We are hearing two (2) different recommendations for establishing CRA benchmark levels of eligible portfolio investments which should be maintained: (1) - 1% of Assets and (2) 5-6% of Tier 1 Capital. In our case as a large Bank, the amounts are substantially different:
1) Bank's total assets: $11.5 billion = 1% is $115mm
2) Tier 1 Capital Level: $1,028,704,000 = 5% is $51.5mm.
Recommendations please?
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