We have bank A, who only met the asset size threshold last year but decided to report anyways.
We have bank B, who did not meet the asset size threshold for 2 years and did not report.

They both merged under a new name starting this year but bank B will still do business as their previous/current name.

What would be the reporting requirements?

See page 8 of 9 in the 2010 CRAHMDA Reporter

http://www.ffiec.gov/hmda/pdf/10news.pdf

thank you for the reference. Would a name change be considered as a "New Institution?"

I would outline the transaction just like you did in this thread and e-mail the information (see information to include below) to CRAHELP@frb.gov. They should be able to give you some guidance.


All respondents that have an institution involved in a merger or acquisition of a branch should send an e-mail to HMDAHELP@frb.gov detailing the merger, the HMDA Respondent IDs, regulatory agencies for the survivor and non-surviving institution(s), and how the filing will be handled (i.e., consolidated submissions or separate reports) for the year of the merger and subsequent years.

Also, ignore the fact that the other bank will continue to trade under their old name. If the charters have been merged, it is legally one bank and the other bank is just operating as a division. One charter equals one bank.