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#2256073 - 06/28/21 08:20 PM Partially Exempt Bank Acquired
Mountaineers_Fan Offline
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Joined: Jun 2018
Posts: 89
I've searched through the Small Entity Guide but does anyone have insight on when a partially exempt bank is acquired by a bank that is required to fully report?

My gut tells me that the partial exemption would still apply when compiling the LAR for the acquired bank for any loans prior to acquisition. However, I'd like some confirmation of this.

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#2256075 - 06/28/21 08:36 PM Re: Partially Exempt Bank Acquired Mountaineers_Fan
Dan Persfull Online
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Dan Persfull
Joined: Aug 2002
Posts: 46,417
Bloomington, IN
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.

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#2256076 - 06/28/21 08:37 PM Re: Partially Exempt Bank Acquired Mountaineers_Fan
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 77,238
Galveston, TX
.3(d) - Comment 3(iii) Assume an institution that is eligible for the partial exemption for closed-end mortgage loans merges with an institution that is ineligible for the partial exemption and the surviving or newly formed institution is ineligible for the partial exemption. For the calendar year of the merger, collection of optional data as defined in ยง 1003.3(d)(1)(iii) for closed-end mortgage loans is required for covered loans and applications handled in the offices of the merged institution that was previously ineligible 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 institution that was previously eligible for the partial exemption. When an institution that is ineligible for the partial exemption for closed-end mortgage loans acquires a branch office of an institution that is eligible for the partial exemption, collection of optional data for closed-end mortgage loans is permitted but not required for covered loans and applications handled by the acquired branch office for the calendar year of the acquisition.
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#2256114 - 06/29/21 04:56 PM Re: Partially Exempt Bank Acquired Mountaineers_Fan
Mountaineers_Fan Offline
Member
Joined: Jun 2018
Posts: 89
Thank you both. I must have missed it. I greatly appreciate it!

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