Our limited purpose bank (no loans, NOW accounts only) is being merged into a company that has a Bank sub that is, believe it or not, exempt from CRA due to its classification as an FDIC regulated industrial loan bank (no loans, and can evidently accept NOW accounts). Our bank currently has one county designated as its CRA Assessment Area. I have been informed that upon the merger, our bank will be folded into the the industrial loan bank as a subsidiary and our CRA requirements will terminate. I am not convinced that this opinion is accurate.

Is there anyone out there who has some expertise on dealing with "CRA exempt" banks who can help me with my concern?

I don't have a definative answer for you, but I'd be happy make a couple of suggestions you might want to follow up on.

First, call the examining agency you're dealing with now and discuss this with them.

Second, KPMG has a division (I think it's out of Chicago but I'm not sure) that specilizes in "Funky" CRA reporting institutions. Amy Matsu is a contact there who could probably help you out as this type of thing is her specialty.

(Disclosure....For anyone who thinks I'm advertising for the company I work for...I'm not an employee of KPMG and I don't play an employee of KPMG on TV...nor do they pay me to use Amy's name I just know she's dang good at this stuff!)