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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?
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