HYPOTHETICAL SITUATION:
1. Bank A is a HMDA covered institution
2. Bank B is a non-covered institution (low loan volumes and asset size exemption)
3. Bank A and Bank B complete a merger on September 1, 2019, with Bank A the surviving institution.
4. Bank A determined reporting of applications and loans with a final action date in 2019 originating with and handled by Bank B office or former Bank B offices was optional, based on comment 2(g)-4.ii.
Bank A also determined that some applications received by former Bank B offices will have final action dates in 2020.
QUESTIONS:
1. Will Bank A be required to report applications and loans received and handled by former Bank B offices ("Bank B applications") with final action dates in 2020?
2. With respect to Question 1, will the date of application (in relation to the merger date) make a difference?
3. What must Bank A do about Bank B applications with application dates prior to the merger date and final action date in 2020 if no GMI or DI was obtained? Can it report without that information?
4. What must Bank A do about Bank B applications with application dates on or after the merger date and final action date in 2020, if DI was not obtained? Can it report without that information?
Last edited by John Burnett; 01/27/20 08:14 PM. Reason: additional info
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8