We currently qualify for the Balloon Payment QM loans. We are going to be merging with another bank later this year and I am trying to figure out how we determine if we will continue to qualify for this after we merge. The part I am trying to work through is the portion that states "originate not more than 500 first-lien, closed end mortgages".

What will we add to our existing numbers? The loans they originated Jan 1, 2014 through the merger date or will we only need to add any loans they generate after the merger?

Until the date of the merger, each bank continues along as is. On and after the date of the merger, the surviving bank combines the counts for the year of the two banks.

For example, if A and B are merging and the surviving bank is A, and the merger date is 9/1/14. Bank A originates 150 loans from 1/1/14 through 8/31/14 and Bank B originates 348 loans for the same period. Assuming no loans close on 9/1/14, Bank A counts 150 + 348 = 498 loans originated to date. Bank B no longer cares.