event. 

Plan smart, stay flexible 

"I'm a big fan of going in with a plan," explains Ryan Hegreness. "Usually, I review the education sessions a week before and use the NRPA app or my Outlook calendar to schedule sessions. I pick a primary and backup session for each time slot—but don't overschedule yourself. The best conference experiences often come from those spontaneous hallway conversations." 

Include the exhibit hall in your pre-planning, advises Jason Genck. “The exhibit hall can be overwhelming. If there are particular areas you want to visit to gain information and learn more, make a game plan ahead of time to be sure you stay focused. 

Maximize learning opportunities 

"Go to every session and take advantage of every opportunity," advises Jeff Milkes, who's attended since 1984. "Get there early—some sessions may be standing room only. Sit in the front. You'll get the most out of each session when you're not busy thinking about emails or deadlines back at the office. Use the NRPA app by selecting everything that appears interesting to you. Do this a few days in advance and ignore the schedule conflicts. Then whittle down your list and make the hard choices." 

Focus on practical solutions 

"If you're anything like me," Rich Neumann suggests, "you might want to consider prioritizing presentations that are heavy on storytelling through case studies. While theory is great, nothing compares to seeing new ideas put into practical use." 

When exploring technology solutions, Erin Provazek advises: "Come to the conference with an idea of the major pain points you have with your current system. But it's equally important to have an idea of the functionality that works really well for you." 

Network naturally 

"Don't underestimate the value of the coffee line," Nikki Ginger emphasizes, drawing from 15 years of conference experience. "I have met some incredible people and some lifelong friends... these casual conversations really can lead to some incredible knowledge sharing and problem solving." 

For introverts, Ryan Hegreness offers a practical tip: "Having a role at a conference or event helps me connect with people more easily. This can be serving as a volunteer, getting involved in planning, being a room host, or leading an education session." 

Practice self-care 

"It's important to take care of staying hydrated, eating well, and making sure you're getting some rest," Dannie Wilson advises, "so that you can really fully participate and enjoy all the conference opportunities." 

Nikki adds, "Don't try to do it all. Take a break when you can... practice self-care," whether that's exploring Lake Eola Park or finding a quiet moment with coffee. 

Listen to these and more tips on the "Let's talk parks with BerryDunn" podcast! 

Sessions presented by our team members 

We love to talk parks! Please join us at these sessions presented by our team and clients.  

Design Together, Build Together, Play Together 

Date: Monday, September 15, 2025 
Time: 8:00 – 11:00 a.m. 
Speaker(s): Lisa Paradis, Stacey Dicke 

From Data Chaos to Clarity: Streamline Operations with Dashboards 

Date: Tuesday, September 16, 2025 
Time: 2:45 – 3:45 p.m. EST 
Speaker: Becky Dunlap 

Lights, Camera, Action? Social Media for the Social Beginner 

Date: Tuesday, September 16, 2025 
Time: 2:45 – 3:45 p.m. EST 
Speaker(s): Johnathan Skinner, Nikki Ginger 

Thriving as an Introvert in an Extroverted Industry 

Date: Wednesday, September 17, 2025 
Time: 4:15 – 5:15 p.m. EST 
Speaker: Ryan Hegreness 

Should I Stay or Should I Go? 

Date: Thursday, September 18, 2025 
Time: 9:00 – 10:00 a.m. EST 
Speaker: Lisa Paradis 

“Squirrel!” …staying focused with a coworker who has ADHD 

Date: Thursday, September 18, 2025 
Time: 9:00 – 10:00 a.m. EST 
Speaker: Dannielle Wilson 

Tackle Them If You Have To: Rethinking Traditional Approaches to Community Engagement 

Date: Thursday, September 18, 2025 
Time: 2:30 – 3:30 p.m. EST 
Speaker(s): Ryan Hegreness, Rich Neumann 

And be sure to visit us at Booth 932! As Rich jokes, forget the typical conference swag—stop by for "really terrible hand-drawn portraits... the one souvenir everyone will be talking about and maybe even crying over." 

