What Is an Intermediate Small Bank? The Status & Exam-Path Planning Kit for CRA Teams

Quick answer

An intermediate small bank is a Community Reinvestment Act category for smaller institutions: a bank that meets the annually adjusted small bank asset threshold and also falls under the lower intermediate small bank threshold set the same year, placing it on a simplified examination path with the small bank lending test plus the community development test instead of the full large-bank framework. The 2023 CRA final rule carries the idea forward as the intermediate bank — total assets above $600 million and up to $2 billion, adjusted annually — evaluated under the community development test, with an option to opt in to the retail lending test.

1. Pull December 31 assets: Take total consolidated assets as of December 31 from Schedule RC of the Call Report and enter them on worksheet line 1.
2. Aggregate affiliate assets: List each affiliate's assets on the aggregation lines and combine them with the bank figure under your regulator's measurement rules.
3. Apply the thresholds: Compare the combined figure against the current year's $600 million and $2 billion thresholds, recorded with their effective dates.
4. Log the determination: Write the resulting category and effective date on the worksheet and extend the annual recalculation log with a change flag if the category moved.
5. Run the opt-in matrix: Score lending mix, assessment-area penetration, data readiness, and asset trajectory to sort the bank into one of three decision states.
6. Set the CD calendar: Schedule community development loans, investments, and services for the year against the evaluation pathway the determination produced.
7. Assemble the exam file: Package the worksheet, log, and decision memo in the examiner-file order so the status determination can be re-performed without follow-up.

Summary

A January-ready worksheet set that turns the intermediate small bank definition into a documented status determination, an opt-in decision, and a community development plan your examiners can follow.

This resource helps readers connect what is an intermediate small bank to classroom practice, standards-aware implementation, and responsible next steps for schools and sponsors.

Short Answer: What Is an Intermediate Small Bank?

An intermediate small bank is a Community Reinvestment Act category that places a smaller institution on a simplified examination pathway. To qualify, a bank must first meet the small bank standard by holding total assets below a threshold the banking agencies adjust each year, and then fall under a second, lower intermediate small bank threshold set on the same schedule. Both measurements look back to December 31 assets. For example, for calendar year 2023 the agencies set the small bank threshold at $1.660 billion and the intermediate small bank threshold at $416 million.

The 2023 CRA final rule restructures these categories going forward. Banks are sorted as small banks at or below $600 million in total assets, intermediate banks above $600 million and up to $2 billion, and large banks above $2 billion, with the thresholds adjusted annually for inflation. An intermediate bank is evaluated under the community development test and may opt in to the retail lending test, making it the closest successor to intermediate small bank status. The Exam-Path Determination Console embedded in this kit turns that definition into a determination workflow you can complete each January and hand to examiners.

Who the Console Is For

This console is written for CRA officers, compliance leads, and finance teams at community and regional banks whose balance sheets sit anywhere near a category line. When year-end assets land close to a threshold, a single year of growth or contraction can move the institution between examination pathways, changing which tests apply and what data the bank must produce. A documented, repeatable determination process protects that bank.

It also serves internal auditors and board members who review the CRA program, and bank teams that sponsor school-based financial literacy programs and need their exam pathway documented before planning the year's community development activity. Every console export is plain-language, format-agnostic across the three regulators, and designed to be completed by one person in a single morning.

Inside the Console: Four Instruments + an Assembly Checklist

The Exam-Path Determination Console is an embedded interactive module with two working panels. The determination panel takes a year, a December 31 total asset figure, and affiliate asset lines, and returns the category verdict with a change flag when the category has moved. The opt-in matrix panel scores the four election inputs and flips visibly between State A, State B, and State C, including the three exam-file line changes each state produces. The console's output exports as four downloadable instruments plus an assembly checklist, each formatted to drop directly into the CRA exam file. Together they convert the asset-size definitions published by the OCC, Federal Reserve, and FDIC into lines, columns, and decision branches a working compliance officer can actually complete.

