In mid June, 2004 Bank A acquired Bank B with a loan system conversion taking place at the end of September '04. Prior to acquisition, both banks were required to report CRA/HMDA information under the large bank guidelines. At year end 2004, both banks filed their SB/SF & HMDA LARS separately for the entire year. The Fed is now saying that Bank B should have only reported information for the year 2004 up to the acquisition and any data after should have been either not reported or reported on Bank A's LAR. Did I miss understand the regulation totally?

I wonder if it's how you titled the submissions? The rule says that the surviving bank may file either a consolidated submission or separate submissions for the year of the merger but must file a consolidated report for subsequent years.

The submissions needed to be under the name of the surviving bank, not the name of the bank that is gone now. The data collection and submission is required for the entire year, so it sounds to me like you needed two submissions under the same (surviving) bank name, not two under different bank names.