EDITION EFFECTIVE for 2015 CRA Data Submissions (Due March 1, 2016) A Guide to CRA Data Collection and Reporting Federal Financial Institutions Examination Council Contents Foreword 3 Executive Summary: Compliance Responsibilities 4 Purpose of CRA 4 Who Must Report 4 When to Report 4 Reporting Requirements 5 File Specifications and Edit Validations 5 Collecting the Data 7 Composite Loan Data 7 Other Loan Data 14 Consumer Loans 15 Reporting the Data 16 Reporting Tools 16 Submitting the Data 17 Data Automation Cycle 18 Public Availability of Data 19 Glossary 22 Appendix A— Regulation BB: Community Reinvestment 26 Appendix B— Interagency Questions and Answers 48 Appendix C — State and County Codes and MSA/MD Numbers 58 Appendix D— Federal Supervisory Agencies 78 Appendix E— Call Report Instructions 81 A Guide to CRA Data Collection and Reporting 2 Foreword In response to numerous requests mation about compliance, contact and inquiries, the Federal Financial your federal supervisory agency (see Institutions Examination Council Appendix D). Institutions may also (FFIEC) has prepared this guide contact the CRA Assistance Line at for Community Reinvestment Act [email protected] for assistance with (CRA) data reporters. Data collec­ data collection and reporting. tion, maintenance, and reporting are Use of this guide is not a substitute important aspects of financial insti­ for familiarity with the CRA regula­ tution evaluations under CRA. This tions and the Interagency questions guide can be used as a resource and answers (Qs&As) that interpret when collecting and maintaining those regulations. The regulations data, creating a submission, and and Qs&As may be revised from posting lending data in the CRA time to time. Thus, institutions public file. should consult them to determine The FFIEC produces a public dis­ whether this edition of the guide closure statement for every report­ reflects the most recent revisions. ing institution. The disclosures and Both are available in the appendices other CRA data are available from of this guide and on the FFIEC’s the FFIEC, by accessing the FFIEC CRA website at www.ffiec.gov/cra . Internet site, www.ffiec.gov/cra . The FFIEC welcomes suggestions Users of this guide should be aware for making changes or additions of its limitations. It relates only to the that might make this guide more collection, maintenance, and report­ helpful. Send your suggestions or ing of small business loans, small comments to farm loans, and community develop­ FFIEC ment data as well as the collection, 3501 Fairfax Drive maintenance, and reporting of other Room B3030 applicable loan data (except data on Arlington, VA 22226. home mortgage loans) that may be Alternatively, you may provide feed­ considered during CRA evaluations. back through Although this guide addresses many issues relating to these matters, new http://www.ffiec.gov/crafeedback/ issues arise often. For further infor­ default.aspx . A Guide to CRA Data Collection and Reporting 3 Executive Summary: Compliance Responsibilities Executive Purpose of CRA for institutions with approved strate­ gic plans. Summary: The Community Reinvestment Act of 1977 (CRA) is implemented The Consumer Compliance Task Compliance by regulations of the Office of the Force of the FFIEC promotes con­ Responsibilities Comptroller of the Currency (OCC), sistency in the implementation of the Board of Governors of the the CRA regulations by periodically Federal Reserve System (Board), publishing Interagency Qs&As on and the Federal Deposit Insurance community reinvestment and exami­ Corporation (FDIC) (collectively, the nation proce dures, and by facilitating agencies) in 12 CFR parts 25, 228, uniform data reporting. 345, and 195. The CRA regulations require that information on business, farm, and community development Who Must Report lending by insured depository All state member banks, state institutions that meet certain asset nonmember banks, national thresholds, determined annually, be banks, and savings associations made available to the public. that meet or exceed the asset CRA directs the agencies to size thresholds for both of the last encourage insured depository insti­ two calendar years are subject to tu tions to help meet the credit needs the data collection and reporting of the communities in which they are requirements of the CRA. The asset chartered. CRA does not prohibit size thresholds are adjusted and any activity, nor is it intended to announced by the federal banking encourage unsafe or unsound agencies annually by December lending practices or the allocation 31. The agencies also publish the of credit. current and historical asset size thresholds at www.ffiec.gov/cra . CRA requires that each insured Institutions that do not meet or depository