CRA

We were a 545 million dollar institution at the end of 2008 down from 583 million at the end of 2007.

CRA examiner is wanting me to send the out loan to deposit ratios for each of the four quarters of 2008 due to our size shrinkage now dictates we need to include in our CRA public file.

Am I missing something here... I thought we would have to be a small bank (under 265 million starting this year) before we had to do that.

You might want to check the definitions in Reg. BB:

228.12(u) Small bank-- (1) Definition. Small bank means a bank that, as of December 31 of either of the prior two calendar years, had assets of less than $1.109 billion.

But I thought Intermediate small was exempted from reporting this ratio.

We have never been large enough to be a large bank, and we have not had to provide this ratio in the past.

FWIW, I agree with Randy. An intermediate SMALL bank is required to have the LTD ratio for the past calendar year in the public file.