I came from a small bank that collected and documented all CRA data as if we were a reporting bank. Examiners spent very little time on CRA review. Recently moved to a new small bank that does not collect any data for examiners.

What is required to be collected for a small bank?

You are not required to collect if you are small bank. However, it is pretty hard to do an analysis if you don't have the info. You are required to calculate your in/out ratio.

What I see now is that when examiners come into small banks they do expect to see at least an Excel file of categorized loans already geocoded. If you do not have that they will pull a sample and base your rating on that sample which may not be representative of your full portfolio for the exam period.

Regulators do recommend that banks collect their data, geocode and analyze so that they know where they are falling short, can change direction, etc.; it is foolish not to do so. Not to collect and analyyze means that the bank is "winging it" on a rating that is critical to the bank.