I'm not sure. Can you advise what the advantages would be for an intermediate bank opting into the Community Development Financing Test?

Only that you will eventually know what the standards are. But that won't be evident until they collect enough data to post the standards. The regulators will need to collect at least one year's worth of data using the additional information to be reported if the NPR passes as proposed. The standard will be in reference to deposits and in comparison to other banks in the market you serve.

Len, thanks. I was thinking along those lines. I suppose we would also need to collect the Community Development Financing data just in case it serves us to toggle from the existing intermediate bank community development evaluation to the Community Development Financial Test.

Even if you are not reporting under CRA it's a best practice to collect your CD activity, identify which purpose(s) is fulfilled, explain why the activity qualifies, and what documentation you have to support the qualifications.