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.
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