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In today’s increasingly digital environment, cybersecurity has become a critical concern for nonprofit (NFP) organizations. While many NFPs operate with smaller teams and tight budgets, they still handle sensitive information—donor records, payment data, client demographics, and sometimes even health‑related or financial assistance files. Unfortunately, cybercriminals recognize this and often view NFPs as soft targets with valuable data. Because community trust is so important, a cybersecurity incident can create financial and reputational hurdles for an organization. The good news, however, is that strong cybersecurity foundations do not always require major capital investments. With strategic planning and a focus on essential controls, even the most resource‑constrained organizations can significantly reduce cyber risk. 

A new federal executive order aimed at eliminating fraud, waste, and abuse signals a clear shift for healthcare and not-for-profit organizations that receive federal funds. While oversight of federal programs is nothing new, this order formalizes a cross-agency task force and raises expectations around documentation, internal controls, and accountability, particularly for organizations that participate in Medicaid, Medicare, and federal grant and assistance programs.

Beginning with calendar year 2026, public housing agencies (PHAs) will be required to submit an annual Federal Financial Report (SF-425) for each operating subsidy grant. Reporting will continue annually until all funds are fully expended or returned to HUD. These changes reflect HUD’s increased focus on transparency, grant life cycle oversight, and compliance monitoring.

To quote George R. R. Martin, “Different roads sometimes lead to the same castle.” The same can be said for Schedule A. When it comes to qualifying as a public charity, the IRS offers more than one path forward. In Part I of this series, we explored the Schedule A Part II public support test—a common route for donor‑supported organizations. In this second installment, we turn to the Schedule A Part III test, an alternative approach designed for organizations that operate under a fee‑for‑service or program‑revenue model. While the tests are different, both can ultimately lead to the same destination: public charity status. 

This is the first in a two-part series that provides a detailed examination of Form 990, Schedule A, offering practical guidance to the many organizations responsible for its complete and accurate preparation. This article focuses on organizations that qualify under Part I, Line 7 – 509(a)(1) – and the steps required to substantiate this classification through the Part II public support test. 

Charitable organizations play a vital role in addressing social issues, supporting communities, and promoting public welfare. As part of their mission, these organizations often make direct charitable expenditures to fund projects, provide services, and support individuals in need. However, with the privilege of tax-exempt status comes the responsibility to ensure that funds are used appropriately and in compliance with regulatory requirements. One crucial aspect of this compliance is expenditure responsibility, a concept that ensures charitable resources are used for their intended purposes. 

The Governmental Accounting Standards Board (GASB) issued Statement No. 105, Subsequent Events to enhance the transparency, consistency, and value of financial reporting related to events that occur after the financial statement date, but before the financial statements are issued. The statement realigns existing guidance by clearly describing the subsequent events' time frame, distinguishing between recognized and non-recognized subsequent events, and providing specific disclosure requirements. 

Rolling out new software isn’t just clicking “Install” and calling it a day. It’s more like planning a wedding. There’s the venue (servers), the guests (users), and yes, the unexpected costs that show up like distant relatives. In today’s digital-first world, implementing software is a strategic investment that can boost efficiency, strengthen compliance, and support long-term growth. However, the true cost goes beyond the sticker price on that shiny new platform. For nonprofits operating on limited budgets, careful planning is essential to avoiding hidden costs when making a technology upgrade. 

The affordable housing landscape in the United States is on the cusp of significant change with the introduction of the Renewing Opportunity in the American Dream (ROAD) to Housing Act of 2025. For nonprofit organizations operating in the affordable housing sector, this proposed legislation brings both new opportunities and important considerations. Here’s what you need to know. 

Liquidity is the lifeline of any nonprofit organization. Strong liquidity ensures uninterrupted programs, financial stability, and the flexibility to respond to unexpected challenges. This article shares practical steps to monitor and manage liquidity effectively, including setting clear policies, tracking cash flow, using key financial ratios, managing reserves, and leveraging technology. By following these best practices, organizations can maintain resilience, build trust with stakeholders, and stay focused on their mission—even during uncertain times.

Private foundations are vital players in the philanthropic landscape, channeling resources toward charitable, educational, and scientific causes. However, to maintain their tax-exempt status and avoid excise taxes, these organizations must comply with strict IRS rules—particularly those governing qualifying distributions. In the second installment of our trilogy, we will follow the McQueen Family Foundation to determine their qualifying distributions. As a non-operating foundation, this is a crucial step in their annual compliance requirements. 

