Rant!

I have been watching the entire CRA debacle unfold with bated breath. As a $400 million, "Outstanding" (small bank exam) FDIC regulated bank , you might say I have just a tiny bit of interest in the outcome of all these proposed changes.

Now, I find out today that my bank will have a CRA exam this 4th qtr. What lousy timing! Will I be examined as a large bank, or will the FDIC adopt their proposed rules by then; and if so, will they differ from the NPR?!?

Calgon..........!

If you submitted 2003 CRA data to the FRB by 3/1/04 you probably will be examined as a big bank. I wouldn't wait for the data request from the examiner to find out, as you may need all the prep time you can get. Consider calling your examiner and ask.

There is also some question as to the effective date any new asset level cut off from small to big bank would be go into effect if it were even passed today. So IMO prepare for big bank unless your examiner tells you other wise

Good news is if you do get bumped down to small bank again you'll be so prepared you'll ace the exam (Sure I know what you're thinking...small benefit for all the work, but I was trying to find a bright spot for you)

We were a "large" bank regulated by the OTS. Now, under their new definition, we are a "small" bank.

We were expecting our next "large bank" CRA exam to be in the coming 4th quarter. The OTS has published their 4th quarter CRA Exam Schedule and we are not on it. In fact, there are only 35 banks on the 4th quarter list, compared with 116 banks on the 3rd quarter list. Could the reduction in the number of exams that the OTS will have to do (because small banks get a CRA exam less frequnently than large banks) be a reason that they wanted to raise the threshold? Just a thought.....

Now, we have no idea when our next CRA exam might come and whether we will be examined as a large bank next time, or as a small bank. Suppose we should just pick up the phone and call our friendly OTS examiners. Any thoughts??

I would call just to be sure. Not being on the list could change. But it sure sounds like you are getting passed over.

My guess is if you are examined in 05 it will be as a small bank. Your examiner is the best person to get the straight scoop from. (Well maybe)

While the threshold change may reduce some paper work for the examiner, the biggest burden has always been on the bank. Examiners still have to do an exam.

IMO OTS regulated institution are more HMDA oriented lenders than CRA lenders. The threshold raise may not cause a big decrease in CRA data collection statistics so it makes it easier for both institutions and examines which translates to savings for both.

My, my Dawnie - what big teeth you have!

Am I to understand that the increase in the large bank threshold is a done deal for OTS regulated banks? December 31 will be our second year-end over $250 million, so I will have to start collecting more data if it is not official, just in case they go back to $250 million. I was under the impression this increase was proposed, and could change based upon what the other regulators decided. It would seem difficult for the various agencies to compare data if the data aren't really comparable

Click here for the OTS release

Steve, your link didn't work for me.

I just tried it again, and it worked for me. Here is the text:

Office of Thrift Supervision

FOR RELEASE at 3:00 P.M. EDT For further information
Thursday, August 12, 2004 Contact: Chris Smith
OTS 04-31 202/906-6677

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OTS Finalizes CRA Rule
WASHINGTON – The Office of Thrift Supervision (OTS) announced today it is issuing a final rule, to be effective October 1, 2004, modifying the existing “small institution” test for thrifts under the Community Reinvestment Act (CRA). The rule increases the “small institution” threshold for savings associations from $250 million to $1 billion. In addition, the rule eliminates the restriction that small thrifts in a holding company with consolidated banking and thrift assets of $1 billion or more are not eligible for “small institution” treatment under the CRA.

The final rule will permit thrift institutions qualifying as small savings associations to benefit from streamlined CRA examinations as well as reduced data collection and reporting burdens under the CRA. The final rule does not, however, relieve small savings associations of all other existing and ongoing compliance requirements and legal obligations under the CRA.




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The Office of Thrift Supervision, an office of the Department of the Treasury, regulates and supervises the nation's thrift industry. OTS's mission is to ensure the safety and soundness of, and compliance with consumer protection laws by, thrift institutions, and to support their role as home mortgage lenders and providers of other community credit and financial services. For copies of news releases and other documents, visit the OTS web page at www.ots.treas.gov.


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Created: Thursday, 8/12/2004

Thanks Steve! How'd I miss that??!!