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#2307429 - 03/24/25 03:41 PM Loan to Deposit Ratio
JWills, CRCM Offline
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JWills, CRCM
Joined: May 2013
Posts: 1,833
The Mitten State
If a bank is now an ISB, but is being examined as a small bank, does the CRA Public File have to contain the loan to deposit ratio?

I thought the Public File was supposed to be current as to what the bank is currently.

Thanks in advance.
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#2307430 - 03/24/25 03:54 PM Re: Loan to Deposit Ratio JWills, CRCM
rlcarey Offline
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Galveston, TX
(3) Small banks. A small bank or a bank that was a small bank during the prior calendar year shall include in its public file:

(i) The bank's loan-to-deposit ratio for each quarter of the prior calendar year and, at its option, additional data on its loan-to-deposit ratio;
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#2307431 - 03/24/25 04:06 PM Re: Loan to Deposit Ratio JWills, CRCM
JWills, CRCM Offline
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JWills, CRCM
Joined: May 2013
Posts: 1,833
The Mitten State
We met the ISB threshold in Dec 2022, so I am thinking it does not need to be included.
Is it an issue if it is included? I don't want it to be viewed that we do not understand what the contents of the public file should be.
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Nonsense wakes up the brain cells.

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#2307433 - 03/24/25 04:36 PM Re: Loan to Deposit Ratio JWills, CRCM
rlcarey Offline
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Galveston, TX
228.43(a)(7) Any other information the bank chooses.
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#2307435 - 03/24/25 04:48 PM Re: Loan to Deposit Ratio JWills, CRCM
JWills, CRCM Offline
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JWills, CRCM
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Posts: 1,833
The Mitten State
Thank you, Randy.
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#2307438 - 03/24/25 04:57 PM Re: Loan to Deposit Ratio JWills, CRCM
Adam Witmer Offline
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Keep in mind that (under the old/current CRA framework) an ISB is a small bank. An ISB is just a type of small bank. Therefore, ISB's are small banks and must include the loan-to-deposit ratios in their public file.

The definition:
(u) Small bank--

(1) Definition. Small bank means a bank that, as of December 31 of either of the prior two calendar years, had assets of less than $1.564 billion. Intermediate small bank means a small bank with assets of at least $391 million as of December 31 of both of the prior two calendar years and less than $1.564 billion as of December 31 of either of the prior two calendar years.


And the requirement for the public file:
(3) Small banks. A small bank or a bank that was a small bank during the prior calendar year shall include in its public file:

(i) The bank's loan-to-deposit ratio for each quarter of the prior calendar year and, at its option, additional data on its loan-to-deposit ratio;
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#2307439 - 03/24/25 05:19 PM Re: Loan to Deposit Ratio JWills, CRCM
JWills, CRCM Offline
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JWills, CRCM
Joined: May 2013
Posts: 1,833
The Mitten State
Thank you, Adam.
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Nonsense wakes up the brain cells.

--Dr. Seuss

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#2307520 - 03/26/25 02:11 PM Re: Loan to Deposit Ratio JWills, CRCM
Len S Offline
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Joined: Oct 2004
Posts: 2,146
Connecticut
Adam has it correctly.
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