Two institutions are exempt from CRA collection and reporting requirements because of asset size. The institutions merge. No data collection is required for the year in which the merger takes place, regardless of the resulting asset size. Institution A is the surviving institution. For the year of the merger, data collection is required for Institution A's transactions.
Data collection is optional for the transactions of the previously exempt institution.
For the following year, all transactions of the surviving institution must be collected and reported. Two institutions that each are required to collect and report the data merge. Data collection is required for the entire year of the merger and for subsequent years so long as the surviving institution is not exempt. The surviving institution may file either a consolidated submission or separate submissions for the year of the merger but must file a consolidated report for subsequent years. However, an institution that has not purchased or originated any small business or small farm loans during the reporting period would not submit the individual loan reports.