CRA Guide To Data Reporting And Collection
A Guide toCRA Data Collectionand ReportingFederal Financial InstitutionsExamination CouncilJanuary 2001
This user’s guide was prepared byCRA/HMDA SystemsInformation TechnologyBoard of Governors of the Federal Reserve Systemfor theA Guide to CRA Data Collection and ReportingFederal Financial InstitutionsExamination Council2
ContentsForeword 4Executive Summary: Compliance Responsibilities 5Purpose of CRA5Who Must Report 5When to Report5Reporting Requirements 6File Specifications and Edit Validations6Collecting the Data 8Composite Loan DataOther Loan Data14Consumer Loans148Reporting the Data 16Reporting Tools 16Internet Resources19Data Automation Cycle 19Public Availability of Data22Glossary 23Appendix A—Regulation BB: Community Reinvestment 26Appendix B—Schedule RC-C, Part II.Loans to Small Businesses and Small Farms 46General Instructions46Loans to Small Businesses 49Agricultural Loans to Small Farms52Examples of Reporting in Schedule RC-C, Part II54Appendix C—Thrift Financial Report Instruction Manual and Form 60Loans to Small Businesses and Small Farms60Appendix D—U.S. Bureau of the Census Regional Offices 64A Guide to CRA Data Collection and Reporting3
ForewordIn response to numerousrequests and inquiries, theFederal Financial InstitutionsExamination Council (FFIEC)has developed this guide forCommunity Reinvestment Act(CRA) data reporters. Datacollection, maintenance, andreporting are importantaspects of large-institutionevaluations under CRA. Thisguide can be used as aresource when collecting andmaintaining data, creating asubmission, and postinglending data in the CRA publicfile. It is designed to reduceburden on the approximately2,000 financial institutionssubject to the reportingrequirements of the CRAregulations.A Guide to CRA Data Collection and ReportingUsers of this guide should beaware of its limitations. Itrelates only to the collection,maintenance, and reporting ofsmall-business and small-farmloan data and to the collection,maintenance, and reporting(as applicable) of other loandata (except data on homemortgage loans) that may beconsidered during CRAevaluations. Although thisguide addresses many issuesrelating to these matters, newissues arise often; they shouldbe directed to the CRAAssistance Line at (202) 8727584 or crahelp@frb.gov.Use of this guide is not asubstitute for familiarity withthe CRA regulations and theinteragency questions andanswers (Qs&As) that interpret those regulations. Theregulations and Qs&As maybe revised from time to time,and you should consult themto determine whether thisedition of the guide reflectsthe most recent revisions.Both are available on theFFIEC’s Internet site atwww.ffiec.gov/cra.4
ExecutiveSummary:ComplianceResponsibilitiesPurpose of CRAThe Community Reinvestment Act of1977 (CRA) is implemented byregulations of the Office of theComptroller of the Currency (OCC),the Board of Governors of theFederal Reserve System (Board),the Federal Deposit InsuranceCorporation (FDIC), and the Office ofThrift Supervision (OTS)(collectively, the agencies) in 12CFR parts 25, 228, 345, and 563e.The CRA regulations require thatinformation on business, farm, andcommunity development lending bylarge insured depository institutionsbe made available to the public.CRA directs the agencies toencourage insured depositoryinstitutions to help meet the creditneeds of the communities in whichthey are chartered. CRA does notprohibit any activity, nor is it intendedto encourage unsafe or unsoundpractices or the allocation of credit.CRA requires that each insureddepository institution’s record inhelping to meet the credit needs ofits entire community, including lowand moderate-income neighborhoods, be assessed periodically.That record is taken into accountwhen considering an institution’sapplications for deposit facilities,including mergers and acquisitions.The CRA regulations containdifferent evaluation methods fordifferent types of institutions: thelending, investment, and servicetests for large retail institutions; thecommunity development test forwholesale or limited-purposeinstitutions; the streamlinedperformance standards for smallinstitutions; and the strategic-planA Guide to CRA Data Collection and Reportingoption for institutions with approvedstrategic plans.The Consumer Compliance TaskForce of the FFIEC promotesconsistency in the implementation ofthe CRA regulations by periodicallypublishing interagency Qs&As andexamination procedures and byfacilitating uniform data reporting.Who Must ReportAll state member banks, statenonmember banks, national banks,and savings associations that are notsmall or special-purpose institutionsare subject to the data collection andreporting requirements of the CRA.For the purpose of collecting andreporting small business and smallfarm loan data, a small institution is abank or thrift that, as of December 31of either of the prior two calendaryears, had total assets of less than 250 million and was independent oran affiliate of a holding companythat, as of December 31 of either ofthe prior two calendar years, hadtotal banking and thrift assets of lessthan 1 billion. Institutions that arenot small are considered largeinstitutions (see the glossary,beginning on page 23, fordefinitions).When to ReportData for a given year must besubmitted to the Board, thedesignated processor for all of theagencies, by March 1 of the followingyear.Merging InstitutionsFollowing are three scenariosdescribing data collection and5
