EDITION EFFECTIVE for 2009 CRA Data Submissions (Due March 1, 2010) 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 14 Reporting the Data 16 Reporting Tools 16 Submitting the Data 18 Data Automation Cycle 19 Public Availability of Data 22 Glossary 23 Appendix A— Regulation BB: Community Reinvestment 26 Appendix B— Interagency Questions and Answers 47 Appendix C— State and County Codes and MSA/MD Numbers 57 Appendix D— Federal Supervisory Agencies 80 Appendix E— Call Report Instructions 83 Appendix F – Thrift Financial Report Instructions 95 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 (202) 872-7584 or [email protected] (CRA) data reporters. Data collec­ for assistance with data collection tion, maintenance, and reporting are and reporting. important aspects of financial insti­ Use of this guide is not a substitute tution evaluations under CRA. This for familiarity with the CRA regula­ guide can be used as a resource tions and the Interagency questions when collecting and maintaining and answers (Qs&As) that interpret data, creating a submission, and those regulations. The regulations posting lending data in the CRA and Qs&As may be revised from public file. time to time. Thus, institutions The FFIEC produces a public dis­ should consult them to determine closure statement for every report­ whether this edition of the guide ing institution. The disclosures and reflects the most recent revisions. other CRA data are available from Both are available in the appendices the FFIEC, by accessing the FFIEC of this guide and on the FFIEC’s Internet site, www.ffiec.gov/cra. CRA website at www.ffiec.gov/cra. Users of this guide should be aware The FFIEC welcomes suggestions of its limitations. It relates only to the for making changes or additions that collection, maintenance, and report­ might make this Guide more helpful. ing of small business loans, small Send your suggestions or com­ farm loans, and community develop­ ments to ment data as well as the collection, FFIEC maintenance, and reporting of other 3501 Fairfax Drive applicable loan data (except data on Room B3030 home mortgage loans) that may be Arlington, VA 22226. considered during CRA evaluations. Alternatively, you may send an Although this guide addresses many e-mail to issues relating to these matters, new issues arise often. For further infor­ [email protected]. A Guide to CRA Data Collection and Reporting 3 Executive Summary: Compliance Responsibilities Executive Purpose of CRA development test for wholesale/ limited-purpose institutions; and the Summary: The Community Reinvestment strategic-plan option for institutions Act of 1977 (CRA) is implemented with approved strategic plans. Compliance by regulations of the Office of the Responsibilities Comptroller of the Currency (OCC), The Consumer Compliance Task the Board of Governors of the Force of the FFIEC promotes Federal Reserve System (Board), consistency in the implementation of the Federal Deposit Insurance the CRA regulations by periodically Corporation (FDIC), and the Office of publishing interagency questions Thrift Supervision (OTS) (collectively, and answers on community the agencies) in 12 CFR parts reinvestment (Qs&As) and 25, 228, 345, and 563e. The CRA examination procedures, and by regulations require that information facilitating uniform data reporting. on business, farm, and community development lending by insured Who Must Report depository institutions that meet certain asset thresholds, determined All state member banks, state annually, be made available to the nonmember banks, national public. banks, and savings associations 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 tutions 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 CRA requires that each insured thresholds at www.ffiec.gov/cra depository institution’s record in Institutions that do not meet or helping to meet the credit needs of exceed the asset size threshold its entire community, including low- have the option of submitting and moderate-income neighbor­ data voluntarily. An institution that hoods, be assessed periodically. submits data voluntarily retains the That record is taken into account option of being examined as a large when considering an institution’s institution. applications for deposit facilities, including mergers and acquisitions. When to Report The CRA regulations contain different evaluation methods for Data for a given year must be sub­ different types of institutions: the mitted to the Board, the designated lending, investment and service processor for all of the agencies, by tests for large retail institutions; March 1 of the following year. the lending and community Merging Institutions development test for intermediate small institutions; the stream­ Following are three scenarios lined performance standards for describing data collection and small institutions; the community reporting responsibilities for the A Guide to CRA Data Collection and Reporting 4 Executive Summary: Compliance Responsibilities calendar year of a merger and for Institutions That Did Not collect home mortgage loan data by subsequent years. Originate or Purchase Small the Home Mortgage Disclosure Act Business or Small Farm (HMDA), it need not collect home Scenario One Loans mortgage loan data under the CRA exam. Examiners will sample an Two institutions are exempt from An institution that has not originated institution’s home mortgage loans to CRA collection and reporting or purchased any small business evaluate its home mortgage lending. requirements because neither met or small farm loans during the If an institution wants to ensure that the asset size threshold. The institu­ reporting period would not submit examiners consider all of its home tions merge. No data collection is the composite loan records for mortgage loans, it may collect and required for the year in which the small business or small farm loans. maintain data on these loans. merger takes place, regardless of However, all institutions subject the resulting asset size. Data collec­ to data reporting requirements Modification, extension and tion and reporting would begin after must submit the information dis­ consolidation agreements (MECAs) two consecutive years in which the cussed below under “Reporting are transactions in which an combined institution would have Requirements.” institution obtains loans from year-end assets that meet or exceed another institution without actually the small institution asset size purchasing or refinancing the loans. threshold amount described in Reporting In some states, MECAs, which are 12 CFR ___.12(u)(1). Requirements not considered loan refinancings because the existing loan At a minimum, an institution must Scenario Two obligations are not satisfied and submit, in electronic format: Institution A, an institution with replaced, are common. Although assets that meet or exceed the • a transmittal sheet, these transactions are not asset size threshold, and Institution • a definition of its assessment considered to be purchases or B, an institution with assets below area(s), refinancings, as those terms have the asset size threshold, merge. • a record of its community devel­ been interpreted under CRA, they Institution A is the surviving institu­ opment (CD) loans. (If an institu­ do achieve the same results. An tion. For the year of the merger, data tion does not have CD loans to institution may present information collection is required for Institution report, the record should be sent about its MECA activities to A’s transactions. Data collection is with “0” in the CD loan composite examiners for consideration under optional for the transactions of the data fields); and the lending test as “other loan data.” previously exempt institution. For • information on small business the following year, all transactions and small farm loans, if applicable. File Specifications of the surviving institution must be CRA data are aggregated on the collected and reported. census tract level. Each tract rep­ and Edit Validations resents one record in an entire data The FFIEC makes available free Scenario Three submission. For example: CRA Data Entry Software to any Two institutions that are each institution that wishes to use it. The • Six different small business loans required to collect and report data software includes several basic made in the same census tract merge. Data collection is required analytical reports regarding