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#1497867 - 01/20/11 07:08 PM Reporting requirements for mergers
odimel2 Offline
100 Club
Joined: Sep 2008
Posts: 140
Las Vegas, NV
We have bank A, who only met the asset size threshold last year but decided to report anyways.
We have bank B, who did not meet the asset size threshold for 2 years and did not report.

They both merged under a new name starting this year but bank B will still do business as their previous/current name.

What would be the reporting requirements?

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CRA
#1497900 - 01/20/11 07:38 PM Re: Reporting requirements for mergers odimel2
Tennismom Online
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Tennismom
Joined: Jan 2004
Posts: 778
See page 8 of 9 in the 2010 CRAHMDA Reporter

http://www.ffiec.gov/hmda/pdf/10news.pdf

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#1497939 - 01/20/11 08:06 PM Re: Reporting requirements for mergers Tennismom
odimel2 Offline
100 Club
Joined: Sep 2008
Posts: 140
Las Vegas, NV
thank you for the reference. Would a name change be considered as a "New Institution?"

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#1498068 - 01/20/11 09:19 PM Re: Reporting requirements for mergers odimel2
Tennismom Online
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Tennismom
Joined: Jan 2004
Posts: 778
I would outline the transaction just like you did in this thread and e-mail the information (see information to include below) to CRAHELP@frb.gov. They should be able to give you some guidance.


All respondents that have an institution involved in a merger or acquisition of a branch should send an e-mail to HMDAHELP@frb.gov detailing the merger, the HMDA Respondent IDs, regulatory agencies for the survivor and non-surviving institution(s), and how the filing will be handled (i.e., consolidated submissions or separate reports) for the year of the merger and subsequent years.

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#1498079 - 01/20/11 09:27 PM Re: Reporting requirements for mergers odimel2
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
Also, ignore the fact that the other bank will continue to trade under their old name. If the charters have been merged, it is legally one bank and the other bank is just operating as a division. One charter equals one bank.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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