Wow, you guys are sensitive. I guess you missed the that was meant to indicate that my comments weren't all that serious.

Len, it was not my intent to "personally impugn" your motives, and if I came across that way I sincerely apologize.

Don, I did not mean to imply that your comments have less value (although you implied that my comments have absolutely no value because I post anonymously), I was just pointing out that you do have a vested interest in banks continuing their data collection efforts.

You stated that we should have an open civilized debate. Well, let's see, because of my comments you called me ignorant, you called me an idiot, and you said I should grow up. Not very civilized in my opinion.

Don, my earlier post obviously touched a raw nerve, and I apologize for that. It was meant to be a lighthearted comment, but it apparently didn't come across that way. Next time I'll think twice before posting those kinds of comments. Once again, my apologies to both you and Len.

Anon -
Apologies accepted. By the way your comments in an earlier post regarding documenting CD opportunities were very good. I regard the threads as a great opportunity to share ideas and, yes, to stimulate debate. I have no problem with sharing differences of opinion but sometimes it's tricky to convey humor in writing to strangers.
Don and I are competitors in some areas, but I am getting to know him and to appreciate his very long and widespread experience and I certainly respect his opinion which is based not only on his experience as a banker but as a consultant to many bankers. I think that is one of the things Don and I bring to the table. We not only specialize in this compliance area, we see the regulation through the experience of hundreds of our community bank clients. Most BOL readers have experience at 1 or 2 institutions. So I think it is fair to say that we bring a broad perspective and in-depth experience with many community banks that gives very valuable insight into how CRA affects many different bankers in many different parts of the country.

Sorry, I didn't realize I hadn't signed in on that last post

Just to set the record straight, those comments you referred to about documenting CD activities were not mine. They must have come from a different Anonymous poster.

RLCarey
In rereading these threads I caught your question regarding exam frequency which I think is a very good one. In reading the revised reg, I could not find any specific reference to clarify this issue. If intermediates don't get the small bank exam frequency that's one less potential benefit of the revision.

Here's an idea.....

Intermediate Banks can go back to the 12 Assessment Factors!

Start keeping memos of all those meetings with High School Principals, Chambers of Commerce, local Neighborhood Housing groups......

We called it CRA by the foot!

Oh - and who can forget loan to deposit ratios for EACH census tract!!!!! Ouch!

I'm getting nostalgic for my wall map with the stick pins: Green for deposits, blue for loans, and orange for declines.