No, we do not believe you need to include the acquired bank’s name when furnishing information to your credit bureaus. In the context of mergers and acquisitions, Regulation V requires furnishers of consumer credit reporting information to establish policies that prevent re-aging, duplicative reporting, or other problems that may similarly affect the accuracy or integrity of the information furnished to a credit bureau. Furnishing the information regarding your newly acquired loans in your institution’s name (rather than in both names), would not impact the integrity of your information.

For resources related to our guidance, please see:

• 12 CFR 1022.42 (“Each furnisher must establish and implement reasonable written policies and procedures regarding the accuracy and integrity of the information relating to consumers that it furnishes to a consumer reporting agency. The policies and procedures must be appropriate to the nature, size, complexity, and scope of each furnisher's activities.”)

• 12 CFR 1022.41(c) (“Furnisher means an entity that furnishes information relating to consumers to one or more consumer reporting agencies for inclusion in a consumer report.”)

• Regulation V, Appendix E to Part 1022 — Interagency Guidelines Concerning the Accuracy and Integrity of Information Furnished to Consumer Reporting Agencies, III(g) (“In developing its policies and procedures, a furnisher should address the following, as appropriate: . . . Furnishing information about consumers to consumer reporting agencies following mergers, portfolio acquisitions or sales, or other acquisitions or transfers of accounts or other obligations in a manner that prevents re-aging of information, duplicative reporting, or other problems that may similarly affect the accuracy or integrity of the information furnished.”)