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#2237976 - 06/11/20 10:43 PM CRA Investments - Merger/Acquisition
BSA_in_depth Offline
Member
Joined: Jun 2006
Posts: 99
Texas
Does anyone know how the qualified investments of an acquired institution are treated after the acquisition? Does the acquiring bank get any credit for the investments made by the acquired bank before the acquisition or would they only get credit for the CRA qualified investments that carried over from the acquisition?

Thank you in advance!

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CRA
#2281519 - 02/24/23 03:47 PM Re: CRA Investments - Merger/Acquisition BSA_in_depth
Comply13 Offline
Member
Joined: Nov 2013
Posts: 54
USA
I would like to also include community development loans. We merged with a bank that did not meet the reporting threshold (we do) in the middle of our exam period. Can we count any CDL's they originated prior to the merger but are still in our exam period?

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#2281562 - 02/24/23 08:10 PM Re: CRA Investments - Merger/Acquisition Comply13
InFairness, CRCM Offline
Platinum Poster
InFairness, CRCM
Joined: Nov 2010
Posts: 957
USA
Originally Posted by Comply13
I would like to also include community development loans. We merged with a bank that did not meet the reporting threshold (we do) in the middle of our exam period. Can we count any CDL's they originated prior to the merger but are still in our exam period?

According to the FFIEC guide, the bank that was already required to report must report, but data collection for the smaller target is optional for the year of merger. For subsequent years, the combined institution must report.
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Opinions are strictly my own, and have nothing to do with my employer.

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#2281649 - 02/27/23 11:15 PM Re: CRA Investments - Merger/Acquisition BSA_in_depth
Lori01 Offline
100 Club
Joined: Jan 2007
Posts: 184
VT
My bank was able to get credit for a couple of investments we "took over" including outstanding LIHTC.
We didn't try for CD loans because any the bank we took over were in a different AA, which we were not examined on. Our merger was toward the beginning of a year and the exam was towards the end.

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#2281650 - 02/27/23 11:19 PM Re: CRA Investments - Merger/Acquisition BSA_in_depth
BSA_in_depth Offline
Member
Joined: Jun 2006
Posts: 99
Texas
We were able to receive credit for the community development loans originated by the acquired institution. We presented them as purchased loans and recorded the amount as the outstanding balance on the day of acquisition.

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