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CRA Guide to Data Reporting and Collection

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CRA Guide to Data Reporting and Collection A Guide to CRA Data Collection and Reporting Federal Financial Institutions Examination Council January 2001 This user’s guide was prepared by CRA/HMDA Systems Information Technology Board of Governors of the Federal Reserve System for the Federal Financial Institutions Examination Council A Guide to CRA Data Collection and Reporting 2 Contents Foreword 4 Executive Summary: Compliance Responsibilities 5 Purpose of CRA 5 Who Must Report 5 When to Report 5 Reporting Requirements 6 File Specifications and Edit Validations 6 Collecting the Data 8 Composite Loan Data 8 Other Loan Data 14 Consumer Loans 14 Reporting the Data 16 Reporting Tools 16 Internet Resources 19 Data Automation Cycle 19 Public Availability of Data 22 Glossary 23 Appendix A— Regulation BB: Community Reinvestment 26 Appendix B— Schedule RC-C, Part II. Loans to Small Businesses and Small Farms 46 General Instructions 46 Loans to Small Businesses 49 Agricultural Loans to Small Farms 52 Examples of Reporting in Schedule RC-C, Part II 54 Appendix C— Thrift Financial Report Instruction Manual and Form 60 Loans to Small Businesses and Small Farms 60 Appendix D— U.S. Bureau of the Census Regional Offices 64 A Guide to CRA Data Collection and Reporting 3 Foreword In response to numerous Users of this guide should be requests and inquiries, the aware of its limitations. It Federal Financial Institutions relates only to the collection, Examination Council (FFIEC) maintenance, and reporting of has developed this guide for small-business and small-farm Community Reinvestment Act loan data and to the collection, (CRA) data reporters. Data maintenance, and reporting collection, maintenance, and (as applicable) of other loan reporting are important data (except data on home aspects of large-institution mortgage loans) that may be evaluations under CRA. This considered during CRA guide can be used as a evaluations. Although this resource when collecting and guide addresses many issues maintaining data, creating a relating to these matters, new submission, and posting issues arise often; they should lending data in the CRA public be directed to the CRA file. It is designed to reduce Assistance Line at (202) 872- burden on the approximately 7584 or [email protected]. 2,000 financial institutions Use of this guide is not a subject to the reporting substitute for familiarity with requirements of the CRA the CRA regulations and the regulations. interagency questions and answers (Qs&As) that inter- pret those regulations. The regulations and Qs&As may be revised from time to time, and you should consult them to determine whether this edition of the guide reflects the most recent revisions. Both are available on the FFIEC’s Internet site at www.ffiec.gov/cra. A Guide to CRA Data Collection and Reporting 4 Executive Purpose of CRA option for institutions with approved strategic plans. Summary: The Community Reinvestment Act of Compliance 1977 (CRA) is implemented by The Consumer Compliance Task Responsibilities regulations of the Office of the Force of the FFIEC promotes Comptroller of the Currency (OCC), consistency in the implementation of the Board of Governors of the the CRA regulations by periodically Federal Reserve System (Board), publishing interagency Qs&As and the Federal Deposit Insurance examination procedures and by Corporation (FDIC), and the Office of facilitating uniform data reporting. Thrift Supervision (OTS) (collectively, the agencies) in 12 CFR parts 25, 228, 345, and 563e. Who Must Report The CRA regulations require that All state member banks, state information on business, farm, and nonmember banks, national banks, community development lending by and savings associations that are not large insured depository institutions small or special-purpose institutions be made available to the public. are subject to the data collection and reporting requirements of the CRA. CRA directs the agencies to For the purpose of collecting and encourage insured depository reporting small business and small- institutions to help meet the credit farm loan data, a small institution is a needs of the communities in which bank or thrift that, as of December 31 they are chartered. CRA does not of either of the prior two calendar prohibit any activity, nor is it intended years, had total assets of less than to encourage unsafe or unsound $250 million and was independent or practices or the allocation of credit. an affiliate of a holding company that, as of December 31 of either of CRA requires that each insured the prior two calendar years, had depository institution’s record in total banking and thrift assets of less helping to meet the credit needs of than $1 billion. Institutions that are its entire community, including low- not small are considered large and moderate-income neighbor- institutions (see the glossary, hoods, be assessed periodically. beginning on page 23, for That record is taken into account definitions). when considering an institution’s applications for deposit facilities, including mergers and acquisitions. When