Large bank is acquiring an ISB. When reading the data collection guide (2015 version) it indicates the large bank does not have to report the data of the ISB prior to date of acquisition.
The questions are
1. can the large bank report those loans as purchased loans?
2. if the large bank can report, can they limit reporting of those purchased loans to only the loans originated the year of acquisition closed?
3. or...can or must, the large bank report all the small business loans they acquired as "purchased loans"
4. if reporting all the loans as purchased, how would they report a loan the prior bank designated as CD, but under the guidelines that same loan would not be considered a CD loan (because it is under a million dollars and would be considered a SB loan for a large bank)

You would report either a consolidated report or separate reports. Either way, it does not involve purchased loans.


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

Why create headaches for yourself? I suggest you report only the activity subsequent to the acquisition. If you report data generated by the acquired bank before the acquisition are you confident in the integrity of their data? The ISB does not have reporting responsibilities so there's no need to report their activity prior to the acquisition.

I assume you are talking about small business loans since you referred to the 2015 Guide. Am I correct?

yes, you are correct. I was asking about small business loans.

thanks!