See you in Orlando! 

Innovative strategies for parks, recreation, and libraries 

BerryDunn's consultants work with you to improve operations, drive innovation, identify improvements to services based on community need, and elevate your brand and image―all from the perspective of our team’s combined 100 years of hands-on experience. We provide practical park solutions, recreation expertise, and library consulting. Learn more about our team and services.  

Changes are brewing in the healthcare industry due to far-reaching federal reforms. With the One Big Beautiful Bill Act (OBBBA) now signed into law—alongside Executive Orders (EO), judicial rulings, and other federal actions—providers are facing a wave of new requirements and opportunities. This article highlights some of the changes affecting the industry and offers a comprehensive, downloadable summary for a closer look at key impacts. 

Overview of OBBBA impacts 

• A new Rural Health Transformation Program has been created to address anticipated losses faced by rural health providers due to the cuts to Medicaid. 

• Significant changes to Medicaid, including:  

• New work requirements 

• Increased eligibility redetermination requirements

• Provider taxes 

• State-directed payments 

• Physician fee schedule 

• Affordable Care Act: Enhanced advanced premium tax credits will expire December 31, 2025.  

Other federal reforms impacting healthcare 

• Tariffs: Expected to increase costs for medical devices and pharmaceuticals made in Mexico, Canada, China, and other nations facing double-digit tariffs. 

• Pharmacy Benefit Manager (PBM)/Pharmacy ownership: Federal court blocked an Arkansas law that called for an end to PBM vertical integration. 

• US Department of Health and Human Services layoffs: The US Preventive Services Task Force is being considered for potential layoffs. 

• Health insurance premiums: Commercial health insurance companies are seeking double-digit increases for premiums for the upcoming year, as well as assessing the viability of their governmental plan offerings. 

For an in-depth look at the impacts of the OBBBA, EOs, and other federal government and judicial actions affecting the healthcare industry, we encourage you to download this full summary created by BerryDunn's industry experts. 

Our healthcare team will continue to monitor developments and offer guidance to help you navigate the changes.  

About BerryDunn 

From labor shortages to regulatory changes, today’s healthcare organizations face greater challenges than ever. Our audit, tax, clinical, and consulting professionals, focused on specific healthcare industry areas, understand these challenges and are committed to helping you meet and exceed regulatory requirements, maximize your revenue, minimize your risk, improve your operations—and most importantly—facilitate positive outcomes. Learn more about our team and services. 

The FDIC has proposed raising several key regulatory thresholds, including those that determine which institutions must comply with Part 363’s audit and internal control requirements. The primary driver behind these proposed changes is the growth experienced by institutions since the original thresholds were set decades ago. Due to inflation, the proposal aims to cover a similar number of institutions as when the thresholds were originally set. For example, the proposed increase to $5 billion for the Internal Control over Financial Reporting (ICFR) threshold, as described below, would still cover approximately 75% of institutions today.  

In addition to increasing these thresholds, the proposal also recommends that the thresholds be automatically adjusted based on some inflationary factors going forward. While the changes are designed to ease compliance burdens for smaller institutions, they also come with a cautionary tale—they would reduce regulatory requirements, but not the risk. 

What the FDIC proposal means 

Under the proposal: 

• Approximately 800 institutions may find themselves newly exempt from Part 363 compliance due to changes in 24 regulatory asset thresholds. The following items are the most likely to be relevant for community banks:

  • Banks under $1 billion in total assets would no longer be required to: 

    • Create a separate audit committee as part of the institution’s board of directors

    • File annual reports 

  • Banks under $5 billion would no longer need to: 

    • Include management assessments or auditor attestations on ICFR 

    • Require the audit committee directors to be independent from management 

    • Require the audit committee directors to include members with banking or related financial management expertise, have access to its own outside counsel, or exclude large customers of the institution 

  • Audit committee independence criteria would increase from $100,000 to a $120,000 compensation threshold. This threshold would not be indexed against inflation as it is meant to align with the listing standards of national securities exchanges. 

