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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Adam Witmer, CRCM
All statements are my opinion, not those of my employer, and should not be taken as legal advice.
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