Executive Summary: Compliance Responsibilitiesreporting responsibilities for thecalendar year of a merger and forsubsequent years.Scenario OneTwo institutions are exempt fromCRA collection and reportingrequirements because of asset size.The institutions merge. No datacollection is required for the year inwhich the merger takes place,regardless of the resulting assetsize. Data collection would beginafter two consecutive years in whichthe combined institution had yearend assets of at least 250 million orwas part of a holding company thathad year-end banking and thriftassets of at least 1 billion.Scenario TwoInstitution A, an institution requiredto collect and report data, andInstitution B, an exempt institution,merge. Institution A is the survivinginstitution. For the year of themerger, data collection is requiredfor Institution A’s transactions. Datacollection is optional for thetransactions of the previouslyexempt institution. For the followingyear, all transactions of the survivinginstitution must be collected andreported.Scenario ThreeTwo institutions, each of which isrequired to collect and report thedata, merge. Data collection isrequired for the entire year of themerger and for subsequent years, solong as the surviving institution is notexempt. The surviving institutionmay file either a consolidatedsubmission or separate submissionsfor the year of the merger but mustfile a consolidated report forsubsequent years.A Guide to CRA Data Collection and ReportingInstitutionswith No Small-Businessor Small-Farm LoansReportingRequirementsAn institution that has not purchasedor originated any small-business orsmall-farm loans during the reportingperiod would not submit thecomposite loan records for smallbusiness or small-farm loans.However, all institutions subject todata reporting requirements mustsubmit the information discussedbelow under “ReportingRequirements.”At a minimum, institutions mustsubmit, in electronic format:Lenders Covered by HomeMortgage Disclosure ActIf an institution is not required tocollect home mortgage loan data bythe Home Mortgage Disclosure Act(HMDA), it need not collect homemortgage loan data under the CRA.Examiners will sample an institution’s home mortgage loans toevaluate its home mortgage lending.If an institution wants to ensure thatexaminers consider all of its homemortgage loans, it may collect andmaintain data on these loans.Modification, extension andconsolidation agreements (MECAs)are transactions in which aninstitution obtains loans fromanother institution without actuallypurchasing or refinancing the loans.In some states, MECAs, which arenot considered loan refinancingsbecause the existing loanobligations are not satisfied andreplaced, are common. Althoughthese transactions are notconsidered to be purchases orrefinancings, as those terms havebeen interpreted under CRA, theydo achieve the same results. Aninstitution may present informationabout its MECA activities toexaminers for consideration underthe lending test as “other loan data.”· a transmittal sheet,· a definition of its assessmentarea(s),· a record of its communitydevelopment (CD) loans. (If aninstitution does not have CD loansto report, the record should be sentwith “0” in the CD loan compositedata fields); and· information on small-business andsmall-farm loans, if applicableCRA data are aggregated on thecensus tract level, and each tractrepresents one record in an entiredata submission. For example:· Six different small-business loansmade in the same census tractwould count as one compositerecord.· Six different small-farm loans,three in one census tract and threein another, would count as twocomposite records.File Specificationsand Edit ValidationsThe FFIEC makes available freeCRA data preparation software toany institution that wishes to use it.The software includes some basicanalytical reports regarding aninstitution’s data. To obtain a copy ofthe latest version of the software,contact the CRA Assistance Line at(202) 872-7584.If an institution finds that theFFIEC’s software does not meet itsneeds, it may create a datasubmission using the FileSpecifications and Edit ValidationRules that have been set forth to6
