[Jody]

We are a bank that reached total assets of $1 billion plus during 2015. I am getting hung up on the word either in 339.5(c)(1)(i) and the word consecutive in 339.5(c)(2).

Since we have not had assest of $1 billion for two consecutive years are we a small lender?

339.5 Escrow Requirement. (c)(1)(i) That has total assets of less than $1 billion as of December 31 of either of the two prior calendar years; and ….

339.5 Escrow Requirement (c)(2) [C]hange in status…has assets of $1 billion or more for two consecutive calendar year ends, the FDIC-supervised institution must escrow premiums and fees for …

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