I'd suggest reaching out to your examiner for clarification.
During our most recent merger, neither of us were subject to the reporting requirements. Our examiner let us provide community development, service, investment, and donation information for all merged institutions during the exam scope...even though it went back farther than the merger dates. The "cut off" for including data was the prior CRA exam date for the merged institution.
I don't need any more negativity in my life...be positive and helpful people or I will kick you in the shins!!!