If 2 HMDA reporters merge, and it has been decided to submit HMDA separately during the merger year, how would I account for denials given the fact that the bank that will be going away during the merger is FDIC-regulated and the survivor bank is FRB regulated?

FDIC banks do not have to record denial reasons. However, when submitting the final HMDA file, we will be part of an FRB bank. Well, actually we will be CFPB-covered after merger.

We were FDIC regulated and they took the optional reporting away and we had to report the denial reasons on the bank's HMDA LAR.

Under current rules, the only FDIC institutions that are mandated to report denial reasons are former OTS institutions that moved to the FDIC. That has caused confusion for FDIC institutions.

Whew. I wasn't looking forward to back-filling my HMDA data with denial reasons.

P.S. I asked HMDAHELP several weeks ago but haven't gotten a response yet.

It was always the OCC and the OTS that required reporting. OTS institutions went with either the OCC (federally chartered) or FDIC (state chartered). They retained the mandatory reporting due to wording of the rule regardless of where they ended up.

I have a related question regarding how to report with an Institutional name change coming in September. There is no merger or acquisition, simply a name change. I am trying to find out if there will also be a respondent ID/Regulator change. I don't find any citation that tells me that we would need to report two LARs (1 under the prior name and 1 under the new name) although this is what is being suggested. Does anyone have anything that I could point to?

Your best bet is to check with your regulator regarding your particular situation.