As shown below...I know this is regarding the actual data collection, but as the following scenarios show - I use this logic to carry forward into my public files as well. I am going through this right now and I will not be putting the HMDA disclosure for the non-surviving bank in my new CRA file.
The CRA Interagency Questions and Answers address the issue of merging
institutions. For your convenience, I have listed the Merger Q&A below.
§ __.42 – 5: When should merging institutions collect data?
A5. Three scenarios of data collection responsibilities for the calendar
year of a merger and subsequent data reporting responsibilities are
• Two institutions are exempt from CRA collection and reporting
requirements because of asset size. The institutions merge. No data
collection is required for the year in which the merger takes place,
regardless of the resulting asset size. Data collection would begin after
two consecutive years in which the combined institution had year-end assets
of at least $250 million or was part of a holding company that had year-end
banking and thrift assets of at least $1 billion.
• Institution A, an institution required to collect and report the
data, and Institution B, an exempt institution, merge. Institution A is
the surviving institution. For the year of the merger, data collection is
required for Institution A’s transactions. Data collection is optional for
the transactions of the previously exempt institution. For the following
year, all transactions of the surviving institution must be collected and
• Two institutions that each are required to collect and report the
data merge. Data collection is required for the entire year of the merger
and for subsequent years so long as the surviving institution is not
exempt. The surviving institution may file either a consolidated
submission or separate submissions for the year of the merger but must file
a consolidated report for subsequent years.
We hope this information helps,
The CRA Assistance Line