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#25807 - 07/30/02 12:29 PM Consolidated HMDA Reporting
Denny Offline
Member
Denny
Joined: Jun 2002
Posts: 79
Pa
My Bank is scheduled to merge with another Bank in mid October. My Bank will be the surviving institution. Both Banks are currently subject to HMDA reporting and both have the same regulator. We are trying to decide if we should file seperate or consolidated HMDA reports for this year. We are not sure if we can file a consolidated report however because of the fact that the other Bank has been reporting Home Equity Lines of Credit while my Bank has not been reporting HELOC's. Does anyone have an opinion as to whether we would have to eliminate the other Banks HELOC's from the LAR before it is submitted for this year in order to file a consolidated report? Thanks for your help

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#25808 - 07/30/02 04:33 PM Re: Consolidated HMDA Reporting
Lestie G Offline

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Joined: May 2002
Posts: 3,608
Near the Land of Enchantment
We merged three charters together in the third quarter a few years ago. We filed a consolidated report simply because it was easier. I recommend you evaluate that before you make your final decision.

As for the HE's - I'm anxious to hear other opinions, but I think I wouldn't report them. That would be easier to document and explain, IMHO, than having to explain why some of the HE's are reported and some aren't since, by the time anyone looks, your portfolios will be mixed together. It is also more feasible than trying to go back to the first of the year and pick up reportable HE's from the charter that doesn't report them.

Be prepared for calls from the Fed, asking where the dissolving charter's HMDA report is. The Feds just don't have a good system for figuring out what reports they should be getting.
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#25809 - 07/30/02 05:34 PM Re: Consolidated HMDA Reporting
Michelle D Offline
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Michelle D
Joined: Oct 2001
Posts: 313
Terminator Country
I did this a couple of years ago at another institution. What we did to eliminate the "where's bank XXX's HMDA report", was to send a letter with the suriving bank's report (we were a large filer and couldn't go internet/e-mail) informing them of where bank XXX's HMDA data was. They didn't even call. I know most file electronically now, but I'd include an explanation in the email as to where bank XXX went.

Good Luck!!
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#25810 - 07/30/02 07:58 PM Re: Consolidated HMDA Reporting
Lestie G Offline

Power Poster
Joined: May 2002
Posts: 3,608
Near the Land of Enchantment
Wow! I guess I'll keep trying, then! I always send along messages about where the other banks went, and I still get phone calls (some of them kind of nasty!). Maybe the person who handles my region is much less organized than the person who handles yours!
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