• Parts 303, 335, 340, 347, and 380 would also have changes if this proposal is enacted: 

• Part 303 – de minimis thresholds: 

• Increased from $1,000 to $1,225 and from $2,500 to $3,500 for certain criminal offenses 

• Part 335 – Insider loan disclosures: 

• Raised the threshold from $5 million to $10 million 

• Parts 340 & 380 – Asset sales restrictions: 

• Raised the “substantial loss” threshold from $50,000 to $100,000, which could allow an increase in potential bidders who are eligible to purchase failed institution assets 

• Part 347 – International banking: 

• Raised limits for foreign underwriting and dealing from $60M to $120M and from $30M to $60M. This is less likely to have an impact unless you have foreign operations. 

Why ICFR still matters for community banks 

Even without a federal mandate, effective ICFR offers tangible benefits: 

1. Fraud prevention: Segregation of duties, account reconciliations, and control monitoring are critical to detecting and preventing fraud—especially in lean staffing environments. 

2. Operational efficiency and reducing material misstatements: ICFR can help identify process inefficiencies and reduce errors. It can also help with training, as processes tend to be more clearly documented when they are being tested on an ongoing basis. 

3. Regulatory confidence: Examiners still expect clear documentation of key controls and risk assessments—even if an ICFR opinion is no longer required. 

4. Merger and acquisition readiness: Strong internal controls enhance bank value in due diligence settings, especially in today’s consolidation-driven environment. 

5. Board-level accountability: Internal controls provide visibility into operational risk that supports informed governance and oversight. 

6. Preparing for the next threshold: Many hours have been spent getting your documentation ready for audits, including creating, updating, and monitoring your internal controls. Walking away from the effort already put forth would mean a significant amount of time and resources to re-establish your documentation and controls as you prepare for the next threshold. Keeping your current internal practices in place with annual updates and regular monitoring will help make that next transition as smooth as possible. 

What we recommend 

For banks that would be newly exempt under the FDIC’s proposed changes, we suggest a right-sized, risk-based approach: 

• Maintain documentation of your key accounting controls and processes, including reconciliations, journal entries, and credit loss provisioning. This documentation should be updated at least annually by control owners. 

• Conduct periodic walkthroughs of high-risk processes (e.g., wire transfers, loan approvals) to identify gaps, inefficiencies, and areas of documentation that need to be updated. 

• Leverage internal or outsourced testing of controls. The frequency of this testing will likely be dependent on your institution’s risk assessment of each operational area. 

• Educate your board on how ICFR practices support accountability, even without formal reporting requirements. 

• Create a compliance checklist related to threshold changes to stay up-to-date with compliance requirements going forward: 

• Indexing monitoring plan 

• Establish a process to track inflation-based threshold changes: 

• Every 2 years, or 

• More frequently if the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPI-W) rises above 8%. Thresholds will not be reduced in deflationary periods. 

• Assign responsibility for monitoring CPI-W and updating compliance scope 

• Governance and board oversight 

• Reassess audit committee composition and independence under new thresholds 

• Review director compensation against the $120,000 independence threshold 

• Document any changes to board and/or audit committee structure or oversight responsibilities 

• Audit planning adjustments 

• Revise audit scope and frequency based on updated regulatory requirements 

• Coordinate with external auditors to align expectations and engagement terms 

• Adjust risk assessments to reflect changes in compliance burden and oversight 

• Reporting and documentation 

• Ensure proper documentation of decisions not to file Section 19 applications due to new thresholds 

• Maintain records of threshold applicability reviews and indexing updates 

• Prepare for potential regulatory inquiries regarding compliance scope changes 

• Stakeholder communication 

• Brief the board on regulatory changes, compliance impacts, and audit committee implications 

• Provide training or guidance to relevant teams (e.g., HR, compliance, finance) 

Final thoughts 

We understand the burden of ICFR compliance—and for many small banks, the relief reduces their already heavy regulatory burden. However, a move to step away from a well-established control environment has the potential to create downstream issues you might not see until it’s too late. 

