We will be acquiring another bank later this year. This bank is very small and never reported loan information to the credit reporting agencies. We (the acquirer) have always reported loan information to the CRAs.

My questions are as follows: Once the conversion is final, and all the other bank's existing loans are on our system, can we just start reporting information to the CRA like we do with our loans? Do we need to first disclose to these borrowers the fact that we will begin doing so?