Executive Summary: Compliance Responsibilitiesassist with electronic datasubmissions. For information aboutspecific electronic formatting procedures, contact the CRA AssistanceLine at (202) 872-7584 or click on“How to File” at www.ffiec.gov/cra.File SpecificationsInstitutions that develop their ownprograms must follow the preciseformat laid out in the CRA FileSpecifications. This file formatshould be incorporated into anautomated system to ensure anerror-free data submission.Edit Validation RulesSyntactical (S) — Records that contain errors that may prevent themfrom being uploaded to the FFIEC database. These errors range fromincorrect activity years to duplicate property locations, which indicate thatthe property combination for that record identifier was used more thanonce. These records will not be reflected in your disclosure statementuntil the appropriate corrections have been made.Validity (V) — Records containing incorrect information. The mostcommon validity errors are incorrect census tract/BNA numbers. Theserecords will not be reflected in your disclosure statement until theappropriate corrections have been made.Quality (Q) — Loan information that, while it may pass all syntactical andvalidity edits, is nevertheless statistically unusual and is subject to furtherinvestigation or review to confirm correctness. For a majority of the qualityedits, if the data are correct, no changes are necessary and the data willbe reflected.When an institution chooses tocreate an electronic datasubmission, it must edit its datausing the CRA Edit Validation Rules.These rules are designed to ensuredata integrity and to prevent errors.CRA edit validations are divided intothree edit types: syntactical, validity,and quality. Each type correspondsto errors of a different degree ofseverity, and each must bethoroughly understood to ensure thatthe data are accurate and complete.A Guide to CRA Data Collection and Reporting7
Collecting theDataComposite LoanDataTransmittal SheetThe transmittal sheet is used toidentify each institution. Institutionsare asked to provide a reporter’sidentification (RID) number. Thisnumber corresponds to thecertificate number for FDICsupervised institutions, the docketnumber for institutions supervisedby the OTS, and the charter numberfor OCC-supervised institutions. If aninstitution is supervised by theBoard, the Research, Statistics,Supervision and Regulation, andDiscount and Credit (RSSD)Number is used. Board-supervisedinstitutions that do not know theirRSSD numbers should contactthe CRA Assistance Line at (202)872-7584 or crahelp@frb.gov toobtain it.The transmittal sheet providesvaluable institution and contactinformation. It is important that theinstitution’s name, contact name,address, phone number, and faxnumber be correct since all futurecorrespondence will be based onthat information. Because areacodes are subject to change, it isimportant to review phone and faxnumbers for accuracy before datasubmission.Assessment Area(s)DelineationFor institutions other than thosedesignated as wholesale or limitedpurpose (see the glossary),assessment areas must consistgenerally of one or more metropolitan statistical areas (MSAs) orone or more contiguous politicalsubdivisions such as counties,cities, or towns. An institution mustA Guide to CRA Data Collection and Reportinginclude the geographies in which itsmain office, branches, and deposittaking ATMs are located as well asthe surrounding geographies inwhich it has originated or purchaseda substantial portion of its loans.Please refer to section .41 of theregulations and the interagencyQs&As for further guidance,particularly Q&A .41(e)(4)–1,which explains limitations on thesize of assessment areas.Note: When you are enteringinformation about small-businessand small-farm loans, you need toprovide MSA, state, county, andtract/BNA information to indicate thelocation of the loan. The informationthat you provide in the loan dataentry screens is not your assessment area(s). This is simply theloan’s location.Assessment Area(s) ReportingIf your assessment area(s) includesan entire MSA, you should report:Include/Exclude MSAStateCountyCensusTract/BNA NANANA0520If your assessment area(s) includesan MSA less one county, you shouldreport:Include/Exclude MSAStateCountyCensusTract/BNA 0520NANANA-0520NA151NAIf your assessment area(s) includesor consists of an entire county, youshould report:Include/Exclude MSAStateCountyCensusTract/BNA 13089NA05208
Collecting the DataFor more assessment area(s)delineation examples, please referto the CRA Edits, which can befound at www.ffiec.gov/cra/edits.htm.regarding the community development purpose and location of thecommunity development loans thatthey report at the time of theirexamination.Community DevelopmentLoansNote: If an institution is not awholesale or limited-purposeinstitution, it cannot designate a loanas a community development loan ifthe loan has already been reportedor collected by the institution or anaffiliate as a small-business, smallfarm, consumer, or home mortgageloan (except in the case of amultifamily dwelling loan, which maybe considered a communitydevelopment loan as well as a homemortgage loan). Further, except formultifamily affordable housing loans,if a loan meets the definition of asmall-business, small-farm,consumer, or home mortgage loan,retail institutions must collect andreport the loan in this manner. Retailinstitutions may not choose tocollect and report it as a communitydevelopment loan.Institutions subject to data reportingrequirements must report theaggregate number and amount ofcommunity development loansoriginated or purchased during theprior calendar year.A community development loan