We're $380 million in assets --- if the proposal becomes final, will it affect us this year (2004)? This is our first year of large bank data collection - what a blessing it would be to delay that for a year or two!

It would not be wise to stop collecting data. This is only a proposal, and the advance notice of this proposal was more than 2 years ago.

Thanks, Don. We would never stop collecting until we had a final rule, but I just might relax my audit frequency and concentrate more heavily on the revised HMDA if I thought there was a good chance we'd get a reprieve from large bank CRA data requirements this year.

My lenders are new to CRA data collection this year, then you add the new HMDA and I am the most unpopular person on the block! Are there any expert opinions out there regarding the chance this might actually become final rule this year? I'm sure it's too much to hope for!

This is speculation on my part but if the amount is raised to 500 mil its not going to be go home free card.I believe examiners will still count on the bank being able to provide a myrid of information including some data collection.

They already do that now, so while you may not have an annual submission you may very well still have data collection, and with a push to do more self assesments of the data between exams.

We still haven't heard from the lobbying groups that want more data collection. This has got to be an issue with them and they are powerful.

In other words - I will not hold my breath! Thanks, Don.