I would like to also include community development loans. We merged with a bank that did not meet the reporting threshold (we do) in the middle of our exam period. Can we count any CDL's they originated prior to the merger but are still in our exam period?
According to the
FFIEC guide, the bank that was already required to report must report, but data collection for the smaller target is optional for the year of merger. For subsequent years, the combined institution must report.