• Asset-Threshold Determination Worksheet (downloadable export) — a one-page form generated from the determination panel's entries, with dedicated affiliate-aggregation lines, a December 31 measurement date field, and a comparison block for the current year's thresholds.
• Annual Recalculation Log (downloadable export) — a running table with one row per January, capturing the asset figure, the thresholds in effect with their effective dates, the resulting category, and a change flag when the category moves.
• Retail Lending Test Opt-In Decision Matrix (downloadable export) — a four-input scoring sheet mirroring the console's matrix panel, sorting the bank into three decision states, from staying on the community development test to building retail lending data capacity.
• Community Development Activity Planner (Intermediate Pathway) (downloadable export) — a quarterly calendar that schedules community development loans, qualified investments, and services against the evaluation structure that actually applies to the bank's determined status.
• Examiner-File Assembly Checklist (downloadable export) — the cover-sheet order that packages the worksheet, log, and decision memo so an examiner can re-perform the determination without follow-up requests.

The January Determination Pass

Block one morning in early January. Pull total consolidated assets as of December 31 from Schedule RC of the Call Report, list affiliate assets on the aggregation lines per your regulator's instructions, and compare the combined figure against the thresholds the agencies have announced for the new year. Because the category is measured on prior-year December 31 assets, the determination you complete in January generally holds for the whole calendar year — which is exactly why the console exists.

Mid-year, the calendar flips to the two decisions the determination feeds: running the opt-in matrix before the evaluation period hardens, and scheduling community development activity against the pathway your status supports. In the fourth quarter, you assemble the exam file. By the following January the log gains its next row, and the cycle repeats.

Assembly Order for the Exam File: The Determination, Line by Line

The worksheet's strength is its line discipline. Each line captures one fact an examiner can independently verify against a public filing or an agency announcement, so the determination never depends on memory, tribal knowledge, or an informal spreadsheet that only one person understands.

Worked example — a model bank through lines 1 to 5. Take Harborview National, a model bank with $705 million in total consolidated assets as of December 31 and one affiliated institution with $96 million in assets. Line 1 records $705,000,000 with the December 31 report date from Schedule RC. Lines 2 through 4 record the affiliate's $96,000,000 on its own aggregation line. Line 5 boxes the combined figure: $801,000,000, measured as of December 31. Lines 6 and 7 hold the year's $600 million and $2 billion thresholds with their effective dates, and the category sentence writes itself: 'As of [date], the bank is an intermediate bank.' Line 8 notes that the category moved up from small bank in the prior year's determination, and the log row preserves the change flag.

• Line 1 — Consolidated total assets as of December 31, taken from Schedule RC of the Call Report, with the report date noted.
• Lines 2 through 4 — Affiliate assets, one affiliate per line, aggregated under the measurement rules the agencies apply to asset-size categories; the 2023 final rule measures bank and affiliate assets together, and the worksheet keeps that basis visible.
• Line 5 — The combined figure, boxed, with the measurement date stamped beside it.
• Lines 6 and 7 — The current year's small bank and large bank thresholds copied from the agencies' annual announcement with effective dates, then the resulting category written as one sentence: 'As of [date], the bank is [category].'
• Line 8 — Preparer and reviewer sign-offs, plus a note on any category change from the prior year and its practical consequences.
• Log row — After sign-off, extend the annual recalculation log: year, figure, thresholds, category, change flag. Five years of rows gives an examiner a readable category history at a glance.

The Opt-In Switch: Three States

The matrix exists because an intermediate bank's examination is not fixed — the community development test is the default, the retail lending test can be added by election, and sustained growth eventually removes the choice. Score four inputs: the share of lending in home mortgages and small business credit, assessment-area penetration, current data systems, and the two-year asset trajectory. The score sorts the bank into one of three states.

State A — Stay on the community development test. When retail lending volume is modest and data systems are thin, the election buys little. The exam file centers on community development loans, investments, and services, and the planner schedules activity quarterly against that structure. When the matrix shows this state, the election line reads 'declined,' with reasons recorded.

