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#2190018 - 08/21/18 09:52 PM LEI/ULI in a Merger Year
bOaty Offline
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bOaty
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Many months ago when I had this conversation it was pretty inconclusive so I'm going to open this conversation back up.

Has anyone got any guidance about what to do with the LEI and or ULI in a merger year? We are going to file a consolidated report. I'm not sure if we should file the loans made prior to legal day 1 with the old LEI our the surviving institution's LEI.

Has anyone had this conversation with their examiner?
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#2190162 - 08/22/18 07:12 PM Re: LEI/ULI in a Merger Year bOaty
bOaty Offline
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I asked the CFPB and here is the very unhelpful response that I got:

Thank you for contacting the Bureau of Consumer Financial Protection (BCFP) with your question.

The ULI should consist of your institution’s Legal Entity Identifier (LEI), a Loan/Application ID number, and a two digit check digit. The Loan/Application ID component of the ULI should contain at least one character and follow these requirements:

• May be letters, numerals, or a combination of letters and numerals;
• Must be unique within the financial institution; and
• Must not include any information that could be used to directly identify the applicant or borrower

Thank you,
BCFP HMDA Help
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#2190174 - 08/22/18 07:53 PM Re: LEI/ULI in a Merger Year bOaty
Adam Witmer Offline
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Very helpful, indeed.
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#2190180 - 08/22/18 08:10 PM Re: LEI/ULI in a Merger Year bOaty
David Dickinson Offline
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Central City, NE
Wow! I hope someone from the CFPB reads this post and can see how unhelpful this is.
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#2190188 - 08/22/18 08:34 PM Re: LEI/ULI in a Merger Year bOaty
bOaty Offline
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Any ideas? Or, shall we just take a stab at it and figure it out three years from now at exam time? laugh
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#2190189 - 08/22/18 08:43 PM Re: LEI/ULI in a Merger Year bOaty
rlcarey Offline
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Galveston, TX
You have the option to combine or report separately also.

If two or more institutions that are subject to Regulation C merge and the surviving or newly formed institution is also subject to Regulation C, data collection is required for the entire calendar year of the merger. The surviving or newly formed Financial Institution files either a consolidated submission or separate submissions for that calendar year.
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#2190211 - 08/22/18 11:34 PM Re: LEI/ULI in a Merger Year bOaty
bOaty Offline
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We would like to combine to show penetration into the new areas for our CRA exam.
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#2230409 - 02/06/20 06:42 PM Re: LEI/ULI in a Merger Year bOaty
ckme Offline
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Joined: Sep 2002
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We have the same scenario for 2019. We merged in October and will be filing separate LARs. I was going to use the ULI for the loans they originated up to legal date and ours for the loans they originated after legal date. Any opinions or comments on how you handled yours in the past?

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#2231338 - 02/19/20 09:53 PM Re: LEI/ULI in a Merger Year bOaty
J_Compliance Offline
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Joined: Apr 2018
Posts: 11
bOaty did you received any more guidance? What did you end up doing? I'm in the same situation you were in. I want to submit a combined LAR but not sure who's LEI to use for the loans of the acquired institution up until the acquisition date. The acquired bank's LEI or our LEI (the surviving bank)?

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#2231374 - 02/20/20 04:41 PM Re: LEI/ULI in a Merger Year bOaty
J_Compliance Offline
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Joined: Apr 2018
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Questsoft support indicated the CFPB website will not accept a LAR with multiple LEIs. If the CFPB allows one combined LAR to be submitted they must be ok with the surviving bank's LEI being used for all loans? Anyone?

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#2231383 - 02/20/20 05:52 PM Re: LEI/ULI in a Merger Year bOaty
bOaty Offline
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Hi J_C. Questsoft is correct, you will use your Bank's LEI (the surviving institution).
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#2231399 - 02/20/20 06:45 PM Re: LEI/ULI in a Merger Year bOaty
J_Compliance Offline
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Thank you!

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#2231689 - 02/25/20 10:14 PM Re: LEI/ULI in a Merger Year bOaty
Ree Offline
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Joined: Mar 2016
Posts: 56
I want to reopen this topic. We have opted to report 2 separate LAR's. Does anyone have any experience with uploading 2 separate LAR's after a merger? I believe your credentials will only allow 1 file to be uploaded per LEI per year. In order to submit a separate LAR under my credentials, it looks as if I have to add another LEI to my credentials. Has anyone done this? If so I'd like to know how you go about doing so and would I add our institutions contact info at the top of the text file we are submitting for the other financial institution we acquired?

I hope my question isn't too confusing. Just trying to figure our the correct way to submit after a merger.

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#2238835 - 06/30/20 04:47 PM Re: LEI/ULI in a Merger Year Ree
Compliance Chick Offline
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I am interested in what you ended up doing? this will be situation next filing year.
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#2239621 - 07/15/20 04:08 PM Re: LEI/ULI in a Merger Year Compliance Chick
Reads Regs Offline
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My bank had some recent acquisitions. I had to reach out to CFPB HMDA help and advise them which institution we acquired. They did something on their end that allowed me to file a separate LAR earlier this year with the activity of the bank we acquired last year with activity from 1/1/2019 through our legal day one. I had no issue filing.

We just acquired a bank as of 4/1/2020 and I reached out to the CFPB and they did something similar so I could submit the other bank’s first quarter data to the CFPB’s beta HMDA platform for 2020. It worked okay. I will have to see if it goes smoothly when I file their 2020 LAR early next year.
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#2239898 - 07/21/20 02:48 PM Re: LEI/ULI in a Merger Year bOaty
swiggles Offline
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So......if we acquired a partially exempt institution (my bank is large and so we collect all the data), and we opt to file one lar using my Bank's LEI, must we go back and pick up all the extra data from the smaller bank? Otherwise, I think we'll have V edits out the wazoo for missing data.
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