In June 2015 my bank did an acquisition and was unsure as to when we have to completely update our Public File with the acquired bank's products and services. I know the reg says it has to be current as of 4/1, but did not see in the reg whether we can wait until 4/1 to complete the updated Public File or do sooner after the merger.

While the reg says it absolutely must be updated no later than 4/1 each year, common practice is to keep up to date with major changes as soon as possible.

I agree with updating as soon as possible but I'm not sure of what to update and when. Here is the scenario.

bank A is acquiring bank B - the sale close is 8/1 but the conversion isn't until 2/1. When does bank B update their public files? At close or at conversion? Should any bank B performance be included now in Bank A's public file? if so, at close or at conversion?

travelgirl1...my dates were fairly close to yours. I used the 4/1 date to allow some wiggle room and only do one update.

In my scenario I would have provided the new and improved public file to everyone on 2/1. I do have info from bank B in the new and improved public file for historical information (such as HMDA disclosure tables, branch closures, LTD ratio) but only have products and fees for bank A (the ongoing entity).

Does that make sense?