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#2256936 - 07/20/21 01:25 PM HELOC Reporting After Acquisition
Mountaineers_Fan Offline
100 Club
Joined: Jun 2018
Posts: 100
Good morning everyone. I'm hoping that you can provide some input on a situation I'm working to find a solution to. My bank is acquiring another bank. We're both HMDA reporters however they aren't required to report HELOCs while we are. The guidance looks to be very gray on those loans in process that start under the acquired bank but action is taken under the acquiring bank. My assumption is that if my bank made the credit decision and/or final action then we're required to report these loans on our LAR.

Specifically, my concern lies with how to report GMI information on these in process loans when the acquired bank did not collect it at the time of application.

Has anyone been through this or have any insight to share?

As always thank you!

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#2257032 - 07/21/21 07:04 PM Re: HELOC Reporting After Acquisition Mountaineers_Fan
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,517
Bloomington, IN
If these are pending application during the merger process and no one from the surviving institution meets with the applicants during the application process then I would report "not provided" and keep track of the loans so if questioned at a later date I could document they were pending applications inherited from the merger.

The alternative would be to collect the information at closing although that would not technically be during the application process.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#2257048 - 07/22/21 01:14 PM Re: HELOC Reporting After Acquisition Mountaineers_Fan
Mountaineers_Fan Offline
100 Club
Joined: Jun 2018
Posts: 100
Thank you Dan. I appreciate your input!

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