We are finalizing the purchase of another bank. We are not going to merge our operations until 60 or more days after the purchase. Since the other bank will be a subsidiary under our holding company for a few months, do I need to do anything to their CRA file until the merger (add our PE, etc.)? (This is our first purchase)

I would probably wait until the transaction is complete so you don't have a lot of extra work to do. However, I would start preparing the info for after the merger so it will be ready to go when it happens.

Thanks for your input. So I shouldn't have to do anything with their public file upon ownership, just upon merger?

Point of clarification:

Your holding company is acquiring the bank but keeping the charter separate until back office operations are able to be merged? Or are you just saying it will be a few months until the back office operations are merged?