The Minimum Investment Return (MIR) is a critical component for all private foundations. It is a standardized calculation based primarily on the value of the foundation’s investment (i.e., non-charitable use) assets to ensure that endowments are put to charitable use rather than accumulating excessive wealth with little to no public benefit. By adhering to IRS guidelines and maintaining diligent records, foundations not only avoid costly penalties but also contribute meaningfully to the communities and causes they support. 

A new Executive Order issued by President Donald Trump on August 7, 2025, brings major changes to how federal agencies handle discretionary grants. Titled "Improving Oversight of Federal Grantmaking," the changes in this Order introduce more political oversight, tighter controls on how funds are used, and new compliance rules that will directly affect organizations receiving federal funding. 

Capital campaigns can be game changers for nonprofits, enabling bold investments in infrastructure, programs, and long-term growth. Whether you're building a new facility, expanding services, or upgrading technology, a capital campaign aligns fundraising with your strategic vision. 

Signed into law by President Trump on July 4, 2025, the One Big Beautiful Bill Act (OBBBA) marks a significant step forward in addressing America’s growing need for affordable housing. With the demand for low-cost units far outpacing supply nationwide, the legislation offers targeted solutions aimed at making development more feasible and sustainable.

As artificial intelligence (AI) becomes increasingly woven into nonprofit operations, boards are stepping into a new and critical role. Traditionally focused on mission oversight and fiscal responsibility, today's boards must also shape how AI is introduced, governed, and aligned with the organization’s values. Below are the seven most important actions a board can take to ensure responsible and strategic AI implementation. 

Credit, purchase, and debit cards each offer convenience for small-dollar purchases, but carry varying levels of risk. Strong internal controls are essential to prevent fraud, misuse, and compliance violations.

Nonprofit leaders must assess the risks and strategically position their organizations to adapt to changing funding landscapes. This article outlines key steps to help your organization proactively evaluate funding vulnerabilities, mitigate risks, and plan for sustainable operations. 

With default federal student loan collections now resumed by the Department of Education, higher education institutions and other effected nonprofits need a strategy to ensure compliance. 

Most nonprofits rely on federal and state government funds to fulfill their missions. With a federal funding freeze in the headlines, many clients are asking us how they can best prepare for a freeze and protect their organizations if funding is cut. Here are three steps you can take today to stay ahead. 

As the new year begins, your organization may be starting to plan for your next fundraising event. In addition to raising money for the organization, fundraising events are a wonderful way to build relationships within the community, raise awareness for a cause, and provide a meaningful experience to donors. Beyond the excitement and benefits of these events, there are important Form 990 reporting and compliance requirements that you must consider. Below are the most frequently asked questions we receive from our clients. We hope this helps you avoid some common pitfalls around fundraising events.

Is your nonprofit using a break-even bottom line as your ultimate budget goal? If so, you may be missing out on opportunities to strategically further your mission. By looking at your budget using a statement of financial position perspective, rather than just a profit and loss perspective, you can gain a more complete financial picture of your organization.

As organizations navigate the complexities ahead in 2025, economic uncertainty presents both challenges and opportunities. Organizations must strategically address financial stability, donor engagement, federal compliance requirements, and workforce management to sustain their missions. This article dives into five critical finance trends and explores how nonprofits can effectively adapt.

The housing industry is subject to ongoing regulatory changes that are critical to their operations. Recently, we shared changes impacting compliance for multifamily housing, but that's just one example; all facets of the industry are subject to ongoing changes to compliance.

If it’s been a while since your nonprofit organization last conducted a review of its governing documents and policies, worry not, you’re not alone! This article will highlight a few of the most critical documents applicable to nonprofits to ensure you remain in compliance and good standing.

The United States Department of Housing and Urban Development (HUD) signed the Housing Opportunity through Modernization Act (HOTMA) into law on July 29, 2016. For multifamily housing owners, HOTMA went into effect on January 1, 2024, and owners are expected to be fully compliant by January 1, 2025.

Not-for-profit board members need to wear many hats for the organization they serve. Every board member begins their term with a different set of skills, often chosen specifically for those unique abilities. As board members, we often assist the organization in raising money and as such, it is important for all members of the board to be fluent in the language of fundraising. Here are some basic definitions you need to know, and the differences between them

Of all the changes that came with the sweeping Tax Cuts and Jobs Act (TCJA) in late 2017, none has prompted as big a response from our clients as the changes TCJA makes to the qualified parking deduction.

