We have recently acquired two branches of another bank, along with the customers base from those two locations. We are wondering about the CIP violations that we seemed to have "inherited" from these two locations. Are these now our issues or does it fall under the bank of account opening? We are the second bank to own these two particular locations. Any information or guidance is appreciated.
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Our bank has a conversion scheduled for January 3rd as we are acquiring another bank and need assistance with the following questions:
1. Will the bank we are acquiring be responsible for filing their own HMDA for 2016?
2. Will this data be included in any exam for our bank since it was prior to the acquisition?
3. What impact will the existing HMDA 2016 data be for our bank?
Our BHC previously held an FDIC, state-chartered bank and a trust company as separate entities. The trust company is now in the process of becoming a wholly-owned subsidiary of the bank. The long-time personnel of the trust company will continue to operate the trust company as it always has. Since the regulatory oversight for the trust company will now shift from the FRB to the FDIC, is it acceptable for the trust company to maintain its existing policies and procedures separate from those of the bank?
If a bank acquires another bank, can the acquiring bank enforce a signed guaranty pledged by a customer to the acquired bank?
Identifying potential red flags can help develop effective compliance program
by Mary Beth Guard, BOL Guru