Under the new CRA rule, the asset size is greater or equal to 2 billion and that is effective 1/1/2026. So for a bank that is currently a large bank ($1.677 billion), assuming it does not reach the 2 billion threshold, at what point does it stop collecting and reporting? I am unsure when the two prior calendar years start.

The current threshold for large banks still applies ($1.564 B) and that dictates if you are a mandated reporter. I always tell my ISB clients they should voluntarily report their data and there are some good reasons to do so.