Our bank has been acquired and will soon be merged into the surviving institution. Pre-merger the two banks will have separate LARs, and post-merger we will have a combined LAR for the rest of this year. Our bank does not report open end lines of credit, but the acquiring bank does report them. One of our lenders is working on a dwelling secured open end line of credit used to purchase residential real estate. Our bank will make the credit decision pre-merger, but the loan is likely to originate post-merger in the name of the surviving institution. Do we not report this line of credit because our bank, which doesn't report lines of credit, made the credit decision? Or do we report it because the surviving institution does report lines of credit and the loan will be originated by the surviving institution?

From the Small Entity Compliance Guide, section 8.2:

"If an institution that is subject to Regulation C and an institution that is not subject to Regulation C merge, and the surviving or newly formed institution is subject to Regulation C, for the calendar year of the merger, data collection is required for Covered Loans and Applications handled in the offices of the institution that was previously subject to Regulation C. For the calendar year of the merger, data collection is optional for Covered Loans and Applications handled in offices of the institution that was not previously subject to Regulation C."

Thanks for your response Adam. I think the part that threw me off was "institution not subject to Reg C" since we are subject to Reg C for closed end reporting, but that makes sense that it would also apply to a category of transactions.