I am having trouble finding this specific information in the CRA Data Collection and Reporting Guide. Any input would be much appreciated!!!

We acquired and institution in 2010 and there for must report those small farm and small commercial loans as purchased loans. My question is for 2010 CRA reporting, we should only report those purchased loans that were originated in 2010 correct? I am being told we should report all purchased loans from prior years from the purchased intitution. The purchased loans go way back to 2003!

I thought only loans originated in 2010 should be reported regardless if they are purchased or not.

Did the institution you purchased have any CRA Reporting obligations? Look at pages 27 - 28 of the Interagency Q & As on CRA for a discussion of mergers. http://www.ffiec.gov/cra/pdf/2010-4903.pdf

They were considered a Large institution under CRA.

I will take a look at the link you provided. Thank you for your response.

I took a look and the information you provided and that was included in the CRA data guide as well. Thank you anyway

I thought I had my answer (see below) but when showed this to my boss,he thought I needed to find something more specific. So it looks like as of now we will be reporting all the loans that we purchased.

Two institutions that each are
required to collect and report the data
merge. Data collection is required for
the entire year of the merger and for
subsequent years so long as the
surviving institution is not exempt. The
surviving institution may file either a
consolidated submission or separate
submissions for the year of the merger
but must file a consolidated report for
subsequent years.

Subsequent is referring to future years, not past years!

Yep, I know that. I was thinking I had my answer with the information I had bolded. "Data collection is required for the entire year of the merger".

Also, you will not code these as purchased loans if you include them in your LAR vs them reporting on their own LAR for 2010. You purchased the bank, not a portfolio of loans.

Forgive me if I sound dumb, this is my second time reporting CRA. So you are saying that we wouldn't code these as purchased loans? I am so confused now!

Purchased loans are when you purchase a portfolio of loans from an affiliate or an unrelated lender.

You actually bought a bank and now have to report their originations as well as your own, in one LAR or two.

You report these as originations.

Thank you!!