As our SMALL bank prepares for our CRA exam, which MFI should I use to document our loans to LMI borrowers? 2000 Census MFI or HUD 2005 estimated MFI?

Which will the OCC use?

For the purposes of Geographic Income Levels you use the 2000 Census MFI. For the individual income levels, you would use the HUD Estimated MFI for the year of the account being opened. So, for loans opened in 2004 you would use the 2004 HUD estimate, and for loans opened in 2005 you would use the 2005 HUD estimate.