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CRA Changes for Intermediate Small Banks

Question: 
Our bank is an Intermediate Small Bank under the current CRA rule, with an asset size of $750 million. Will we still be treated differently from large banks under the proposed rule?
Answer: 

As proposed, there will not be a classification of Intermediate Small Bank for CRA.
Small banks will continue to be evaluated under current small bank standards, with some additional requirements. Small banks will be those banks that had assets of $500 million or less in each of the previous four calendar quarters.
Banks that are not small banks will be evaluated under standard rules regardless of size, making performance context important.
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Learn more about Kathleen Blanchard’s webinar CRA Modernization Proposal Review

First published on 02/16/2020

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