We have merged with a smaller institution. They are small and exempt from reporting the expanded fields. We are not. I'm confused as to what the options are.

File one LAR with all data fields.
File one LAR with expanded fields for our data and not for the acquired bank.
File two LARs for the entire year, one for the acquired institution (no expanded fields) and one for our institution (expanded fields)
File two LARs, one for the acquired institution up to the merger date (no expanded fields) and one for our institution (expanded data) which would include the acquired institution, post merger)

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.

If a Financial Institution that is eligible for the partial exemption for closed-end mortgage loans
merges with a Financial Institution that is not eligible for the partial exemption and the
surviving or newly formed Financial Institution is not eligible for the partial exemption, for the
calendar year of the merger, collection of optional data for closed-end mortgage loans is
required for covered loans and applications handled in the offices of the merged Financial
Institution that was previously not eligible for the partial exemption. For the calendar year of
the merger, collection of optional data for closed-end mortgage loans is permitted but not
required for covered loans and applications handled in the offices of the merged Financial
Institution that was previously eligible for the partial exemption.

OK...so after reading that 5 times.....I'm not as smart as are...LOL....

Bank A not exempt
Bank B exempt
Bank B surviving institution

This tells me that....
ALL applications taken after the merger date by Bank B must be reported with the expanded fields.
Applications submitted to Bank A prior to the merger, can be reported with or without the expanded fields.

BUT....although paragraph 2 doesn't address it, I would assume that if Bank A will NOT be reporting the expanded fields, Bank B cannot file a consolidated submission because all the loans missing the optional data with have validity edits.

I would say that would be a correct assumption, as it is not really addressed.