A capital campaign is a big undertaking. During the planning stage of a capital campaign you need to not only focus on your donor outreach strategy, but also on outreach materials. 

Good fundraising and good accounting do not always seamlessly align. While they all feed the same mission, fundraisers work to meet revenue goals while accountants focus on recording transactions in compliance with accounting standards. 

As 2018 is about to come to a close, organizations with fiscal year ends after December 15, 2018, are poised to start implementing the new not-for-profit reporting standard. Here are three areas to address before the close of the fiscal year to set your organization up for a smooth and successful transition, and keep in compliance:

With the wind down of the Federal Perkins Loan Program and announcement that the Federal Capital Contribution (FCC) (the federal funds contributed to the loan program over time) will begin to be repaid, higher education institutions must now decide how to handle these outstanding loans.

Last week, in addition to The Eagles Greatest Hits (1971-1975) album becoming the highest selling album of all time, overtaking Michael Jackson’s Thriller, the IRS issued Notice 2018-67—its first formal guidance on Internal Revenue Code Section 512(a)(6).

Over the course of its day-to-day operations, every organization acquires, stores, and transmits Protected Health Information (PHI), including names, email addresses, phone numbers, account numbers, and social security numbers.

Recently the Governmental Accounting Standards Board (GASB) finished its Governmental Accounting Research System (GARS), a full codification of governmental accounting standards.

As we begin the second year of Uniform Guidance, here’s what we’ve learned from year one, and some strategies you can use to approach various challenges, all told from a runner's point of view.

When it comes to offering non-qualified deferred compensation to executives of not-for-profit organizations, there aren’t many options.

With the implementation of GASB 72 now in full force, GASB organizations are hard at work drafting their new fair value disclosures. The addition of a fair value hierarchy table in the footnotes will add a bit more thickness to a likely already hefty financial package. 

Why it can happen to you and how to protect yourself. We’ve all seen the headlines. Stories about not-for-profit fraud have been popping up in the news, and the statistics confirm what you might have suspected: fraud in the not-for-profit sector is on the rise.

Read this article if you are a compliance officer, risk manager, or healthcare administrator in an ambulatory care practice, federally qualified health center, or rural health center and have responsibility for developing your organization’s workplace violence prevention program or complying with state reporting requirements.

Did you know workplace violence is increasingly prevalent in the healthcare industry? If your organization doesn’t have a plan, it might be time to consider one. This article addresses the definition and types of workplace violence, regulations, plan elements, and other considerations. 

Workplace violence in healthcare by the numbers 

Data from the US Bureau of Labor Statistics shows that prior to the COVID-19 pandemic, the incidence rate of nonfatal workplace violence to full-time healthcare workers was 10.4 per 10,000 in comparison to an all-worker rate of 2.1 per 10,000. In 2018, healthcare workers accounted for 73% of all nonfatal workplace injuries and illnesses due to violence.

Post-pandemic, the Bureau of Labor Statistics reported that healthcare and social assistance workers experienced the highest counts and annualized incidence rates for workplace violence of any private industry sector over the two-year period from 2021 – 2022. There were 41,960 total nonfatal cases of workplace violence requiring days away from work, job restriction, or transfer in the healthcare and social assistance industry over this time, accounting for 72.8% of all cases in private industry over the two-year period. These cases occurred at an annualized incidence rate of 14.2 cases per 10,000 full-time workers.

How is workplace violence defined?  

In its 2024 Comprehensive Accreditation Manual for Behavioral Health Care and Human Services Glossary, The Joint Commission (TJC) defined workplace violence as, “Any act or threat occurring in the workplace that can include any of the following: 

  • Verbal, nonverbal, written, or physical aggression 
  • Threatening, intimidating, harassing, or humiliating words or actions 
  • Bullying 
  • Sabotage 
  • Sexual harassment 
  • Physical assaults 
  • Other behaviors of concern involving staff, licensed practitioners, patients, or visitors”    

How is workplace violence classified? 

The Institute for Healthcare Improvement (IHI) is a leading, globally recognized, nonprofit healthcare improvement organization that has been applying evidence-based quality improvement methods to meet healthcare challenges for more than 30 years. In its Framework for Standardized Data Collection of Workplace Violence Incidents in Health Care, the IHI classifies workplace violence incidents into five distinct categories: 

  • Type 1: The offender has no connection to the workplace or its employees. 
  • Type 2: The offender is a customer or patient associated with the workplace or its staff. 
  • Type 3: The offender is a current or former employee of the organization. 
  • Type 4: The offender maintains a personal relationship with employees but has no ties to the workplace itself. 
  • Type 5: Violence motivated by ideological, religious, or political beliefs targeting a healthcare facility, its personnel, or property. This type is carried out by extremists or groups driven by their convictions. 

