((2) Change in status. If an FDIC-supervised institution previously qualified for the exception in paragraph (c)(1) of this section, but no longer qualifies for the exception because it had assets of $1 billion or more for two consecutive calendar year ends, the FDIC-supervised institution must escrow premiums and fees for flood insurance pursuant to paragraph (a) for any designated loan made, increased, extended, or renewed on or after July 1 of the first calendar year of changed status.
We just reached the $1 billion in assets. I want to make sure I get this right, that if you have assets of $1 billion or more for two consecutive calendar year ends, you loose the exception. So, 1st calendar year would be 2018 and second 2019. Do we begin complying in July of 2018?