We have always been examined as a Large Bank but is strongly considering changing to an Intermediate Small Bank. I want to make sure I have everything straight before we make the change.

1. We will now be able to use Consumer loans as part of the lending test (we track these but do not report)
2. We continue to report (by March 1st) our small business, small farm and community development loans
3. The public file needs to include the loan to deposit ratio

Are these correct and am I missing anything?

Why are you considering being examined as an ISB? Believe it or not, it's easier to pass a CRA exam under the large bank standards. So what is motivating you to change?

We just went through a CRA exam and our examiner suggested that we look into it. In one of our assessment areas the small business and small farm loans have been going down and she suggested that we look into it so we can count our consumer loans in those census tracts. We're hoping to work on getting more small business and small farm loans in that area but just in case we'd like to be able to count our consumer loans so we keep a good rating.

The regulation allows banks who voluntarily report their data two electives: (1) you can be examined under the Large Bank standards and (2) you can include your non-mandatory loans (i.e., consumer loans and other business loans/lines in loan type 3) to be included in a CRA exam if you have collected the data and scrubbed it so examiners know you have done what you can to preserve the integrity of the data. Apparently you've been voluntarily filing your CRA data because you've been allowed to be examined under large bank standards. So you've set the stage for voluntarily collecting and submitting the elective loans in your CRA exam. A caveat is when you select a type of loan, you must include all the loans of that type. Cherry picking is not allowed.

As far as the annual submission, we still only submit the small business and small farm loans, correct? The other loans I just keep a record of and don't submit them.

Most people think CRA reporting is like HMDA reporting, but it completely different. In HMDA you are reporting each and every loan application. In CRA you are reporting summary data on your small bus, small farm and CD loans. Even if you collect data on other types of loans, none of that is reported in your annual filing. However, that data along with the SB, SF and CD records are maintained on your desktop computer in the "micro-data" file.When the EIC asks you in the documentation request letter for your data one thing you submit is your CRA micro-data file. You can elect portfolio by portfolio to have the elective loans considered as part of your loans to be evaluated for CRA purposes.