Subject to Lending Test & Reporting Requirements?
by David Dickinson, BOL Guru Guru BIOS
Question: Does a bank with less than 100 million in assets and a holding company with assets below 1 billion have any reporting obligation under CRA or HMDA? Is the bank subject to any type of test such as the lending test?
Answer: CRA: Your bank is a "small bank" for CRA. You have no data reporting requirements unless you opt out of the streamlined process. Despite the streamlined process, small institutions will still be evaluated based on their performance, particularly their lending performance within their delineated assessment area(s).
HMDA: Any bank that has either a home office or a branch office in a metropolitan area and has total assets of $34 million or more is subject to HMDA. Refer to §203.2(e).
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