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Question & Answer
Question: Our bank is close to $250 million in assets. We expect to reach that size before the end of 1997. When do we have to collect and report CRA data?
Answer: You begin to collect CRA data the year after you have reached large bank status ($250 million) for two years in a row. So if you have $250 million in assets by December 31, 1997, that does not yet trigger the reporting requirements. Data collection would begin after the bank is again $250 million or more in assets on December 31, 1998. Then, in 1999, the bank would begin to collect CRA data and report the data in 2000. The rule provides that the institution should reach the large bank size for two years in a row before the data collection requirement begins.
Copyright © 1997 Compliance Action. Originally appeared in Compliance Action, Vol. 2, No. 8, 7/97
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