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Asset Size - HMDA Reporting

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Our bank operates branches in multiple counties throughout the state. This fall, two of our coastal branches will be chartered into their own bank. We will no longer report their HMDA loans after their conversion date. Is there any reason we would not report the loans from January 1st until their conversion date on the lead bank's LAR? Will the new bank have to report their HMDA loans from conversion to December 31st if their asset size is over the threshold? My thought process tells me no since they would not have had any assets of their "own" for the prior two years. They will be located in an MSA and will have initial assets over the threshold.

Refer to the Commentary to section 203.2(e) #3 which discusses mergers and reporting following this action.

First published on 11/12/07

First published on 11/12/2007

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