We have been bought out by another bank. They will actually take over in November. Our bank is not a CRA reporting bank, as we are considered an intermediate sized bank. We did not submit data last year. Should we continue to collect CRA data? The new bank will begin collecting in November, but our current bank will never reach the level needed to report CRA. To collect or not to collect, that is the question?

Example:

Institution A, an institution required to collect and report data, and Institution B, an exempt institution, merge.

Institution A is the surviving institution. For the year of the merger, data collection is required for Institution A’s transactions. Data collection is optional for the transactions of the previously exempt institution . For the following year, all transactions of the surviving institution must be collected and reported

Don, what if Institution B is the surviving institution?

Does it really depend on what type of merger it is, or is the rule: if two merge and one is exempt and one isn't, they must report whatever the resulting entity does?

For the record, I just talked to our FDIC examiner and he said we could just stop collecting the CRA information. So, I'm happy to oblige him. If only they would have said that about HMDA.

Ron

IMO The type of merger does not matter. The Non reporting survivor will automatically become a reporting institution when they acquire the institution that is. Just reverse the A and B example stated above.

The exception to this is if both, institutions, are an ISB. If the merger still keeps them in an ISB category, and one has been reporting and the other has chosen not to. Then it would be the survivors call as to report or not.

Ah, so it is like the second part of my question. That seemed to be the most intuitive to me. THinTN's example is like your second paragraph in 574189.

Shucks, I was hoping I was going to get to flex my M&A muscles.