My question is, if you elect to be examined under the Intermediate Small Bank rule, do we still have to report data for HMDA? Thanks in advance.

You still have to report under the HMDA, if you are subject to HMDA.

The ISB rule only permits your bank not to report SB, SF and CD Loans.

One doesn't necessarily have anything to do with the other. If you are required to report HMDA, whether you are designated a Small Bank, ISB or Large Bank, you will still have to report HMDA.

I believe the only break you get with HMDA when you are an ISB is that you no longer have to Census Tract any properties outside of your MSA(s).

So, we are an ISB as well, and my question is, how do you get examined / graded if you don't count your CD loans?

I have read and cannot find this answer.

Doesn't seem to make sense to me.

You just don't have to "report" your CD loans by March 1st of each year on the LR.

You still show them to your examiner to be counted when they come in for your examination.

Ohhhhhhhhhhhhhh, gotcha. Thanks, that makes sense.

So, really, what are the major differences in Examination procedures between an ISB and large bank other than the LAR filing?

You got it. The Lar submisssion has been replaced with the Community Development Test which you MUST pass in oredr to get Satisfactory n a CRA exam.

I am sending private message that lists the ISB Exam Criteria

Thanks Don, you're a wealth of information and I appreciate you sharing.