Q: For banks that acquired failed institutions during 2010, does the purchasing bank report all the loans acquired through the acquisition, or does the purchasing bank ensure that only the 2010 loans and applications from the acquired institution are reported?
A: Institutions should treat acquisitions of failed institutions as they would a typical merger or acquisition. Q&A ___.42-5 (page 11667 of the Federal Register notice ) provides specific data collection responsibilities for the calendar year of a merger and subsequent data reporting responsibilities. Institutions should not report data for loan activity that occurred prior to the year of acquisition. In a situation where neither a merger nor an acquisition of a branch is involved, and the institution purchases CRA-related loans in bulk from another entity (for example, from a failing institution), the purchasing institution must report those loans as purchased loans.
Conversely, acquisitions of loan portfolios would be treated differently. In those circumstances, the acquired loans would be reported as purchased loans, as outlined in §228.42 of Regulation BB.
This can be found in - CRA FAQ#3 of the FAQs. The Federal Reserve Board FAQs can be found at: https://consumercomplianceoutlook.org/2011/second-quarter/hmda-and-cra-data-reporting/