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What if the bank is unsure about whether to elect examination under the large bank test? Can it voluntarily submit the CRA loan data just in case?

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What if the bank is unsure about whether to elect examination under the large bank test? Can it voluntarily submit the CRA loan data just in case?

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Yes, the agencies will accept voluntary submissions to preserve the large bank option. If the bank is unsure whether to stay under the ISB test or opt for the large bank test, it should collect and submit the data. Without the submission of the required data, it cannot be examined as a large bank.

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