I think I understand but want to make sure... in 12/31/2012 we had $260 mill in asset size; 12/31/2013 we had $335 mil in asset size; in 12/31/2014 we will also have over $350 mil in asset size.

My question; if we have a CRA exam scheduled early 2015... will they examine us as a small or intermediate small bank? We know we need to begin collecting data etc. as of 1/1/15 but was curious as to what to expect.

From the FFIEC site:

http://www.ffiec.gov/cra/pdf/Explanation...Change_2014.pdf

"Small institution" means a bank that, as of December 31 of either of the prior two calendar years, had assets of less
than $1.202 billion.

"Intermediate small institution" means a small institution with assets of at least $300 million as of December 31 of
both of the prior two calendar years, and less than $1.202 billion as of December 31 of either of the prior two
calendar years. Since there is no CRA loan data requirement for an intermediate small institution, its next
examination is under the intermediate small institution examination procedures even if that examination comes due
during the institution’s first year as an intermediate small institution.

“Large institutions” have total assets of at least $1.202 billion for December 31 of both of the prior two years. Large
institutions are subject to CRA data collection. Thus they cannot be examined under the large institution examination
procedures until they have at least one full year of data collected. In addition, any size institution may opt to be
examined as a large institution provided it has collected and reported the required CRA loan data.

I believe the idea behind having the two year period is to given an institution sufficient time to start planning the transition from Small Bank to ISB so you can start ramping up your Community Development Activities.

After all, it's not as if you didn't have plenty of warning notice that you'll be thrown into the ISB bin. If management has not paid attention to the increasing CRA Compliance Risk and has not done anything to shore up CD loans, investments and services, then you may wind up with an unpleasant exam experience.

Thanks for your feedback.. since our jump in size was due to a merger, we had started down the path of preparation for next tier however, had not had a lot of time to prep. So guess we will scramble.