We read in the Act the following...
ii) Rule for certain acquisitions, mergers, or reorganizations. When registered or licensed mortgage loan originators become national bank employees as a result of an acquisition, merger, or reorganization, only the requirements of paragraphs (a)(4)(i)(A), (C), and (D) of this section must be met, and these requirements must be met within 60 days from the effective date of the acquisition, merger, or reorganization.

Recently another bank acquired our Holding Company. But we will be operating under our original bank charter until later this year. In the last quarter of the year, our current charter will go away and we will be operating under the new bank charter.
The question is, when does the clock start? When our holding company was acquired just recently, or when we begin to operate under the new bank's charter later this year?
Thank you!!!

Right now, your bank, is still the same entity. From your post, it would seem that all you have done is switch holding companies - although I don't know how a bank acquires a holding company.