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Inactive Financial Institution Letters 


Office of the Comptroller of the Currency

Federal Deposit Insurance Corporation

Federal Reserve Board

Office of Thrift Supervision

QUESTIONS AND ANSWERS ON CRA DATA COLLECTING AND REPORTING

The following is an interagency document containing answers to frequently asked questions on the new CRA data collection and reporting requirements. The answers relate to institutions that a-re using the FFIEC data collection and reporting software and to those that have developed their own data collection and reporting systems consistent with the file specifications accompanying the software.

Small Business Loan Data Collection and Reporting

  1. Must institutions collect and report data on all commercial loans under $1 million at origination?No. Institutions that are not exempt from data collection and reporting are required to collect and report only those commercial loans that they capture in the Consolidated Reports of Condition and Income, Schedule RC-C, Part H, ("Call Report") and in the Thrift Financial Report, Schedule SB ("TFR"). Small business loans are defined as those whose original amounts are $1 million or less and that were reported as either Loans secured by nonfann or nonresidential real estate or Commercial and Industrial loans in Part I of the Call Report or TFR.

  2. For loans defined as small business loans, what information should be collected and maintained? Instructions that are not exempt from data collection and reporting are required to collect and maintain in a standardized, machine readable format information on each small business loan originated or purchased for each calendar year:
    1. a unique number or alpha-numeric symbol that can be used to identify the relevant loan file
    2. the loan amount at origination
    3. the loan location
    4. an indicator whether the loan was to a business with gross annual revenues of $1 million or less

    The location of the loan must be maintained by census tract or block numbering area. In addition, supplemental information contained in the file specifications, which were distributed on October 27, 1995, includes a date associated with the origination or purchase and whether a loan was originated or purchased by an affiliate. The same requirements apply to small farm loans.

  3. For information that is collected and maintained, what data should be reported?Each institution that is not exempt from data collection and reporting is required to report in machine-readable form annually on March 1 the following information, aggregated for each census tract or block numbering area in which the institution originated or purchased at least one small business or small farm loan during the prior year:
    1. the number and amount of loans originated or purchased with original amounts of $100,000 or less
    2. the number and amount of loans originated or purchased with original amounts of more than $100,000 but less than or equal to $250,000
    3. the number and amount of loans originated or purchased with original amounts of more than $250,000 but not more than $1 million
    4. to the extent that information is available, the number and amount of loans to businesses and farms with gross annual revenues of $1 million or less (using the revenues the institution considered in making its credit decision)

  4. When indicating whether a small business, borrower had gross annual revenues of $1 million or less, upon what revenues should an institution rely? Generally, an institution should rely an the revenues that it considered in making its credit decision. For example, in the case of affiliated businesses, such as a parent corporation or its subsidiary, if the institution considered the revenues of the entity's parent or a subsidiary corporation of the parent as well, then the institution would combine the revenues of both corporations to determine whether the revenues will be $1 million or less. Alternatively, if the institution considered the revenues of only the entity to which the loan is actually extended, the institution should rely solely upon whether gross annual revenues are above or below $1 million for that entity. However, if the institution considered and relied on revenues or income of a cosigner or guarantor that is not an affiliate of the borrower, the institution should not adjust the borrower's revenues for reporting purposes.

  5. If an institution that is not exempt from data collection and reporting does not request or Consider revenue information to make the credit decision regarding a small business or small farm loan, must the institution collect revenue information in connection with that loan? No, In those instances the institution should enter " 3 " on the individual loan portion of the data collection software, or on an internally developed system, indicating "revenues not known."

  6. Schedule RC-C, Pall 11 of the Call Report and schedule SB of the TFR do not allow financial institutions to report loans for Commercial and Industrial purposes that are secured by residential real estate. Loans extended to small businesses with gross annual revenues of $1 million or less may, however, he secured by residential real estate. Is there a Way to collect this information on the software to supplement an institution's small business lending data at the time of examination?Yes. Even though these loans are not reportable under HMDA, are not included as "small business" loans for Call Report or TFR purposes, and are not included in reported small business loan data for CRA purposes, at its ppikon, an institution may collect and maintain data concerning loans, purchases, and lines of credit extended to small businesses and secured by residential real estate for consideration in the CRA evaluation of its small business lending, To facilitate this optional data collection, the software provides that an institution may collect this information to supplement its small business lending data by choosing loan type 3, "Other lines of credit for purposes of small business," under record identifier 9 in the individual loan data, TMs information should be maintained at the institution and should not be submitted for central reporting purposes.

