To be considered a large bank,
does it have to be two consecutive years at 12/31 over 250 or are you considered a large bank the very first year after being at $250 or higher?

A small institution is a state member, state nonmember or national bank that, as of December 31 of either of the prior two calendar years, had total assets of less than $250 million and was independent or an affiliate of a holding company that, as of December 31 of either of the prior two calendar years, had total banking assets of less than $1 billion.

Yes. I get that; but, unfortunately, I still don't know the answer to my question. I think the reg definition is confusing. Anyone?

Short answer: NO.

"A small institution is a ... that, as of December 31 of either of the prior two calendar years, had total assets of less then $250 million..."

To be considered a large bank, you have to report 2 consecutive years > $250MM on Dec 31. AR.

Thank you AnonRegulator. Two consecutive years of $250 or more, we'll go with.

And hopefully in year 3 the reg will change and you'll still be small