Reporting data for Bank Acquisitions

Posted By: KelliD

Reporting data for Bank Acquisitions - 03/29/17 04:08 PM

Is the acquiring bank required to report CRA activities for the acquired bank which were made prior to acquisition/merger? I think it is optional but want to double check. We are scheduled for an exam later this year so I want to be sure I am prepared. If this is optional, is there a good reason we would want to include?

Thank you in advance!
Posted By: Tennismom

Re: Reporting data for Bank Acquisitions - 03/30/17 02:29 PM

See page 4 and 5 (Mergers) of the A Guide to CRA Reporting https://www.ffiec.gov/cra/pdf/2015_CRA_Guide.pdf
Posted By: ckme

Re: Reporting data for Bank Acquisitions - 01/04/18 05:09 PM

Sorry, that I can read it, but still need clarification

Scenario Two: ...For the year of the merger, data collection is required for Institution A’s transactions. Data collection is optional for the transactions of the previously exempt institution. For the following year, all transactions of the surviving institution must be collected and reported.

If a reporter and non reporter merge, then the option is to report all data after the merger or not to report any data from the branches acquired in the merger until the following year? This makes sense that you do not have to change your assessment area midstream, but in my mind all loans after the merger are Institutions A's transactions.

Can someone help me?
Posted By: ckme

Re: Reporting data for Bank Acquisitions - 02/14/18 03:29 PM

bump??
Posted By: RR Jen

Re: Reporting data for Bank Acquisitions - 02/14/18 05:02 PM

I'd suggest reaching out to your examiner for clarification.

During our most recent merger, neither of us were subject to the reporting requirements. Our examiner let us provide community development, service, investment, and donation information for all merged institutions during the exam scope...even though it went back farther than the merger dates. The "cut off" for including data was the prior CRA exam date for the merged institution.