But...you can collect the data and track it for future use if you ever decide to have your consumer loans submitted for consideration in an exam Overloaded. (I believe that was what you were getting at)
One caution on that...I myself collect the data, just in case I'd want to, or have to, use it during an exam. BUT!!! I don't do data integrity on consumer lending at this point, so the data is really just FYI. I wouldn't use it unless I had done a very significant review of it's quality. I'd hate to submit my auto loans under the consumer lending category, (by submit I mean give the data to the examiner during exam time) and then find that the dealer was not reporting income correctly, so while I thought I had a boatload of LMI deals, I really had a boatload of high income deals.