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Acquired 2 Branches: "Inherited" CIP Violations

09/30/2018

We have recently acquired two branches of another bank, along with the customers base from those two locations. We are wondering about the CIP violations that we seemed to have "inherited" from these two locations. Are these now our issues or does it fall under the bank of account opening? We are the second bank to own these two particular locations. Any information or guidance is appreciated.

Education and Training

11/19/2017

Why a Bank VP got her Master of Accounting degree (and why you should, too)

Conversion When Acquiring Another Bank (HMDA)

01/01/2017

Our bank has a conversion scheduled for January 3rd as we are acquiring another bank and need assistance with the following questions: 1. Will the bank we are acquiring be responsible for filing their own HMDA for 2016? 2. Will this data be included in any exam for our bank since it was prior to the acquisition? 3. What impact will the existing HMDA 2016 data be for our bank?

Shifting Reg Oversight From FRB to FDIC

03/24/2014

Our BHC previously held an FDIC, state-chartered bank and a trust company as separate entities. The trust company is now in the process of becoming a wholly-owned subsidiary of the bank. The long-time personnel of the trust company will continue to operate the trust company as it always has. Since the regulatory oversight for the trust company will now shift from the FRB to the FDIC, is it acceptable for the trust company to maintain its existing policies and procedures separate from those of the bank?

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HMDA Reportable Transaction Exclusions

12/22/2024

I actually referenced these as well which is what I used to support my interpretation; however, the other interpretation I heard the reason they said they got to that was following the citations along with the HMDA reportable transaction exclusions. So 12 CFR § 1002.104(b)(2) then if you go to the citation referenced there 12 CFR 1003.2(e) then go to the 1003.3 (C) referenced there. So looking at those exclusions it doesn’t mention anything in regards to if your bank is in an MSA or not but #11 references FI that have fewer than 25 loans. Hence, that being their reasoning that the only way non HMDA banks would exclude HMDA transactions was if they were non-HMDA due to loan volume. I’m not disagreeing with your answer because that was our interpretation as well but when following the citations that they used to come up with their interpretation and can see why they would maybe think that.”

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