As an ISB with a mortgage company subsidiary, we choose not to include our mortgage company's lending with CRA because we would have to include all of it, and they serve such a large area it would not really benefit us.

Without including the lending, can we include the qualified investments and CD services of that same mortgage company subsidiary as long as no other institution counts them? I do not see any requirement within the reg that we have to include all or none, so I thought I would seek opinions on this for us including only qualified investments of our subsidiary/affiliate or CD services. Can we include only the QIs or CD services?