We have always been a large bank, but recently fell beneath the threshold, and are now considered an intermediate small bank. We believe it's in our best interest to continue being examined under the large bank exam option (lending, investment, service tests), will continue reporting SB/SF loan data, and have outlined this in our CRA policy.
If, however, we decide we want to be examined using the ISB test (lending/CD), do we need to notify the OTS of this and is there a timeframe for doing so? I can't find anything in the regulation that requires this.
Does anyone have any experience with this?