We were a large bank, this year we have the option and since we were already collecting and reporting, we went ahead and reported. We are not that far from being large again. Would you say it's better to be examined as a large bank, versus a ISB? We have the option now to go either way.

I would think the ISB would be the easier exam. But have you done a self-eval to see how you'd rate either way?

WE have a total of 13 CD loans totaling $43Million and 31 Small Business Loans.

If you are not that far away from becoming large, why dump data collection and analysis ( which is really necessary for an ISB) and then have to retrain and start all over again.

If you don't file for 2006 then you have lost the option to be examined as a Large bank until you become one.

At the FRB Community Development Conference a couple weeks ago, it was clearly stated that an ISB is expected to "Know their story and be able to tell it" The only way you can do that is to collect and analize you data. You need to know what the Community Needs are and be able to discuss them. Writting a formal Community Needs Assessment has been dropped, but you still need to know what they are and show how you are meeting those needs.

As far as dollar amount and number of CD loans, so much of an ISB exam is dependent on the subjectivity of the examiner. Small Business loans may not qualify as CD loans.

So if you need to provide data to examiners prior to the exam and collect data in order to answer examiner questions, IMO don't drop your system.

I totally agree with you, after all the hard work that was put through to get everyone to understand the process on reporting requirements, we have that in our favor. I have not been able to find much on banks examined by the OCC under the new ISB. The way I see it is that if we have been examined as large in prior years and done OK, I feel we should continue to go that route.

Vegas - is the majority of your lending activity consumer and/or mortgage lending? Or is the majority of your activity in construction loans or loans over $1MM?

Otherwise, to be approaching the $1Billion in assets threshold and have made only 31 Small Business Loans seems a bit odd.

Bonnie - the majority are loans over $1MM, we do very few consumer loans.

Having just completed an ISB exam and also attending the recent SF FRB Community Reinvestment Conference, I would recommend staying with the Large Bank procedures and exam. Why change horses in the middle of the stream just to change back again? And, IMO, the risks of the ISB exam outweigh the perceived relief of not gathering and reporting data.

On a side note, as Don and Len have both stated in previous posts, I can not stress how much emphasis was placed on "presenting your story and backing it up" by the regulators at the recent conference. Be prepared!