Our bank announced it is merging with another larger bank. We are planning to keep our name/brand for our current market area "as a division of" the main bank (one charter under that bank's name). (Please don't ask for details on this as many of us do not understand this aspect either.)

Do we have the option to file our HMDA LARs separately? If so, do we now have to share an LEI or do we keep our separate LEIs?

If we file together, how do we handle that for transactions made before we merged onto their charter? Example - if the merger is in effect March 1, 2020, how do we handle apps/loans for HMDA that had final action taken Jan 1-Feb 29, 2020?

If anyone has other thoughts on other affected areas of a merger please let me know. We will be well below the 60K HMDA reportable loans mark, so no quarterly reporting requirements.
We will be below the $2.167B asset threshold so we can still use the small creditor portfolio loan QM option for our loans that we keep in house.
We will be below the 5,000 mortgage loans so we can still use the small servicer exemptions in RESPA.
Any other thoughts?

Thank you!

https://www.ffiec.gov/hmda/pdf/2019guide.pdf

Start on page 7.

Thank you DeeQ!
After reading through that document, it appears that the bank acquiring us will be responsible for reporting HMDA data.
It appears that during the year of the merger (i.e. 2020), data collected that year and reported in 2021 by them can either be done through separate LARs or one combined LAR.

However, I am still unclear if, during the year of that merger, we report separately...would the records from 'our bank' use our current LEI or would we use the other bank's LEI?

Also, for the year after the merger, does this mean that our records must all be reported together going forward? Or can they still be separate? It seems to just address the "year of", but maybe all subsequent years are implied that our data must be reported together with one submission.

Thanks for any thoughts on this.

Speaking from experience, my bank was acquired by a larger bank in 2014. As the acquired bank, I did
not file 2014 data, they did. How they filed, I have no idea. Nor do I care after being jettisoned by them.

Did you ever get an answer on this? what did you do for the 2020 filing regarding the LEI's?

Well to start off...since the original post, we learned from examiners we could not retain our former Bank's name, so we fully switched to new bank's name at merger. (We could have retained it but it would have been a LOT of work and requirements so they just sadly dissolved our former bank name).

We are reporting our (former) Bank's LAR from Jan 1st - day before merger 2020 (a few months' worth of data). It will be in our (former) Bank's name and LEI.

For all files with action taken on or after merger date, they were transferred to the current Bank's system, and are reported on their 2020 LAR with their LEI, etc.

Current Bank has acquired other banks and said this is how they did that with those. Luckily, I retained my position on the Compliance team so I'm still part of the HMDA reporting.

Thanks for checking, @Compliance Chick!