I read on the FDIC website that small dollar, affordable loan programs may be considered favorably in a CRA exam. We don't have a specific program, but many of our loan products have low minimum loan amounts and meet the other requirements. Think we have a shot at getting credit for the small dollar loans we do?

http://fdic.gov/news/news/press/2007/pr07052a.html

To cinch it TMatt, you could look at the incomes of the borrowers, and if they are lower than 80% of your median family income for the MSA, you have a real shot at presenting the programs you have as being used primarily used by LMI.

You might want to compare your low minimums to your competition as well.

You could beat us up pretty bad, we only offer credit cards as alternatives to low dollar loans.

No harm, no foul.

Service Test - Add the information/details to your listing of products and services. Elaborate on products and/or services that specifically address the needs of low -and moderate- income individuals or unbanked or underbanked, such as lending products that bridge the gap of payday or title lenders or deposit products that encourage saving.

Lending Test - The program that you speak of may be condsdered innovative by the examiners. For the loan product do an analysis of the number of accounts opened by income level of the borrower.

Worth a try.