Thanks rlcarey, I have taken a look at this. Just one question.
Based on asset size, under the prior 2020 rule we were considered a small bank, now with the transition to the new 2021 rule, we are considered a intermediate bank. For the public file requirements included under 25.43(b)(1) - "Additional information available to the public (1) Banks and savings associations other than small banks or savings associations. A bank or savings association, except a small bank or savings association or a bank or savings association that was a small bank or savings association during the prior calendar year, shall include in its public file the following information pertaining to the bank or savings association and its affiliates, if applicable, for each of the prior two calendar years:..."
If I'm not mistaken, isn't the intermediate bank category, a subcategory of "small bank" (as in "intermediate small bank")? Asking as I'm trying to determine if the requirements outlined in section (b)(1) apply to us as an "intermediate" bank under the 2021 rule.