We are doing a merger this year and acquiring another covered institution.
I know we have the option of reporting a consolidated report or 2 separate reports.

During the HMDA Data Verification Exam, is the surviving institution "responsible" for any errors found for loans made by the other bank prior to the merger?

An acquiring bank always assumes all sins of the acquired institution.

The last merger we did we scrubbed all of the acquired institutions HMDA files. We filed a consolidated report and we had subtle differences (i.e., action date definition, etc.) that needed to be reviewed and changed.

Glad we did or their "sins" would have been ours!

The volume compared to staffing makes that nearly impossible for us.

I have been involved with some smaller bank mergers. Acquiring bank was advised to file separately. Old bank goes away and no one to penalize. May not work for all banks, but that is the advice they were given. Kind of a win win for examiners too, Maybe that was because they were so overwhelmed with TRID that they were happy to ignore the under 200 lines on the old bank's LAR.