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#2229695 - 01/27/20 07:50 PM Merger of covered and non-covered institution
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
HYPOTHETICAL SITUATION:
1. Bank A is a HMDA covered institution
2. Bank B is a non-covered institution (low loan volumes and asset size exemption)
3. Bank A and Bank B complete a merger on September 1, 2019, with Bank A the surviving institution.
4. Bank A determined reporting of applications and loans with a final action date in 2019 originating with and handled by Bank B office or former Bank B offices was optional, based on comment 2(g)-4.ii.

Bank A also determined that some applications received by former Bank B offices will have final action dates in 2020.

QUESTIONS:
1. Will Bank A be required to report applications and loans received and handled by former Bank B offices ("Bank B applications") with final action dates in 2020?
2. With respect to Question 1, will the date of application (in relation to the merger date) make a difference?
3. What must Bank A do about Bank B applications with application dates prior to the merger date and final action date in 2020 if no GMI or DI was obtained? Can it report without that information?
4. What must Bank A do about Bank B applications with application dates on or after the merger date and final action date in 2020, if DI was not obtained? Can it report without that information?
Last edited by John Burnett; 01/27/20 08:14 PM. Reason: additional info
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John S. Burnett
BankersOnline.com
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#2267607 - 03/14/22 05:03 PM Re: Merger of covered and non-covered institution John Burnett
HMDAQueenBee Offline
New Poster
Joined: Sep 2015
Posts: 8
I've got a question to add on to this 2 year old question.

1. Bank A is a covered institution
2. Bank B is a non-covered institution (low loan volumes and asset size exemption)
3. Bank A acquires Bank B on February 14, 2022, with Bank A being the surviving institution
4. Bank A determines reporting of applications and loans with a final action date in 2022 originating and handled by Bank B office or former Bank B offices was optional based on volume.
5. Bank B sold all mortgage originated loans to 2 other originating institutions that made the underwriting decisions so Bank B didn't have to report.
6. Upon acquisition selling Bank B's mortgages ends as Bank A has their own mortgage department.
7. Are the applications and originated loans made by the mortgage department for applications that may be considered to have been received by Bank B offices or former offices reportable since technically the employees making these decisions were from Bank A before the acquisition or do they need to be kept off of Bank A's LAR since they would be considered to have been taken/originated from Bank B's offices? There are 2 other divisions in the bank that will start reporting in 2023, but currently are not due to the option to not report for the year that the bank was acquired.

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