I just want to get clarification on this. It was announced yesterday that we will be merging with another bank and we will be the surviving institution. When the transaction is completed do all loans that are HMDA and CRA need to be entered on our LAR's as purchased loans. I believe that they would accoriding to my research, however I just want to get some additional input. Thanks

In most cases, they're not going to be purchased loans (unless your "merger" transaction was really strange). If you truly did just purchase the other bank's portfolio (and didn't acquire the whole entire institution) - then you have to report every single reportable loan in their portfolio - not just the current year stuff. That is a potential nightmare that you want to avoid.

The two guides (Getting It Right) list your options for reporting when two institutions merge. They give you several scenarios to choose from as well. When we acquire a bank, we usually choose to merge their HMDA LAR into ours and report as one bank. Same with their CRA LR. If the acquired institution isn't a HMDA reporter, or a CRA reporter, then we typically just pick up their activity starting with the acquisition date.

You might choose another of the options available - you just have to determine what is best for your particular situation.

A new investment group purchases a state bank that has been around for several years (small bank under CRA). The new group changes the name of the bank but retains the same charter number. Does the CRA public file for the newly named bank need to contain the former bank's CRA performance evaluation until the newly named bank gets an evaluation?

CRA is charter specific. Keep the "old state bank" PE in the public file. I'd suggest that you make a note and attach it to the PE stating "The former name of the bank is X. We changed the name of the bank to X on X date."

This is not that uncommon, especially when two bank merge and obtain a new charter number. In that case, the PEs of the "former banks" are typically maintained in the public file, until a NEW PE is written for the newly created bank.