Have you developed a workplace violence prevention program? 

Key aspects of your healthcare organization’s or practice group’s program should include: 

  • Conducting an environmental risk assessment 
  • Contacting local law enforcement to build or enhance relationships 
  • Performing trend analysis of reported incidents by site, location on the premises, day of week/time of day, and classification type    
  • Obtaining feedback from staff: What do they consider to be reportable? This will help you develop meaningful training
  • Recognizing staff champions while building the program  
  • Testing your reporting system 
  • Providing staff training, soliciting anonymous feedback, and identifying any unresolved questions  
  • Identifying program gaps and developing remediation strategies 
  • Keeping executive leadership and the Board regularly informed about the program and emerging trends or needs 

Which states require employer-sponsored workplace violence prevention programs? 

Two factors have led states to establish requirements for healthcare organizations to develop workplace violence prevention programs. The first reason for state action: There has been no corresponding action by the federal Occupational Safety and Health Administration (OSHA). Secondly, the proposed Workplace Violence Prevention for Health Care and Social Service Workers Act has not been enacted by Congress.  

As of January 2026, 20 states require mandatory workplace violence prevention plans or workplace safety* plans. These are Arizona, California, Connecticut, Illinois, Hawai’i, Kentucky*, Louisiana, Maine*, Maryland, Minnesota, Nevada, New Hampshire, New Jersey, New York, Ohio, Oregon, Texas, Vermont, Virginia, and Washington. 

In addition, seven states now require mandatory reporting of workplace violence incidents to a designated state agency. These states are California, Connecticut, Maryland, Montana, North Carolina, Oregon, and West Virginia.

BerryDunn can help 

Has your healthcare organization developed a workplace violence prevention plan? If yes, has it been reviewed recently? How do you train your staff to respond when a situation escalates? How do you analyze incidents? Do you have questions about your healthcare organization’s compliance with state requirements for submitting its plan?  Does your state require you to submit incident reports to a designated state agency? 

Our healthcare compliance team can help. We incorporate deep, hands-on knowledge with industry best practices to help your organization manage compliance and revenue integrity risks. Learn more about BerryDunn’s healthcare compliance consulting team and services. 

Additional resources for workplace violence prevention planning: 

Article
Key insights on healthcare workplace violence prevention plans

As we previously wrote about, on February 20, 2026, the US Supreme Court invalidated tariffs imposed under the International Emergency Economic Powers Act (IEEPA).

Last week, the US Customs and Border Protection (CBP) announced a new process that allows importers to request refunds of those tariffs. We'll walk through how to actually claim refunds, what to expect from the process, and where complications can arise.

About the CAPE tariff refund system

CBP’s new system, called CAPE (Consolidated Administration and Processing of Entries), is an added functionality accessed through the existing ACE (Automated Commercial Environment) Portal, which most importers already use for customs reporting.

How to request a tariff refund

To submit a refund claim, importers should take the following steps:

  • Confirm that your importer information and ACE Portal account are active and up to date.
  • Ensure you are enrolled in ACH Refund (required to receive refund payments).
  • Note: If you do not already have an ACE Portal account, be aware that setting one up can take several weeks.

Refund requests are submitted by filing a CAPE Declaration in the ACE Portal. This declaration is a spreadsheet‑style (.CSV) file listing entries eligible for refunds of IEEPA tariffs. Each declaration can include up to 9,999 entries, with additional filings required for larger volumes. CBP provides guidance on how to prepare and submit this file.

Which imports qualify for tariff refunds?

At this time, refund claims are only available for:

  • Unliquidated entries
  • Entries liquidated within the past 80 days

Other types of entries are currently excluded from the CAPE process. CBP has indicated that future system expansion may allow for the submission of additional types of claims beyond the above. Importers are encouraged to consult with their customs broker or advisor(s) to determine whether any of their imports fall into excluded categories and whether additional steps are needed to protect refund claims.

How long does the refund process generally take?

Once a CAPE Declaration is submitted:

  • The invalid IEEPA tariffs are removed.
  • Duties are recalculated as if those tariffs never applied.
  • Refunds including 6% interest are automatically calculated.
  • Payments are made via ACH, generally within 60 – 90 days after acceptance of the CAPE Declaration.

