If a bank exceeds the threshold in 2020, does it begin to report data in 2022 or 2020?
Thank you.

I believe you start reporting when you become a large bank. You won't be examined as a large bank until you have reported your data for a sufficient amount of time.

The definition of small bank (which includes ISB) states that a small bank is below the threshold on 12/31 on either of the two prior calendar years. So if you just exceeded the threshold (and will be above on 12/31/2020), you will still be a small bank in 2021. You will become a large bank in 2022, assuming your assets continue to exceed the small bank threshold.

(u) Small bank--

(1) Definition. Small bank means a bank that, as of December 31 of either of the prior two calendar years, had assets of less than $1.305 billion. Intermediate small bank means a small bank with assets of at least $326 million as of December 31 of both of the prior two calendar years and less than $1.305 billion as of December 31 of either of the prior two calendar years.

Thank you! I wanted to make triple sure! Technically the bank then will continue to be categorized as a ISB until after 2 years it exceeded the threshold.

You should anticipate the transition. We suggest you report data this year even though you are not technically required as an ISB. This will also provide you the option to be examined as a large bank. Frankly, I think passing a large bank exam is easier than an ISB exam which absolutely requires satisfactory performance on the CD part, whereas you can do rather poorly regarding CD activity on the large bank exam and still get a composite satisfactory PE.