Our bank just acquired a mortage bank subsidiary. Can we consolidate the reporting of CRA/HMDA data such that all activity is reported under our bank's name?

I want to bring this scenario question back up. I know that for HMDA, the mortgage company can submit it's own LAR directly or can file its separate LAR through the bank as the parent company, but I'm still not sure about CRA. Would the mortgage company as a wholly owned subsidiary of the bank be considered an "affiliate" under CRA and therefore we have the option to include their loans in our CRA reporting?

As a Mortgage company they are not subject to CRA examination. As a Sub of the bank they can submit there own LAR and the Bank could claim the loans as an affiliate. If you do it this way the affiliate loans would only be used for the income and tract distribution portion of the lending exam. You will just need to let your exmainer know that you will be using affiliate lending. This should be done before they come in to do data integrity. If you are contiplating this you should discuss this with your regulator so they can tell you how they want to handle to proceed.

Thank you!