Our ISB will have an exam in February. I was suprised that the FRB has requested to verify our CRA data to be sure it's accurate. We had to submit 06 & 07 to them.

What if we weren't collecting our data because we are an ISB?

Have any other ISB's had this with their examiners?

What's the point of not having to report if you have to give them all of the data anyway?

I'm sure that it will all be fine as we have been collecting everything anyway; it's just that we were not expecting it!

Being an ISB does not release the bank from the responsibility of "Knowing their story and being able to tell it" A quoate from a regulator when I proposed the same question to them a couple years ago. That means you need to do some analysis, which means you need to collect data.

Being an ISB does exempt you from filing but thats it. Everything else is in play AND you have a Community Development test to pass as well as the CRA.

If you have filed, my recomendation is to continue as this gives you the option as the exam the regulators will perform. If you don't think you have enough Community Development activities and Lending you may not want to be examined as an ISB.

Once you do not file you give up your examination option and will be examined as an ISB.

If you haven't collected or done any analysis on your data then you will at the complete mercy of the examiners and will have to accept what ever they come up with.

I think that we will be fine. We are real close to the threshhold of becoming a large bank so I have been keeping our program just as if we were one. We did not report last year; we spent last year and this year collecting the data and making sure that it is accurate in order to be ready to report once we were no longer an ISB.

I knew that we would still be examined I'm just suprised that they want to verify our accuracy. But don't worry, I'm ready!

Bring it on!!

Oh, and thanks Don! Hope everything is well with you!!