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Conversion When Acquiring Another Bank (HMDA)

Answered by: 
Randy Carey

Question: 
Our bank has a conversion scheduled for January 3rd as we are acquiring another bank and need assistance with the following questions: 1. Will the bank we are acquiring be responsible for filing their own HMDA for 2016? 2. Will this data be included in any exam for our bank since it was prior to the acquisition? 3. What impact will the existing HMDA 2016 data be for our bank?
Answer: 

Conversion and acquisition are two different things. If you mean the date of merger and not just the date they may be converting to your systems, see the following:

1. Yes. However, since they will no longer exist, I'm not sure how they will file unless you assume responsibility for filing under their name.

2. Yes

3. You assume complete responsibility for content and accuracy.

First published on 01/01/2017

Filed under: 
Compliance
Filed under compliance as: 
HMDA
Mergers/Acquisitions

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