
My institution acquired a small bank mid-year 2004. The acquired institution did not report CRA-LAR due to their small size. Based on the CRA guide, we only report, at our option, loans post-merger for the entire combined banks. My question is this: Can I mix and match when it comes to Community Development or consortium loans? The acquired bank had several consortium loans on nursing facilities (not HMDA reportable) and there's probably a high percentage of medicare/medicaid patients, so the loans might quality under the consortium section of the CRA LAR. Any thoughts? I am currently liening toward being consistent and not reporting those loans, letting them serve as additional walk-on info during our next CRA exam.