We strongly recommend voluntary reporting for several reasons:
1 - anyone responsible for CRA should be collecting data and monitoring performance. If you are doing that why not report?
2- Voluntary reporting preserves your elective to be examined under Large Bank rules rather than ISB performance tests. This can be a big advantage because CD activities are absolutely essential to passing the ISB exam standards, but not indispensable to passing the Large Bank standards
3- reporting allows your data to be included in the national database which means you can compare market rank and market share
4- if you collect data on voluntary loans like automobile loans, etc. and you have run it through the CRA software (free or commercial) you can opt to include in a CRA PE if it helps your performance.
CRA Exam Preparation, CRA Performance Evaluations, Key Performance Benchmarks, & maps