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#1601920 - 09/09/11 07:08 PM You just can't find this stuff.
JUST CALL ME CRA Offline
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I am transitioning to a new bank due to an FDIC takeover. There is just nothing out there to answer some of this.

The new bank is actually assuming all of the deposits and some of the assets of the failed bank. Shortly after, the new bank began to close branches. In the public file, do I list all the branches as purchased (opened) as of the takeover date and then show the closings for the ones that are closed? The old bank signs were removed immediately and the new bank's signs were posted so they were operating as branches of the new bank.

Also, the new bank had a regular merger a few months ago and they do not show any of those branches in their public file which, I know, is supposed to be current as of 4/1/11. In that case, the purchase was final as of 1/1/11 but they operated the branches under the former bank's name until some time in May. Which date is used?

I just don't think there are commentaries or any written clarification on any of this. If there is, I can't find it.
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#1602011 - 09/09/11 08:20 PM Re: You just can't find this stuff. JUST CALL ME CRA
Pale Rider Offline
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With reference to the merger occuring 1/1/11, that is when the public file should be amended with the new locations. It doesn't matter they operated in a transition period under the old name. Legally they were your bank branches on the date of acquisition.

I thought there was something in the Q&A about assisted acquisitions, so maybe KB or others can help you with the first question.
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#1602053 - 09/09/11 09:21 PM Re: You just can't find this stuff. Pale Rider
Khaleesi Offline
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We had the same situation with branches acquired.

They were open for only a few months after we took over the failed bank.

I listed them as opened and also in branches closed.
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#1602073 - 09/09/11 11:12 PM Re: You just can't find this stuff. JUST CALL ME CRA
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
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Originally Posted By: I Love My Job
I am transitioning to a new bank due to an FDIC takeover. There is just nothing out there to answer some of this.

The new bank is actually assuming all of the deposits and some of the assets of the failed bank. Shortly after, the new bank began to close branches. In the public file, do I list all the branches as purchased (opened) as of the takeover date and then show the closings for the ones that are closed? The old bank signs were removed immediately and the new bank's signs were posted so they were operating as branches of the new bank. Yes, the new bank took over at the closing of the old bank by the FDIC and that bank no longer existed-unless there was some special provision of the FDIC closing. Check the announcement of what was happening day one to the "old bank" branches.

Also, the new bank had a regular merger a few months ago and they do not show any of those branches in their public file which, I know, is supposed to be current as of 4/1/11. In that case, the purchase was final as of 1/1/11 but they operated the branches under the former bank's name until some time in May. Which date is used? In this case, you need to find out if they operated under one charter or two. They could have bought a bank and operated as two banks. You need to find out. Or they could have operated under one charter and the purchased bank was operated under a trade name...ABC Bank (the purchaser) trading as XYZ Bank (the purchased). Or XYZ Bank, a division of ABC Bank.

You will have to do a little digging and checking with legal or bank admin staff to find out how the purchase was handled.


I just don't think there are commentaries or any written clarification on any of this. If there is, I can't find it.
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#1602478 - 09/12/11 06:50 PM Re: You just can't find this stuff. Kathleen O. Blanchard
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Joined: Aug 2002
Posts: 133
SOMEWHERE
Thank you. Very helpful.
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