  7. Which location should an institution record if a small business loan's proceeds are used in a variety of locations? The institution should record the loan location by either the location of the business headquarters or the location where the plurality of the proceeds are applied as indicated by the borrower.

    General Report Questions

  8. When must an institution collect and report data under the CRA regulations?All institutions except small institutions are subject to data collection and reporting requirements. A small institution is a bank or thrift that, as of December 31 of either of the prior two calendar years, had total assets of less than $250 million and was independent or an affiliate of a holding company that, as of December 31 of either of the prior two calendar years, had total banking and thrift assets of less than $1 billion.

    For example:
    DateInstitution's asset sizeData collection required for
    following calendar year?
    12/31/94 $240 million No
    12/31/95 $260 million No
    12/31/96 $230 million No
    12/31/97 $280 million No
    12/31/98 $260 million Yes, beginning 1/01/99

    All institutions that are subject to the data collection and reporting requirements must report the data for a calendar year by March I of the subsequent year. In the example, above, the institution would report the data collected for calendar year 1999 by March 1, 2000.

    The Board of Governors of the Federal Reserve System is handling the processing of the reports for all of the primary regulators. The reports should be submitted in a prescribed electronic format on a timely basis. The mailing address for submitting these reports is:

    Attention: CRA Processing
    Board of Governors of the Federal Reserve System
    1709 New York Avenue, N.W.
    5th Floor
    Washington, DC 20006

    The first time data must be reported is March 1, 1997, for data collected in calendar year 1996.

  9. When should merging institutions collect data?

    Three scenarios of data collection responsibilities for the calendar year of a merger and subsequent data reporting responsibilities are described below.
    1. 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. Data collection would begin after two consecutive years in which the combined institution had year-end assets of at least $250 million or was part of a holding company that had year-end banking and thrift assets of at least $1 billion.
    2. Institution A, an institution required to collect and report the data, and Institution B, an exempt institution, merge. 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.
    3. 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.

  10. Is an institution that has no small farm or small business loans required to report under new CRA? Except for small institutions, each institution must, at a minimum, submit a transmittal sheet and a definition of its assessment area(s). 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.

  11. Are all institutions required to report the "military flag" in the individual loan record (record identifier 9) or assessment area designation (record identifier 4)?No. The file specifications originally sent out to institutions have been revised to delete the military flag indicator on the individual loan data.

    An institution that wishes to identify that it has chosen to designate its entire deposit customer base as its assessment area, pursuant to the conditions outlined in 41(f) of the CRA regulations, can do so by selecting "Y" in record identifier 4 in the assessment area definition portion of the software. If "Y" is not entered, the software automatically defaults to "N" to accommodate the large number of institutions for which this item is not applicable.

  12. Should an institution develop its own program for data collection, or Will the reguLators require a certain format? Regulators require a precise format for the new CRA data collection and reporting rules. File specifications that outlined this format were mailed to institutions on October 27, 1995.

  13. Can small institutions get a copy of the data collection software even though they are not required to collect or report data?Yes. Any institution that is interested in receiving a copy of the software and in being placed on the mailing list for information related to new CRA data collection and reporting can do so by written request to:
    Attn: CRA Processing
    Board of Governors of the Federal Reserve System
    1709 New York Ave, N.W.
    5th Floor
    Washington, DC 20006

    They may also call the CRA Assistance Line at (202) 872-7584 or e:mail to CRAHELPOFRB,GOV.

