This is our first year as a CRA Large Bank. We exceeded the threshold at the end of 2020 and 2021. Our last exam was in mid 2020 and we were examined as an intermediate Small Bank. Our next exam should be either end of 2022 or early 2023. Does that mean the examiners would be examine us as a large bank or because two of the three years were as an intermediate small bank we would still be under those rules?

We had the same situation a few years ago. Since we hadn't submitted a CRA small business/farm LAR by the time of the exam, they didn't have the data required for a large bank exam, so we were examined under ISB criteria. Reach out to your regulators to see how they will approach it.

You will be examined as a Large Bank in the second year after you qualify as a large bank. This is to allow the bank time to collect and report the data.

"Large banks are subject to CRA loan data collection, but cannot be examined under the large bank examination procedures until they have at least one full year of data collected."

Thank you. I will double check with our regulator.