hascommunity development as itsprimary purpose. As defined in theregulations, “community development” means—· affordable housing (includingmultifamily rental housing) for lowor moderate-income individuals;· community services targeted tolow- or moderate-incomeindividuals;· activities that promote economicdevelopment by financingbusinesses or farms that meet thesize eligibility standards of theSmall Business Administration’sDevelopment Company or SmallBusiness Investment Companyprograms (13 CFR 121.301) orhave gross annual revenues of 1million or less; or· activities that revitalize or stabilizelow- or moderate-incomegeographies.In addition to having a communitydevelopment purpose, a communitydevelopment loan must also benefitthe institution’s assessment area(s)or a broader statewide or regionalarea that includes the institution’sassessment area(s). Institutionsshould be prepared to provideexaminers with informationA Guide to CRA Data Collection and ReportingPrimary PurposeAs long as the primary purpose ofthe loan is community development,the full amount of the institution’sloan should be included in its reportof aggregate community development lending. A loan has a primarypurpose of community developmentwhen it is designed for the expresspurpose of community development.Refer to the interagency Qs&As forfurther discussion of primarypurpose, particularly Q&A .12(i)and 563e.12(h)–7.Affiliate LoansAffiliate means any company thatcontrols, is controlled by, or is undercommon control with anothercompany. The term “control” has themeaning given to that term in 12U.S.C. 1841(a)(2), and a company isunder common control with anothercompany if both companies aredirectly or indirectly controlled by thesame company.An institution is not required tocollect information on affiliate loans.However, an institution that elects tohave its regulator consider loans byan affiliate, for purposes of thelending or community developmenttest or an approved strategic plan,must collect, maintain, and report forthose loans the data that theinstitution would have collected,maintained, and reported had theloans been originated or purchasedby the institution.An institution may elect to have onlya particular category of an affiliate’slending considered. The basiccategories of loans are homemortgage loans, small-businessloans, small-farm loans, communitydevelopment loans, and the fivecategories of consumer loans (motorvehicle loans, credit card loans,home equity loans, other securedloans, and other unsecured loans).Affiliate’s Home MortgageLendingIf an institution elects to have anaffiliate’s home mortgage lendingconsidered in its CRA evaluation andthe affiliate is a HMDA reporter, theinstitution must be prepared toidentify those loans reported by itsaffiliate under 12 CFR part 203(Regulation C, implementing HMDA).At its option, the institution mayeither provide examiners with theaffiliate’s entire HMDA disclosurestatement or just those portionscovering the loans in its assessmentarea(s) that it is electing to haveconsidered. If the affiliate is not9
Collecting the Datarequired by HMDA to report homemortgage loans, the institution mustprovide sufficient data concerningthe affiliate’s home mortgage loansto enable the examiners to apply theperformance tests.Constraints on the Considerationof Affiliate LendingNo affiliate may claim a loanorigination or loan purchase ifanother institution claims the sameloan origination or purchase.However, an institution can count asa purchase a loan originated by anaffiliate that the institutionsubsequently purchases, or count asan origination a loan later sold to anaffiliate, provided the same loans arenot sold several times to inflate theirvalue for CRA purposes.If an institution elects to have itssupervisory agency consider loanswithin a particular lending categorymade by one or more of theinstitution’s affiliates in a particularassessment area(s), the institutionmust elect to have the agencyconsider all loans within that lendingcategory in that particularassessment area(s) made by all ofthe institution’s affiliates.Consortium/Third-Party LoansCommunity development loansoriginated or purchased by aconsortium in which an institutionparticipates or by a third party inwhich the institution has invested:· will be considered, at theinstitution’s option, if the institutionreports the aggregate number andaggregate amount of consortium/third party loans originated orpurchased; and· may be allocated amongparticipants or investors, as theyA Guide to CRA Data Collection and Reportingchoose, for purposes of thelending t
A Guide to CRA Data Collection and Reporting 2 This user’s guide was prepared by CRA/HMDA Systems Information Technology Board of Governors of the Federal Reserve System
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Mar 01, 2016 · A Guide to CRA Data Collection and Reporting. 5. Scenario One. Two institutions are exempt from . CRA collection and reporting . requirements because neither met . the asset size threshold. 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 .
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