If you are under $1 billion in assets you don't have to file your CRA small business loan data, although you should continue to collect it and monitor your activity so you can anticipate performance problems and correct them before you are examined next time. Remember, even if you are not a reporting institution, you are still accountable to perform under CRA and are subject to periodic examination. And the negative consequences of a composite SNC or NI rating are the same for all institutions. So don't report if you don't want to, but continue to monitor your own performance unless you want to suffer terminal anxiety waiting for your next exam.
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