Not an answer to your question, however, more of an FYI for mid-size banks that are currently not required to complete an MLR...
At the OCC Midsize Bank BSA Officer Roundtable this summer, the OCC stated there is a project currently to develop an MLR requirement for midsize banks...the data points sought will not be as broad as that for small banks, but will be more granular in the data they will be seeking.
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* My opinion is not necessarily that of my employer.