Page 118 of the 2021 HMDA Reporting Getting it Right manual (GIR)
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. Comment 3(d)-3.iii.
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The opinions expressed are mine and they are not to be taken as legal advice.