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#1388045 - 05/07/10 08:24 PM Switching Exam Options
BNKO Offline
100 Club
Joined: Sep 2009
Posts: 213
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?

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CRA
#1388248 - 05/10/10 01:38 PM Re: Switching Exam Options BNKO
Midwest Banker Offline
Gold Star
Joined: Nov 2004
Posts: 349
Cheeseland
We are FED, so this may not help, however we ran into the same situation. We were being examined under the large bank test, then switched to small intermiediate (mistake for us) and then went back to large bank test and have stayed there ever since.

We explained to our examiners why we did make the initial change and the reasoning for going back (and sticking with) the large bank option. They were completely understanding and supportive.

The key is communication. We keep copies of any and all communincations about this in case there were any questions in the future

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#1388369 - 05/10/10 03:39 PM Re: Switching Exam Options Midwest Banker
BNKO Offline
100 Club
Joined: Sep 2009
Posts: 213
Midwest Banker,

Did you actually send some type of official "election" letter to the FED, when you decided to switch from large to ISB? I'm just trying to understand if there are any official notification requirements that need to be made, or if documenting our election option in our CRA policy is sufficient.

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#1388405 - 05/10/10 04:25 PM Re: Switching Exam Options BNKO
AnonRegulator Offline
Gold Star
AnonRegulator
Joined: Mar 2002
Posts: 451
Everywhere, USA
This is similar to changes in your AA. You don't have to send an official notification or election letter to your regulator, but as MW Banker said, communication is the key, meaning the sooner you let your regulator know of your election, the better for everyone. Technically, you could wait until the examiners walk in the door for your CRA exam to tell them, but why do that? Knowing your intention well in advance helps them with scheduling of adequate resources for the exam, and focus any offsite analysis they do, making for a more efficient onsite visit. AR.

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