Our Intermediate Small Bank (ISB) has been voluntarily submitting data to the FDIC as part of our CRA lending test. We submit only at exam time. Soon we will become a Large Bank and I am wondering about impacts. I've spent hours searching online and every thread and blog and article I find is on the scariness of switching from "small bank" to "ISB" for the first time. I have found nothing that talks about switching from an ISB to a Large Bank, other than vague warnings from regulators that a bank shouldn't do it without being prepared and anticipating the consequences.

1. In our exams we have been submitting CRA-type data voluntarily, but I'm not sure if that is the same or even roughly similar to what a Large Bank has to provide. How similar is it? Is it identical, or nowhere near as intense and complex?

2. How many FTEs would you anticipate adding as you change from $1.3 billion to $1.6 billion and become a Large Bank for CRA purposes?

3. Is it comparable to HMDA reporting, in terms of complexity? Right now we have 4 full-time employees devoted to HMDA (we do a lot of HMDA loans), and they stay very busy. Is it reasonable to anticipate that becoming a Large Bank will require one, two, three, or even four full-time CRA people, since that's what HMDA requires? Or is CRA loan data something your system can just generate on demand, and no one really has to verify every last field of data the way we do for HMDA?

4. I know there are more expectations in terms of community development but I'd appreciate replies on the above first, before we get into all that. We're pretty solid in that area and I think we'll do well (being in an area that is almost perpetually a FEMA-related disaster zone due to natural disasters tends to make that one part of CRA a little easier).

Here is a link to the fourth quarter 2014 Consumer Compliance Outlook magazine, which has a very good article on transitioning from ISB to large bank: https://consumercomplianceoutlook.o...iate-small-bank-to-large-bank-under-cra/

I suggest you also download the CRA Guide (2015 A Guide to CRA Data Collection and Reporting): https://www.ffiec.gov/cra/guide.htm

As to your questions:

1. It's hard to say without knowing how the "data" was submitted to the FDIC. You collect certain data, but it will eventually be submitted in the aggregate.
2. It would depend on the number of reportable small business and small farm loans that your bank has. One employee should be able to handle 20 to 40 loans per month, maybe more. The fields to scrub are minimal. The hardest part I would say is verifying revenue.
3. Other than determining gross annual revenue (when Credit used some other amount to make the credit decision for example), CRA scrubs are nothing like HMDA. You only have a few data points to verify (loan data, amount, address, revenue, loan type, etc.).