institution’s record in exceed the asset size threshold helping to meet the credit needs of have the option of submitting data its entire community, including low­ voluntarily. An institution that sub­ and moderate­income neighbor­ mits data voluntarily retains the hoods, be assessed periodically. option of being examined as a large That record is taken into account institution. when considering an institu tion’s applications for deposit facilities, including mergers and acquisitions. When to Report The CRA regulations contain differ­ Data for a given year must be sub ­ ent evaluation methods for different mitted to the Board, the designated types of institutions: the lending, processor for all of the agencies, by investment and service tests for March 1 of the following year. large retail institutions; the lend­ ing and community development Merging Institutions test for intermediate small institu­ tions; the stream­lined performance Following are three scenarios standards for small institutions; the describing data collection and community development test for reporting responsibilities for the wholesale/limited­purpose institu­ calendar year of a merger and for tions; and the strategic­plan option subsequent years. A Guide to CRA Data Collection and Reporting 4 Scenario One Institutions That Did Not collect home mortgage loan data by Originate or Purchase Small the Home Mortgage Disclosure Act Two institutions are exempt from Business or Small Farm (HMDA), it need not collect home CRA collection and reporting Loans mortgage loan data under the CRA requirements because neither met exam. Examiners will sample an the asset size threshold. The An institution that has not originated institu tion’s home mortgage loans to institutions merge. No data or purchased any small business evaluate its home mortgage lending. collection is required for the year or small farm loans during the If an institution wants to ensure that in which the merger takes place, reporting period would not submit examiners consider all of its home regardless of the resulting asset the composite loan records for mortgage loans, it may collect and size. Data collection and reporting small business or small farm loans. maintain data on these loans. would begin after two consecutive However, all institutions subject years in which the combined insti­ to data reporting requirements Modification, extension and tution would have year­end assets must submit the information dis­ consolidation agreements (MECAs) that meet or exceed the small insti­ cussed below under “Reporting are transactions in which an tution asset size threshold amount Requirements.” institution obtains loans from described in 12 CFR ___.12(u)(1). another institution without actually purchasing or refinancing the loans. Reporting In some states, MECAs, which are Scenario Two Requirements not considered loan refinancings Institution A, an institution with because the existing loan At a minimum, an institution must assets that meet or exceed the obligations are not satisfied and submit, in electronic format: asset size threshold, and Institution replaced, are common. Although B, an institution with assets below • a transmittal sheet, these trans actions are not the asset size threshold, merge. • a definition of its assessment considered to be purchases or Institution A is the surviving institu­ area(s), refinancings, as those terms have tion. For the year of the merger, • a record of its community devel­ been interpreted under CRA, they data collection is required for opment (CD) loans. (If an institu­ do achieve the same results. An Institution A’s transactions. Data tion does not have CD loans to institution may present information collection is optional for the report, the record should be sent about its MECA activities to transactions of the previously with “0” in the CD loan composite examiners for consideration under exempt institution. For the following data fields), and the lending test as “other loan data.” year, all transactions of the surviving • information on small business institution must be collected and and small farm loans, if applicable. File Specifications reported. CRA data are aggregated on the and Edit Validations census tract level. Each tract rep­ The FFIEC makes available free Scenario Three resents one record in an entire data CRA Data Entry Software to any Two institutions that are each submission. For example: institution that wishes to use it. The required to collect and report data software includes several basic • Six different small business loans merge. Data collection is required analytical reports regarding an made in the same census tract for the entire year of the merger institution’s data. The latest version constitute one composite record. and for