Posted By: Kristi
Small Intermediate Bank - 02/20/20 10:27 PM
Are small intermediate banks required to annually report the data on small business and small farm loans like large banks?
No, only large banks as defined by CRA are required to submit data. Others can voluntarily submit.
Posted By: Len S
Re: Small Intermediate Bank - 02/24/20 10:24 PM
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.