As it relates to small dollar loans or similar activities liken to the FDIC’s Affordable small dollar loan program, how much CRA credit does an institution actually get?

Our bank’s lending is primarily small business & farm lending. Consumer lending makes up less than 25% of our lending and of that, unsecured is (maybe) 3 to 5 %, if that.
We do not have a small dollar loan PROGRAM and we, by policy, do not make “pay-day” loans.
However, our CRA examiner has requested a list of our unsecured loans under $2,500 and all loans under $1,000 (secured or not) so that he can evaluate us for CRA credit.
He says it is not required and is just offering the option.

Since we do not have a program and the task of compiling this data will take man-hours away from other important tasks at hand, is it even worth try to obtain CRA credit?
Last exam we received an Outstanding primarily due to our Small business & farm loans and our community development lending. Consumer lending did not play a part, at least per the P.E.

Any advice?

There are two issues here. First, you asked how much credit a bank would get for a small dollar program. This is a frequent question of examiners regardless of the type of program. There is no pat or formulaic answer for this, but in deciding how much credit to give, we need to know the impact of the program. For example, how many people did it reach? In this case, how did it help them with their credit history or in helping to reach the unbanked and establish a banking relationship? Give some context to the program and chances increase for increased credit, although we don't assign an acutal number to that credit.

Second, you hit the issue on the head by asking about the relevance of consumer lending when you are a small business and farm lender. If your borrower distribution is similar to that of the last exam when you were rated Outstanding, and still compares very well against your assessment area demographics, I wouldn't bother with small loans that will probably have small impact and for which the data gathering would offset any benefit to you.

It was nice of the examiner to want to go the extra mile for you, but I think I'd ask them what concerns they have about your CRA performance that they feel the need to ask about small loans. AR.