We are an ISB that chose to remain Large for reporting and examination. I read on a posted thread that an ISB should follow Small Bank requirements for their Public File. Does this apply if the bank has chosen to remain Large? Am I correct that the only difference is providing the loan-to-deposit ratio? Thanks.

I was not sure so I went ahead and put the loan-to-deposit ratio in the file. I figured it was easy enough to do until I figured out whether or not I actually needed it.

I,too, fall into the ISB but chose to remain Large for reporting. I am going to just add the loan-to-deposit ratios to the public file just to be on the safe side since it is so easy to do.

I agree, that sounds like the easiest thing to do. Thank you.

You should follow the regulation for what should be in the public file for a Large Institution.

What do you base this on?

For those of you who include LTD ratios in your public files, do you use quarter-end numbers to calculate the ratios or do you use quarterly averages? I know examiners use the same ratios that are reported in UBPRs when they "test" LTDs for reasonableness, so I'm wondering if we should use the same numbers for consistency.

We use quarter-end numbers, and we are a small bank for CRA purposes (OTS regulated).

This may be a silly question, but here goes: I just started a new FI and am trying to figure out how they came up with the LTD ratios for their public file. The numbers they have do not match any of the #s in their UBPR. Do any of you just go back to your UBPR and pull the #s from page 10? If so, are you pulling the net loans & leases to deposits or net loans & leases to core deposits? Thanks!!

We use the following figures from our Call Report:
RC 4d Net Loans / RC 13a Total Deposits = %