How BerryDunn can help

Our dedicated audit, tax, and consulting professionals understand the impact of tariffs and can assist with developing strategies for refunds as they become available. Learn more about our team and services.

Article
How to claim tariff refunds after the Supreme Court ruling

In today’s increasingly digital environment, cybersecurity has become a critical concern for nonprofit (NFP) organizations. While many NFPs operate with smaller teams and tight budgets, they still handle sensitive information—donor records, payment data, client demographics, and sometimes even health‑related or financial assistance files. Unfortunately, cybercriminals recognize this and often view NFPs as soft targets with valuable data. Because community trust is so important, a cybersecurity incident can create financial and reputational hurdles for an organization. The good news, however, is that strong cybersecurity safeguards do not always require major capital investments. With strategic planning and a focus on essential controls, even the most resource‑constrained organizations can significantly reduce cyber risk.

The cyber threat landscape for nonprofits 

NFPs face a wide variety of cyber threats, many of which exploit human error or outdated systems. Phishing attacks remain the most common, often leading to credential theft or unauthorized access to email accounts. Business Email Compromise (BEC) schemes, which can trick employees into sending fraudulent payments or sensitive data by impersonating trusted email addresses, can be particularly damaging for smaller organizations with smaller internal control structures. Beyond causing operational slowdowns, a breach can make donors and other stakeholders more cautious and raise understandable questions. 

Practical, low‑cost cybersecurity strategies 

Despite limited budgets, NFPs can meaningfully enhance their cybersecurity position by focusing on high‑impact, low‑cost strategies. 

Strengthening governance is a key first step. Establishing basic cybersecurity policies—such as acceptable use, password standards, and incident response—creates a foundation for consistent practices across employees and volunteers. Free frameworks, like the NIST Cybersecurity Framework resources, designed originally for government use, but applicable to many organizations, provide a helpful starting point, including a Quick Start Guide for small businesses.

Next, NFPs can maximize the value of technology they already own. Many cloud platforms commonly used in the sector, such as Microsoft 365 and Google Workspace, include built‑in security features at no extra cost. Enabling multifactor authentication (MFA), automatic software updates, and email filtering tools can significantly reduce the likelihood of a successful cyberattack. Removing unused accounts and reviewing permissions helps ensure attackers don't exploit dormant access. We recommend a formal user access review at least annually for small organizations and quarterly for medium-sized organizations or if there is higher turnover at a small NFP. 

Because many cyber incidents stem from unintentional mistakes, training is one of the most cost‑effective defenses. Free or low‑cost cybersecurity awareness programs can be incorporated into onboarding for staff and volunteers. Regular reminders about phishing, safe browsing, and password practices—combined with simple processes for reporting suspicious activity—create a culture of security without significant expense. 

Data protection is another essential component. Tracking where sensitive data resides and limiting access to only those who need it helps reduce exposure. Continuously testing that cloud-based backups are working effectively can ensure critical information is recoverable in the event of a ransomware attack or system failure. We recommend testing data backups at least quarterly, especially with your cloud vendors, to help ensure their responsibilities around data are being upheld.  

Finally, NFPs can leverage outsourced support and community resources. Many managed service providers offer NFPs pricing, and state or local government programs sometimes provide free cybersecurity assessments or monitoring tools. These partnerships allow small organizations to access expertise they may not be able to hire internally. 

The path to cost-effective cybersecurity 

Effective cybersecurity is achievable—even for NFPs with limited resources. By focusing on governance, human awareness, existing technology, and targeted use of outside support, NFPs can build a resilient security foundation without heavy financial investment. With the right culture and controls in place, organizations can protect their data, safeguard their reputation, and continue advancing their mission with confidence.

BerryDunn can help 

We help organizations understand their cybersecurity risk environment and translate threats into leadership-ready insights. Our consultants guide you in identifying actionable next steps, gaining engagement and buy-in from key decision-makers. With deep experience across sectors, we deliver practical cybersecurity solutions tailored to your systems and compliance needs. Learn more about our team and services. 

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Cybersecurity risk strategies for cost‑conscious nonprofits

For many people, charitable giving is deeply personal, motivated less by tax considerations and more by values and a connection to a cause or organization. While tax benefits are rarely the primary reason people give, understanding how charitable contributions may affect your taxes remains important. 