State B — Opt in to the retail lending test. Banks with meaningful mortgage and small business originations in their assessment areas can earn examination consideration for that lending by electing in, but the same election commits the bank to producing the supporting data for the evaluation period ahead. Flipping from State A to State B visibly changes three file lines: the election memo replaces the decline memo, retail loan data collection moves onto the compliance calendar, and the planner rebalances toward activities that complement rather than substitute for lending performance.

State C — Prepare to scale. If the asset trajectory in the recalculation log shows the bank approaching the $2 billion line, the retail lending test stops being optional on the transition timeline the agencies set for banks newly crossing into large bank status. The third state is not an election at all — it is a build order: stand up data collection one to two years early, and treat the log as the early-warning system it was designed to be.

Worked pass — why Harborview lands in State B rather than State A. Score the model bank from the determination example on the four inputs. Retail lending mix: home mortgage and small business originations run 61 percent of total lending — meaningful, not marginal. Assessment-area penetration: about three-quarters of those originations land inside the bank's delineated assessment areas. Data readiness: loan-level records can already be produced to the retail lending test's standard, on deadline. Trajectory: combined assets grew roughly 4 percent over two years, so the $2 billion line is years away and the election window matters now. That profile clears State A, where the election would buy little, without approaching State C's build order — so the matrix lands on State B, and the three exam-file lines flip exactly as described: the election memo replaces the decline memo, retail loan data collection moves onto the compliance calendar, and the planner rebalances toward activities that complement rather than substitute for lending performance.

• Matrix input 1 — Retail lending mix: home mortgage and small business originations relative to total lending.
• Matrix input 2 — Assessment-area penetration: where those loans land relative to the bank's delineated assessment areas.
• Matrix input 3 — Data readiness: whether loan-level data can be produced at the standard the retail lending test requires, on deadline.
• Matrix input 4 — Trajectory: the two-year asset path in the recalculation log, which signals whether the election window even matters.

Pairs With Your CRA Stack

The console is designed to sit inside a broader CRA exam-preparation stack rather than stand alone. Pair it with the SuccessEdu resources below so the January determination connects directly to the compliance dates, rating mechanics, and qualified activities that surround it.

• CRA Compliance-Date Lookup — match every effective date on the recalculation log to an interactive timeline (/tools/cra-compliance-date-lookup).
• CRA Rating Qualifier — see how the pathway you determine feeds the rating levels your bank can reach (/tools/cra-rating-qualifier).
• Coverage Gate Scoping Kit — the predecessor worksheet that establishes whether the CRA applies at all, upstream of any category determination (/resources/cra-coverage-gate-scoping-kit).
• The 2023 CRA Final Rule Explained — the written companion covering tests, timelines, and data changes behind the thresholds in this kit (/articles/what-is-the-2023-cra-final-rule).
• Qualified CRA Activity Anatomy — a test-by-test breakdown to use when filling the activity planner's quarterly calendar (/case-studies/cra-qualified-activity-anatomy).
• Large-Bank Data Readiness Kit — the downstream kit for banks whose trajectory log points at the $2 billion line (/resources/cra-large-bank-data-collection-readiness-kit).

Disclaimer

This kit is educational, not legal, compliance, tax, or financial advice, and completing it does not guarantee any examination outcome, rating, or CRA treatment. How a regulator evaluates any bank, election, or activity depends on program facts, assessment-area context, and examiner review. Asset-size thresholds are adjusted annually and applicability dates differ by bank; always verify the current figures in the agencies' published announcements and confirm requirements with your primary federal regulator.

The 2023 CRA final rule has also been the subject of litigation and agency review, so dates and definitions cited here should be reconfirmed against current regulatory guidance before reliance. Consult qualified counsel for decisions about elections, category transitions, and examination strategy.

Next Steps

• Open the CRA Compliance-Date Lookup
• Try the CRA Rating Qualifier
• Get the Coverage Gate Scoping Kit
• Read the 2023 CRA Final Rule Explainer
• Walk the Qualified Activity Anatomy
• Preview the Large-Bank Data Readiness Kit