    General Lending Ouestions

  14. Should institutions collect and report data about small business and small farm loans that are refinanced or renewed?An institution collects and reports information about refinancings but does not collect and report information about renewals. A refinancing typically involves the satisfaction of an existing obligation that is replaced by a new obligation undertaken by the same borrower, When an institution refinances a loan, it is considered a new origination and loan data should be collected and reported if otherwise required. Consistent with HMDA, however, if under the original loan agreement, the institution is unconditionally obligated to refinance the loan, or is obligated to refma= the loan subject to conditions within the borrower's control, the institution would not report these events as originations.

    For purposes of the CRA data collection and reporting requirements, an extension of the maturity of an existing loan, without a new credit decision, is a renewal, and is not considered a loan origination, Therefore, institutions should not collect and report data on loan renewals.

  15. Must an institution collect data on loan commitments and letters of credit?No. Institutions are not required to collect data on loan commitments and letters of credit. Institutions may, however, provide for examiner consideration information on letters of credit and commitments.

  16. How should an institution report data on lines of credit?Institutions must collect and report data on lines of credit in the same way that they provide data on loan originations. Pursuant to the interagency supplementary information to the revised CRA regulation (60 F.R. 22164 (May 4, 1995)), lines of credit are considered originated at the time the line is approved or increased; and an increase is considered a new origination. Generally, the full amount of the credit line is the amount that is considered originated. In the case of an increase to an existing line, the amount of the income is the amount that is considered originated and that amount should be reported.

  17. Should renewals of lines of credit be reported?No. Similar to loan renewals, renewals of lines of credit, where no new credit decision is made, are not considered loan originations and should not be reported.

    Small Farin Loan Data- Cgilection and Reporting

  18. Will farm loans need to be segregated from business loans?Yes.

  19. Should institutions collect and report data on all agricultural loans under $500, 000 at origination?Institutions are to report those farm loans that they capture in the Call Report, Schedule RC-C, Part Il and Schedule SB of the TFR. Small farm, loam are defined as those whose original amounts are $500,000 or less And were reported as either Loans to finance agricultural production and other loans to farmers or Loans secured by farmland in Part I of the Call Report and TFR.

  20. Does a loan to the "fishing industry" come under the definition of a small farm loan? Yes, Instructions for Part I of the Call Report and Schedule SB of the TFR include loans "Made for the purpose of financing fisheries and forestries, including loans to commercial fishermen" as a component of the definition for Loans to finance agricultural production and other loans to fanners. Part 11 of Schedule RC-C of the Call Report and Schedule SB of the TFR, which serve as the basis of the definition for small business and small farm loans in the revised regulation, capture both Loans to finance agricultural production and other loans to farmers and Loans secured by farmland.

    Communift Development --Loan Data Reporting

  21. What information about community development loans must institutions report?institutions, except small institutions, must report the aggregate number and amount of community development loans originated and purchased during the, prior calendar year.

  22. If a loan meets the definition of a home mortgage, small business, or small farm loan AND qualifies as a community development loan, where should it be reported? Can FHA, VA and SBA loans be reported as community development loans? ? Loans that meet the definitions of home mortgage, small business, or small farm loans, with one exception, must be reported only meet those respective categories even if they also meet the definition of community development loans. The exception is that multifamily affordable housing loans that.may be reported under HMDA as home mortgage loans may also be reported as community development loan.

    Consumer Loan Data Collection

  23. What are the data collection and reporting requirements regarding consumer loans?There are no data reporting requirements for consumer loans. Institutions may, however, opt to collect and maintain data on consumer loans. If an institution chooses to collect information on consumer loans, it may collect data for one or more of the following categories of consumer loans: motor vehicle, credit card, home equity, other secured, and other unsecured. If an institution collects data for loans in a certain category, it must collect data for all loans originated or purchased within that category. The institution must maintain these data separately for each category for which it chooses to collect data. The data collected and maintained should include for each loan:
    1. a unique number or alpha-numeric symbol that can be used to identify the relevant loan file
    2. the loan amount at origination or purchase
    3. the loan location
    4. the gross annual income of the borrower that the institution consideTed in making its credit decision

  24. If an institution does not consider income when making an underwriting decision in connection with a consumer loan, must it collect income information? No.

Last Updated 11/9/2011 communications@fdic.gov