Hello,

We are acquiring a bank that is a HMDA reporter. Legal day one is 9/15. If we decide to file separate reports, at what time will the acquired bank need to file their LAR? Do they file at closing (9/15) or do we file on their behalf in March 2018?

Thanks in advance!

We did this a few years ago. The deadline is still March 1st. One thing that concerned me was the reporting status of loans closed before merger date that didn't get sold to the investor until after merger date. Our regulator (FDIC) confirmed that they were considered sold in the reporting year even if the loan sale was completed after merger date, as long as it happened prior to year-end.

Bumping this - we acquired a bank and decided to file HMDA separately. Now that we're ready to push the button, it's only giving us the options of the two banks owned by the holding company, both of which have separate LARs that are also about to be filed.

We may have totally messed this up, but we have the file for the acquired bank showing it's former name, respondent number, former regulator, etc. We're stuck at the point of the upload to CFPB.

I did this once at a former institution 6 years ago - there was a code tacked onto one of the transmittal fields that let the FED know it was the last filing for that institution. You might contact HMDA Help for details on how to file.

Contact your regulator to get the revised respondent number to use. Our regulator (FDIC) sent an email ahead of time asking how we were going to handle our final HMDA data, combined or separate filing.

Ask around. Someone at the bank might have already had this conversation but forgot to pass the information on to you.