We acquired multiple banks through merger and FDIC assisted transactions. Both the acquiring bank and acquired banks were HMDA and CRA Reporters.

I understand that the acquiring bank can opt to file separate HMDA LARs or a combine HMDA LAR for the transactions that occurred prior to the acquisition date. The same is true CRA. If we decide to file a combined HMDA LAR or a combined CRA LAR are the transactions from the acquired banks considered originated or are they purchased?

They are originated.

Thank you. Have a great weekend!

For HMDA you also need to report the applications that didn't result in an origination.