Yes it would. You're now going to have to really focus on CD lending, investment, service, etc. more than you have had to in the past. If you aren't really strong in all of those areas it's a challenge to get to satisfactory for many banks that have in the past had no problem with it.
Also, the focus on data integrity changes (worse)
It's worth the time to see what the examiners are thinking. With this new risked based exam, it's interesting to see how the changes affect both the little and the large bank.
If you're not using a consultant or software to collect your data you have a chance to see what's available. Personally I wouldn't work for a bank without one or the other to gather the data. Remember, you're a "big boy" now...right up there with BofA! We're held to the same reporting standards (fair huh?) The assistance from either a consultant or a program inhouse is a must!
Then there's the last important item, which shouldn't be considered small. I went to this program a year after my first exam. I was sooooo sorry I hadn't gone before it! I learned so much that would have helped me, as much from instructors as I did from networking around the tables during lunch and breaks.
As I mentioned, there are just the two seminars that really have a good focus on CRA. I go to both and find value in both but if you have to do just one, make it the Fed this year, and PCI next year.
PCI is holding theirs in Florida in November by the way. I suppose that should be taken into consideration