33 THE NAFCU JOURNAL March–April 2023 for mergers and acquisitions, which the CFPB highlights in the preamble to the final rule. For example, when two credit unions below the asset threshold merge, the surviving or newly formed credit union meets the definition of a covered institution, but the preamble explains that no data is required for the calendar year of the merger. The CFPB highlights several other merger circumstances where data collection may be required for surviving or newly formed credit unions. This is where it can get tricky. When a covered credit union merges with a credit union that is not covered and the covered credit union is the surviving institution or a new credit union, which is covered, is formed, then the surviving credit union is required to provide data for the previously covered credit union and has the option to provide data for the credit union that was not covered. On the other hand, when the surviving credit union is the previously, not covered credit union in the equation, then HMDA data collection is still required for covered loans that occurred before the merger date at the previously covered credit union. After the date of the merger, the surviving credit union has the option to provide HMDA data on covered transaction that took place at the originally covered credit union after the merger. Finally, data collection is required for the entire year when two covered credit unions merge. The changes to the threshold exemptions will likely impact HMDA data collection and subsequent reporting to the CFPB. As you adjust to these changes, please don’t hesitate to reach out with any questions. Visit www.nafcu.org/ contactcompliance to get in touch with any member of the NAFCU Regulatory Compliance Team. AI Oasis Website: ai-oasis.com...................................31 FIS Website: fisglobal.com............................... C2 Franklin Madison Website: franklin-madison.com.................. 7 Index to Advertisers Gallagher Website: nafcu.org/gallagher.................. C4 LendKey Website: lendkey.com..................................29 Strategic Resource Management Website: srmcorp.com................................... 4 CUNA Mutual Group Website: cunamutual.com/life................. C3
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