Tax benefit for charitable giving 

Generally, a tax benefit for charitable giving was only available to taxpayers who itemized their deductions. In 2017, with the passing of the Tax Cuts and Jobs Act, the standard deduction was increased and the state and local tax (SALT) deduction was capped at $10,000. These changes made it more beneficial for some taxpayers to shift from itemizing their deductions to taking the standard deduction. This shift essentially removed the federal tax benefit for charitable giving for such taxpayers. For some, this put charitable giving on the sidelines, either by reducing giving, not giving to qualified public charities, or simply not keeping track of their giving. 

2026 charitable tax benefit with standard deduction 

Beginning in 2026, a permanent change expands the charitable tax benefit to taxpayers who take the standard deduction. Under the One Big Beautiful Bill Act, non-itemizers may now claim an above-the-line charitable deduction up to $2,000 for married taxpayers filing jointly (or $1,000 for single filers).  

To qualify to take this deduction, a few requirements must be met: 

  • The donation must be cash 
  • The donation must be made to a qualified public charity 
  • The donation cannot be a contribution to a donor-advised fund 

Some important reminders: 

  • Documentation is a must. Acknowledgment letters are a good form of documentation. 
  • Verify the organization you are donating to is a qualified public charity. One common mistake some taxpayers make is assuming online crowdfunding fundraisers are qualified public charities.   
  • Remember to provide your charitable giving information to your tax professional.   

Admittedly, the change is modest, not transformational, but it does broaden the number of taxpayers who benefit from donating to charity. It is important to keep in mind that each individual taxpayer’s situation is unique. State tax implications must also be considered, as not all states follow federal tax law.  

BerryDunn can help 

Our seasoned tax professionals partner with you to offer practical, accessible guidance and to develop a detailed strategy that supports your unique needs. We excel at tax strategy and solutions, placing an emphasis on building long-term relationships. Our deep expertise spans a full range of tax concerns, tax services, and consulting to support individuals, businesses, and nonprofit organizations. Our consultants are specialists in their industry, working closely with their colleagues across the firm to deliver integrated, comprehensive solutions. Learn more about our team and services.

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New charitable giving tax opportunity for 2026 non-itemizers

Read this if you are a chief financial officer or controller at a community bank.

On April 23, 2026, the federal banking agencies—the Office of the Comptroller of the Currency, the Federal Reserve, and the Federal Deposit Insurance Corporation—issued a final rule revising the Community Bank Leverage Ratio (CBLR) framework. The changes are intended to encourage broader adoption of the CBLR framework while maintaining strong capital standards for qualifying community banks.

What are the key changes under the final rule? 

Lower CBLR requirement 

  • Threshold lowered from 9% to 8% 
  • Likely increase in community banks that qualify for the simplified CBLR framework rather than the more complex risk‑based capital rules

Expanded grace period 

  • Grace period for banks that temporarily fall out of compliance with the CBLR qualifying criteria extended from two quarters to four quarters, provided the bank maintains a leverage ratio above 7% 
  • Institutions may remain in the CBLR framework while reestablishing compliance or transitioning back to the risk‑based capital framework

Limits on repeated grace period use 

  • Grace period use is limited to no more than eight quarters during the prior five-year (20‑quarter) period to preserve safety and soundness 
  • Institutions exceeding the threshold must immediately comply with risk‑based capital requirements if they again fall out of CBLR compliance

The final rule is effective July 1, 2026.

Why does this matter for community banks?  

Regulators expect these changes to reduce regulatory burden, provide banks with additional balance sheet flexibility, and increase capacity for community lending—while keeping capital levels consistent with well‑capitalized standards. For banks currently near the prior 9% threshold or concerned about short‑term capital volatility, the revised framework may make the CBLR a more practical and sustainable option. 

Key takeaways

  • Broader CBLR adoption: The lower qualifying threshold means more community banks can opt into the simplified CBLR framework. 

  • Grace period expansion: Banks have a longer runway to recover from temporary shortfalls without needing to revert to the risk-based capital framework. 

  • Grace period restrictions: Limitations have been added to avoid reliance on grace period use. 

  • Compliance relief: The changes are meant to ease compliance burden while facilitating consistent capital levels.  

BerryDunn can help

Our dedicated audit, tax, and consulting professionals understand the financial services industry and its challenges and are committed to helping you meet and exceed regulatory requirements. We partner with you to bring tailored approaches to fit your needs and operations and provide guidance on best practices and recommendations that make sense for you. Learn more about our services and team. 

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Federal banking agencies revise Community Bank Leverage Ratio framework