Our OCC examiner sent me this e-mail this morning.

I received confirmation recently that banks between $250MM and $1B that wish to preserve their ability to be examained under the large bank CRA guidelines, must collect and file their CRA data.

However, filing the CRA data would not preclude a bank in this catagory from electing to be examined under the intermediate small bank CRA guidelines.

There have been numerous posts regarding pros and cons of being examined as an ISB. You may want to check them out as a lot of information has been provided.

Yes, in order to keep your option to be examined as an ISB or Large Bank, you must report each year. If you do not report you loose the option and will be examined as a ISB.

What the ISB no data collection really means is you do not have to collect data FOR REPORTING PURPOSES. To quote what was stated in the FRB Community Development Conference.


We will not tell a bank they should or should not collect and analyze their data."

"We do expect a bank to know their story and be able to tell it"

In other words you need to collect some data in order to know your story.