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#2266326 - 02/14/22 08:39 PM Merger
jel99 Offline
Junior Member
Joined: Sep 2021
Posts: 27
We are merging with another institution in mid-2022 and we both currently submit annual HMDA files.

For 2023 annual submission, we will file two separate submissions, one with the old banks information and records from Jan 1-Date of merge and another with our bank's information and records, correct?

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#2266333 - 02/14/22 09:00 PM Re: Merger jel99
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,793
Cape Cod
The answer is in Comment 2(g)-4, Merger or acquisition—coverage for calendar year of merger of acquisition. Paragraph iv. of that comment says, in pertinent part:
Quote
Two covered institutions merge. The surviving or newly formed institution is a covered institution. Data collection is required for the entire calendar year of the merger. The surviving or newly formed institution files either a consolidated submission or separate submissions for that calendar year. ....

In short, you have two options. You can go either way as long as all the applications and loans with final action dates in 2022 are reported.
Last edited by John Burnett; 02/14/22 09:03 PM. Reason: typo
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John S. Burnett
BankersOnline.com
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#2266343 - 02/14/22 09:27 PM Re: Merger John Burnett
jel99 Offline
Junior Member
Joined: Sep 2021
Posts: 27
If we decide to do two submissions, will one be required to have the old bank's information (Tax-ID, LEI, etc.) or will both submissions be submitted under the surviving institution's information?

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#2266351 - 02/14/22 10:23 PM Re: Merger jel99
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,793
Cape Cod
The surviving institution files using its own identity whether it make one submission or two.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

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