In my on-going saga to pick up where someone left off, i see where we chose to be examined under intermediate small. is there somewheres where it explains the differences between, small, large, inter. small bank and how the examination criteria differs? I didn't see anything in Reg BB. Don't know where to begin to look undder FFIEC page, expect is it in the FAQs???

You will find this Guide to be extremely helpful.

All banks are subject to almost identical Lending tests. ISB's are subject to a Community Development activities test (community development lending, service and investment) in addition to the lending test. And the Large Banks are examined for Lending, Service and Investment tests.

An ISB undergoing a CRA exam must pass both the lending test and the community development test. I believe the ISB's have the toughest challenge because of the importance of the CD test in comparison to Large Banks which have a 24 point system and need to attain only 11 points to earn a composite "satisfactory" performance evaluation.

based on what you said, Len, why would a bank want to be examined under the ISB level. We are almost $1 billion. Might it be better if we went for the large bank level?

It would depend on your confidence in your CD activity. If you have a comfortable level of activity (and you are competent to know what qualifies for CD credit under the Regulation) then you may want to be examined as an ISB. But if you are not confident about your CD activity then I would suggest you consider being examined as a Large Bank. But in order to do so you must have voluntarily filed your annual CRA data. If you haven't filed, it's a moot point and you will be examined as an ISB. But going forward you may want to do so. If you are a growing bank it may be only a few years off anyways, and this will allow you to develop experience filing while it is not yet mandatory.

Len, when you say "voluntarily filed CRA data" what are you referring to: I thought banks had to file certain CRA data as of 3/1 of every year. What am I missing? As an ISB at the present, we were not responsible/required to file the data? Are we talking about data different than the info due 3/1? I'm not seeing this spelled out in the Reg. Should I look at the FAQs?

The only banks required to file their CRA data each year are the so-called large banks (effective Jan 1, 2010 the asset size threshold would be $1.098 billion). Any other bank may file voluntarily.

HMDA filings are another matter. Many banks that are not required to file under CRA must file their HMDA data under HMDA.

So, if we have been examined under the IS bank level, we are not required to file the loan report sited in the Guide. HMDA data, of course, will be reported as usual. I was interpreting the Reg section on reporting to mean that all banks are required to provide the loan data....yeah! something clarified for me at last!

Trees, did you say earlier that your bank had chosen to be examined as a large bank? If that was not correct, and you are being examined as an ISB, you are not required to submit but should prepare (geocode, categorize, evaluate) your loan data so that you are in control and can explain your performance at exam time.

OK, thank you MS Kaybee. I read through the last report and the examiners identified us as an Intermediate small. A choice that must have been made a couple years back. I will certainly have the backup avail, as you suggested. But, if i can "buy some time" and not have to report data on 3/1 that will help me to get a better hold on what I am supposed to be doing!

As an ISB, the only data you are required to report by 3/1 is your HMDA data.

Thanks Plum.