Q: We are a HMDA-reportable bank. In September, we merged with a bank that does not report HMDA. Do we need to report loans originated by the other bank prior to September?
A: If the surviving institution is a HMDA reporter, the institution has the option of reporting the transactions handled in the offices of the previously exempt institution during the year of the merger, as discussed in comment 203.2(e)-3. For example, if Bank A (a HMDA reporter) merges with Bank B (a non-HMDA reporter) in 2010 with Bank A as the surviving institution, Bank A would report all of its 2010 HMDA activity and have the option of reporting 2010 HMDA transactions handled by Bank B.
This can be found in - HMDA FAQ#9 of the FAQs. The Federal Reserve Board FAQs can be found at: https://consumercomplianceoutlook.org/2011/second-quarter/hmda-and-cra-data-reporting/