prefacing this question with I am new to CRA..

we are a 1 branch bank located in a fairly wealthy county ( only 3 census tracts considered low income, and about 10 low-moderate out of 300 + tracts). Our business model is that of a commercial bank, in that we do very little consumer lending ( less than 8% of our lending volume and that is usually as an accomadation to our business owner clients).
I am working through the small bank exam and rapidly coming to the conclusion we do not have a sufficient number of loans to small businesses under $1 mil.. is there any damage control we can do (i.e. other things we could slice and dice to help us pass the next exam-likely spring sometime)... any help/suggestions would be greatly appreciated!

You can:

>do an analysis, including a needs analysis, to show that the loans you do make that may not be in the small business loan category but are to businesses with revenue of $1 million or less are responsive to the credit needs in your community (construction loans, letters of credit, etc.)

>purchase small business loans from other banks

>participate in a loan fund that makes loans to small businesses (many areas have these and some of the loans have guarantees from a government entity, such as the county)

>provide funding to CDFIs or minority/women owned banks in your area (if any) earmarked for small business loans.

Look for other ideas along these lines.

thank you so much for your suggestions,

we do have a couple of minority owned banks in the area so will explore that option as well as your other suggestions.