As of 12/31/20, our assets exceeded the large bank threshold of $1.322 billion. We anticipate that we will maintain this level in 2021 and, therefore, be considered a large bank starting in 2022. The “Current and Historical Asset-Size Thresholds and Examples” document on the CRA Examinations page of the FFIEC website says the following: Large banks are subject to CRA loan data collection, but cannot be examined under the large bank examination procedures until they have at least one full year of data collected.
So, to make sure we prepare for the transition appropriately, is 2022 the first year that we will be required to collect and report data with our first exam as a large bank not possible until 2023?
Assuming you meet the 2022 threshold on both Dec. 31, 2020 AND 2021, you would meet the large bank criteria for 2022 and should begin collecting data at that time. Once you have collected a full year of data you will be subject to examination under the large bank procedures, which under this scenario would be 2023 at the earliest. It is good that you are anticipating this change and will be ready to comply. When you are expecting transitions like this to occur it is a good idea to communicate with your examiners along the way to ensure there are no surprises for you or them.