We were a large bank last year and have now become an intermediate small bank. I would assume we remove the CRA Disclosure Statements we currently have in our CRA Public File and replace them with the loan-to-deposit ratios for each quarter of the prior year ... per the small bank public file requirements. Is this a correct assumption?

I'm not one for tossing final documents (the CRA disclosure statement) but it's an option. That I'd want to discuss with my examiner. It should be fine, but I'm a little wierd about stuff like that I am always afraid that they'll say something like "well the reg required it for year 2005 so why wasn't it there in 2005, even if we're not looking at it" (ok I'm paranoid)

But, I'd go backwards on thoe LTD ratios and include them in the file from your last exam period on. Bascially it's over compliance (keeping the disclosure as well) but it's easy over compliance so why not?