to Report The CRA regulations contain Data for a given year must be different evaluation methods for submitted to the Board, the different types of institutions: the designated processor for all of the lending, investment, and service agencies, by March 1 of the following tests for large retail institutions; the year. community development test for wholesale or limited-purpose Merging Institutions institutions; the streamlined performance standards for small Following are three scenarios institutions; and the strategic-plan describing data collection and A Guide to CRA Data Collection and Reporting 5 Executive Summary: Compliance Responsibilities reporting responsibilities for the Institutions Reporting calendar year of a merger and for with No Small-Business subsequent years. or Small-Farm Loans Requirements An institution that has not purchased At a minimum, institutions must Scenario One or originated any small-business or submit, in electronic format: small-farm loans during the reporting Two institutions are exempt from · a transmittal sheet, period would not submit the CRA collection and reporting · a definition of its assessment composite loan records for small- requirements because of asset size. area(s), business or small-farm loans. The institutions merge. No data · a record of its community However, all institutions subject to collection is required for the year in development (CD) loans. (If an data reporting requirements must which the merger takes place, institution does not have CD loans submit the information discussed regardless of the resulting asset to report, the record should be sent below under “Reporting size. Data collection would begin with “0” in the CD loan composite Requirements.” after two consecutive years in which data fields); and the combined institution had year- · Lenders Covered by Home information on small-business and end assets of at least $250 million or Mortgage Disclosure Act small-farm loans, if applicable was part of a holding company that CRA data are aggregated on the had year-end banking and thrift If an institution is not required to assets of at least $1 billion. collect home mortgage loan data by census tract level, and each tract the Home Mortgage Disclosure Act represents one record in an entire data submission. For example: Scenario Two (HMDA), it need not collect home mortgage loan data under the CRA. · Six different small-business loans Institution A, an institution required Examiners will sample an institu- made in the same census tract to collect and report data, and tion’s home mortgage loans to would count as one composite Institution B, an exempt institution, evaluate its home mortgage lending. record. merge. Institution A is the surviving If an institution wants to ensure that · Six different small-farm loans, institution. For the year of the examiners consider all of its home three in one census tract and three merger, data collection is required mortgage loans, it may collect and in another, would count as two for Institution A’s transactions. Data maintain data on these loans. composite records. collection is optional for the transactions of the previously Modification, extension and exempt institution. For the following consolidation agreements (MECAs) File Specifications are transactions in which an year, all transactions of the surviving and Edit Validations institution must be collected and institution obtains loans from another institution without actually reported. The FFIEC makes available free purchasing or refinancing the loans. CRA data preparation software to In some states, MECAs, which are Scenario Three any institution that wishes to use it. not considered loan refinancings The software includes some basic Two institutions, each of which is because the existing loan analytical reports regarding an required to collect and report the obligations are not satisfied and institution’s data. To obtain a copy of data, merge. Data collection is replaced, are common. Although the latest version of the software, required for the entire year of the these transactions are not contact the CRA Assistance Line at merger and for subsequent years, so considered to be purchases or (202) 872-7584. long as the surviving institution is not refinancings, as those terms have exempt. The surviving institution been interpreted under CRA, they If an institution finds that the may file either a consolidated do achieve the same results. An FFIEC’s software does not meet its submission or separate submissions institution may present information needs, it may create a data for the year of the merger but must about its MECA activities to submission using the File file a consolidated report for examiners for consideration under Specifications and Edit Validation subsequent years. the lending test as “other loan data.” Rules that have been set forth to A Guide to CRA Data Collection and Reporting 6 Executive Summary: Compliance Responsibilities assist with electronic data submissions. For information about Syntactical (S) — Records that contain errors that may prevent them specific electronic formatting proce- from being uploaded to the FFIEC database.
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