Small Intermediate Bank

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?
Posted By: Kathleen O. Blanchard

Re: Small Intermediate Bank - 02/21/20 10:55 PM

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.