We hit 250 million 12/31/2001. So we started collecting as a large bank in 2003 and will be reporting this year. My question is this...the public file for a small bank required a loan-to-deposit ratio for each quarter. Is it appropriate that this is only complete through 2002?

This ratio will still be referred to by compliance examiners in the large bank evaluation. Therefore, you would want to continue calculating and reporting it to management. There are other purposes for this ratio as well. Of course, you don't need to put it in you Public File, although it will be in your CRA evaluation that goes in your public file.

Thank you.

Can I beg to differ?

I have a hard time seeing the value in keeping up on this information as a large bank. The information is not used in the CRA PE. Focus is on Net Tier 1 and Asset Size to determine capacity. (This information will come from your annual report, which you will provide your examiner).

Why would one track the ratio as a large bank in relation to CRA? It sounds like needless work to me but I'd be happy to hear I'm missing something if I am.

Dawnie:
I beg to differ that we differ. I agree that the LTD ratio is not considered, as long as it is reasonable. But our FDIC examiners in Texas will reference the ratio in our Evaluation for each of 10 MAs as then all of our rural areas combined. That was my only point. We also need the ratio internally because we have state laws that require we have "qualified investments" of at least 15% of deposits in our local service areas, which are loosely defined as our assessment areas. And then we also need the ratio for incentive bonus calculations. These are my other purposes I mentioned in my response. So, please don't label me as disagreeing with the Queen. I can't sleep at night thinking you take issue with me.

In my experience the OCC will put it in the PE, but I don't know if they use the bank's calc or do their own. (That may have been personal preference. I don't know if it is part of the template report.)

I had in mine because I was transitioning from small to large and small banks need it.

That's what we're going through now, Andy.
Thanks all, for your input.

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I beg to differ that we differ.

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heh heh Don...I said I wanted to learn I knew you must have some crazy reason for keeping it. We don't have the Texas goober to worry about so we don't bother.

LTD ratio specifically isn't mentioned in my OCC exam, but my total deposits are (which I pull for them off of the FDIC site). They also list out assets (by type) deposits, etc at the very beginning of the PE when describing the bank but they use year end reports (or quarterly depending on the schedule) for this information verses me keeping track of it.

Obviously Don has other reasons to keep the information, my only thought was that as swamped with tracking data as we all get, unless there is a good reason to keep the data (ie all the reasons Don keeps it) it's not worth the time to calculate as the examiners are probably not worried about it anyhoo.

While the OCC discusses our assets, liabilities, etc, they never actually calculate a LTD ratio within the PE. Goodness knows the FDIC does things differently, but it's not supposed to be part of a large bank exam. (Ever hear me say that the rules change depending on the examining agency, direction of the wind and time of the day? Great example!!! It's like they all read the regulation and then add footnotes of their own!)

We dont' believe in bonuses and aren't in Texas, and THANK GOD are examined by the OCC...so I'm going to let that bit of data slip by and continue not to bother with it

Can I keep my crown without a LTD ratio Don? I have a bald spot that would show if I take it off...

I bow down before the Queen and hope she allows me to stay in her kingdom. I am having the same problem with my hair so please do not take your crown off, maybe its that Adkins diet, why don't you eat more bread ? I am getting off track here and I don't want to get flamed for not being serious (as in the 150,000 thread that Andy started and would love to have ended).

Maintaining the LTD info is not required of large banks. The purpose of the LTD ratio in the small bank test is to answer the central question, "Does the bank lend?" For large banks, we have all the collected and reported loan data to compare volumes of lending to decide if a bank lends.

"But AR," you ask, "why is the LTD ratio mentioned so often in the large bank PEs?" This typically happens, but is not confined to, PEs of banks that are the only large bank for CRA purposes in their trade area. For these types of banks, we have no other CRA collectors to which to compare the bank. Examiners have figured out that in those cases they can essentially do a small bank CRA exam and dress it up to look like a large bank exam. I don't know if that makes sense to you, but that's why you see the LTD ratio mentioned in many large bank PEs. AR.

Thanks AR. I couldn't figure out the reason for the LTD ratio in large banks And I'm too busy to keep any extra information on hand, but once I hear there might be a reason I get worried I'm being lazy

Fortunately for me I have plenty of competition around town filing CRA data so I don't have to worry about the information

Now, can I drive your car? heh heh