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#476254 - 12/29/05 09:05 PM CRA Mixup Here
Compliance A2Z Offline
Member
Compliance A2Z
Joined: Dec 2005
Posts: 56
I am new to my Bank here since October and just found out today that back in August our Bank had stopped reporting CRA Data. I don't think they understood the "option" of changing to an ISB or keeping our option open when they stopped our CRA Procedures. I have talked with Management (My Boss & the Owner) since I've been here and they were counting on me as their CRA Officer to get my arms around the CRA Program and with my research and reading your posts here, I think it is to our best interrest to continue to report as a large bank (since we know we rate well) and keep our options open until we know we can pass the Community Development Tests and know for sure that we will rate well under ISB BEFORE making the change. Am I on the right track here? Thoughts?

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#476255 - 12/29/05 09:20 PM Re: CRA Mixup Here
Compliance A2Z Offline
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Compliance A2Z
Joined: Dec 2005
Posts: 56
Addition: Management wasn't aware of the "option" in September and would we need to re-track our steps if we do not wish to be an ISB?

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#476256 - 12/29/05 09:55 PM Re: CRA Mixup Here
Don_Narup Offline

Power Poster
Joined: Jul 2001
Posts: 3,708
Las Vegas Nevada
Bummer but you will need to collect data from where you left off in August and report the full year prior to March 1st 2006.

Yes IMO you are on the right track
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#476257 - 12/29/05 09:58 PM Re: CRA Mixup Here
Len S Offline
Diamond Poster
Joined: Oct 2004
Posts: 2,084
Connecticut
You are taking the prudent course of action. By collecting the data for the remainder of the year and reporting it you are preserving your right to be evaluated under the familiar tests under which you have performed successfully the last 10 years. As long as you have reported your annual data you will have the option to be evaluated under either the ISB or the Large Bank test. It's a no-lose proposition.
Technically you didn't stop reporting data in September because you report only once per year at the end of February. You may have stopped collecting the data on September 1. But you can resume your old data collection system and collect the data for the balance of the year and then submit your entire year's data before March 1, 2006 and you will be ok.
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#476258 - 12/29/05 10:02 PM Re: CRA Mixup Here
Compliance A2Z Offline
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Compliance A2Z
Joined: Dec 2005
Posts: 56
Thank you Len.

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