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#2231445 - 02/20/20 10:27 PM Small Intermediate Bank
Kristi Offline
Joined: Feb 2005
Posts: 87
Are small intermediate banks required to annually report the data on small business and small farm loans like large banks?

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#2231516 - 02/21/20 10:55 PM Re: Small Intermediate Bank Kristi
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,277
No, only large banks as defined by CRA are required to submit data. Others can voluntarily submit.
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy

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#2231576 - 02/24/20 10:24 PM Re: Small Intermediate Bank Kristi
Len S Online
Diamond Poster
Joined: Oct 2004
Posts: 1,897
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

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