We've been lucky for several years, to have remained classified a small bank for CRA purposes. However, with OTS adopting the Intermediate Small Bank designation, we now fall into that category. We've been rated Outstanding for our last two exams under the small bank standards. Is anyone aware of a spreadsheet or similar tool that has a side-by-side comparison of the CRA requirements for the two so that I can easily see what we need to do? TIA!

The biggest difference is going to be your need to get a satisfactory rating on "community development" activities. As a small bank this was not an issue, but with ISB's this is absolutely critical because you must get a satisfactory performance rating on your community development activities in order to be eligible for a composite satisfactory PE. (unless you voluntarily file and maintain your elective to be evaluated under the Large Bank Tests)