Our holding company has Bank A that was regulated by the OTS until January 2009 and then it was acquired by the holding company's affilate Bank B, which is regulated by the FDIC.
Bank A's last CRA Exam was through December 31, 2007. There is a period of time (January 1, 2008 through January 2009) where the Bank was still regulated by the OTS, but Bank B's next CRA examination will be conducted by the FDIC and include that time period (January 2008 - January 2009).
Will the CRA activities and transactions that occured during the January 2008 - January 2009 time period for Bank A (during regulation by the OTS) be considered in the FDIC Exam?
I hope I've explained this well enough!