We are moving a branch from a moderate income to a middle income area. The new branch is about 5 miles from the old branch. We are regulated by the OTS and are considered a small bank. We are still under the old rules because the OTS did not adopt the new rules. Our customers will be notified as required and we did notify OTS of the move. Is there anything we need to do for CRA? I was thinking that since we are going from a moderate to a middle we should document why we are making the move.

Pat

I think that a good idea to do, but I am not aware of any regulation or requirement to provide an explanation as to why an office was moved regardless of the tract income classification.