Strong internal controls are not just a box to check for regulators and auditors—they're a tool for protecting your institution, your people, and your reputation. Regulators, investors, and auditors still care about the strength of your bank’s control environment—whether or not it's required by regulation. 

Maintaining strong internal controls remains a best practice—and a strategic imperative. Both are essential to your bank’s resilience, integrity, and long-term success. 

Let’s talk 

If your bank is approaching a new threshold or deciding whether to scale back ICFR documentation, we’d love to help you build a right-sized internal control approach that matches your risk profile. Reach out to our team with questions. 

Imagine this: You’re at a family reunion and Uncle Bob decides to use the college fund to pay for a bouncy castle “because the kids looked bored.” Sure, it worked, but now the college fund is short—and Bob’s in hot water. That’s essentially what the US Department of Housing and Urban Development’s (HUD) PIH Notice 2025-14 is trying to stop (minus the bouncy castle). 

In its newly released PIH Notice 2025-14, HUD lays out clear guidance for Public Housing Agencies (PHA) on how to properly manage, report, and safeguard Operating Funds—especially when using centralized accounts like PayMaster or Revolving Fund Accounts. Think of this as the rulebook that keeps Uncle Bob from dipping into the wrong piggy bank. 

This article will share the main takeaways from the Notice. 

What is PIH Notice 2025-14 about? 

The notice is aimed at PHAs managing public housing funds, including those in the Moving to Work (MTW) program. It provides detailed instructions on the acceptable use of Operating Funds, how to structure centralized accounts, and how to avoid misusing restricted funds. 

Key highlights 

• Operating Funds are sacred (and restricted): These federal dollars must only be used for eligible public housing expenses. No crossing the streams with other programs unless HUD explicitly says it's okay. 
• Centralized accounts need guardrails: While PHAs can use pooled bank accounts to streamline spending, they must track every dollar, making sure each program’s money is spent correctly and reported cleanly. 
• New rules for Financial Data Schedule (FDS) reporting: 
  • Certain line items (e.g., Lines 144, 172, 347, 352) now have updated definitions and require justifications if classified as long-term. 
  • Inter-program balances must be settled to avoid being misreported as cash. 
  • Misuse or reclassification of restricted funds could lead to program noncompliance and penalties. 

Best practices required 

To stay compliant, PHAs must adopt strong internal controls and financial management practices. This includes regular reconciliation of accounts, clear documentation for centralized payer accounts, and ensuring that all transactions are authorized, compliant, and properly recorded. Think of it like running your own business—you wouldn’t want your intern paying the electric bill with Monopoly money, right?  

Common pitfalls to avoid 

HUD is clear about what not to do. PHAs should never use Public Housing funds to cover other programs—even temporarily. Advancing funds beyond the allowed expenditure rate is also off-limits. Long-term balances must be documented and justified, and inter-program debts should not be written off without HUD’s explicit approval. 

Consequences 

Noncompliance with these guidelines can lead to serious consequences, including sanctions, repayment obligations, or direct HUD intervention under the US Housing Act. In other words: if you mess up the books, HUD might just shut the whole party down. 

In summary 

PIH Notice 2025-14 is HUD’s reminder that good accounting isn’t optional—it’s essential. By setting firm expectations for how Operating Funds can be used and reported, HUD aims to keep PHAs transparent, compliant, and financially healthy. 

So, before you let Uncle Bob anywhere near your budget spreadsheets, give this notice a thorough read. 

At BerryDunn, we understand that affordable housing organizations are unique and dynamic organizations with specific challenges and opportunities. Our commitment to specialization provides our clients with a team of specialists who understand the complex accounting, regulatory, and tax issues of affordable housing organizations. Learn more about our services and team.