I was wondering why any bank would choose to report consumer loans if it’s optional for CRA. The FDIC regulation states that, if consumer lending constitutes a substantial majority of a bank’s business, the FDIC will evaluate one or more consumer lending categories. Our lending is primarily consumer however, we received a High Satisfactory on our lending test without reporting consumer loans. Is this part of the regulation suggesting that because consumer lending is a substantial majority of our business, reporting is not optional for us?
I’ve never seen it where they expect you to report those types of loans but I’ve been in an exam where they use Consumer loans to assess your CRA lending patterns. Especially if that’s the concentration in the AA.