A Guide To CRA Data Collection And Reporting

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EDITION EFFECTIVE for 2015 CRA Data Submissions(Due March 1, 2016)A Guide toCRA Data Collectionand ReportingFederal Financial InstitutionsExamination Council

ContentsForeword 3Executive Summary: Compliance Responsibilities 4Purpose of CRA 4Who Must ReportWhen to Report44Reporting Requirements5File Specifications and Edit Validations 5Collecting the Data 7Composite Loan DataOther Loan Data14Consumer Loans157Reporting the Data 16Reporting Tools16Submitting the Data17Data Automation Cycle18Public Availability of Data 19Glossary 22Appendix A—Regulation BB: Community Reinvestment 26Appendix B—Interagency Questions and Answers 48Appendix C —State and County Codes and MSA/MD Numbers 58Appendix D—Federal Supervisory Agencies 78Appendix E—Call Report Instructions 81A Guide to CRA Data Collection and Reporting2

ForewordIn response to numerous requestsand inquiries, the Federal FinancialInstitutions Examination Council(FFIEC) has prepared this guidefor Community Reinvestment Act(CRA) data reporters. Data collec tion, maintenance, and reporting areimportant aspects of financial insti tution evaluations under CRA. Thisguide can be used as a resourcewhen collecting and maintainingdata, creating a submission, andposting lending data in the CRApublic file.The FFIEC produces a public dis closure statement for every report ing institution. The disclosures andother CRA data are available fromthe FFIEC, by accessing the FFIECInternet site, www.ffiec.gov/cra .Users of this guide should be awareof its limitations. It relates only to thecollection, maintenance, and report ing of small business loans, smallfarm loans, and community develop ment data as well as the collection,maintenance, and reporting of otherapplicable loan data (except data onhome mortgage loans) that may beconsidered during CRA evaluations.Although this guide addresses manyissues relating to these matters, newissues arise often. For further infor A Guide to CRA Data Collection and Reportingmation about compliance, contactyour federal supervisory agency (seeAppendix D). Institutions may alsocontact the CRA Assistance Line atcrahelp@frb.gov for assistance withdata collection and reporting.Use of this guide is not a substitutefor familiarity with the CRA regula tions and the Interagency questionsand answers (Qs&As) that interpretthose regulations. The regulationsand Qs&As may be revised fromtime to time. Thus, institutionsshould consult them to determinewhether this edition of the guidereflects the most recent revisions.Both are available in the appendicesof this guide and on the FFIEC’sCRA website at www.ffiec.gov/cra .The FFIEC welcomes suggestionsfor making changes or additionsthat might make this guide morehelpful. Send your suggestions orcomments toFFIEC3501 Fairfax DriveRoom B3030Arlington, VA 22226.Alternatively, you may provide feed back px .3

Executive Summary: Compliance ibilitiesPurpose of CRAThe Community ReinvestmentAct of 1977 (CRA) is implementedby regulations of the Office of theComptroller of the Currency (OCC),the Board of Governors of theFederal Reserve System (Board),and the Federal Deposit InsuranceCorporation (FDIC) (collectively, theagencies) in 12 CFR parts 25, 228,345, and 195. The CRA regulationsrequire that information on business,farm, and community developmentlending by insured depositoryinstitutions that meet certain assetthresholds, determined annually, bemade available to the public.CRA directs the agencies toencourage insured depository insti tu tions to help meet the credit needsof the communities in which they arechartered. CRA does not prohibitany activity, nor is it intended toencourage unsafe or unsoundlending practices or the allocationof 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 institu tion’sapplications for deposit facilities,including mergers and acquisitions.The CRA regulations contain differ ent evaluation methods for differenttypes of institutions: the lending,investment and service tests forlarge retail institutions; the lend ing and community developmenttest for intermediate small institu tions; the stream-lined performancestandards for small institutions; thecommunity development test forwholesale/limited-purpose institu tions; and the strategic-plan optionA Guide to CRA Data Collection and Reportingfor institutions with approved strate gic plans.The Consumer Compliance TaskForce of the FFIEC promotes con sistency in the implementation ofthe CRA regulations by periodicallypublishing Interagency Qs&As oncommunity reinvestment and exami nation proce dures, and by facilitatinguniform data reporting.Who Must ReportAll state member banks, statenonmember banks, nationalbanks, and savings associationsthat meet or exceed the assetsize thresholds for both of the lasttwo calendar years are subject tothe data collection and reportingrequirements of the CRA. The assetsize thresholds are adjusted andannounced by the federal bankingagencies annually by December31. The agencies also publish thecurrent and historical asset sizethresholds at www.ffiec.gov/cra .Institutions that do not meet orexceed the asset size thresholdhave the option of submitting datavoluntarily. An institution that sub mits data voluntarily retains theoption of being examined as a largeinstitution.When to ReportData for a given year must be sub mitted to the Board, the designatedprocessor for all of the agencies, byMarch 1 of the following year.Merging InstitutionsFollowing are three scenariosdescribing data collection andreporting responsibilities for thecalendar year of a merger and forsubsequent years.4

Scenario OneTwo institutions are exempt fromCRA collection and reportingrequirements because neither metthe asset size threshold. Theinstitutions merge. No datacollection is required for the yearin which the merger takes place,regardless of the resulting assetsize. Data collection and reportingwould begin after two consecutiveyears in which the combined insti tution would have year-end assetsthat meet or exceed the small insti tution asset size threshold amountdescribed in 12 CFR .12(u)(1).Scenario TwoInstitution A, an institution withassets that meet or exceed theasset size threshold, and InstitutionB, an institution with assets belowthe asset size threshold, merge.Institution A is the surviving institu tion. For the year of the merger,data collection is required forInstitution 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 that are eachrequired to collect and report datamerge. Data collection is requiredfor the entire year of the mergerand for subsequent years, providedthe surviving institution is notexempt. The surviving institutionmay file either a consolidatedsubmission or separate submissionsfor each institution for the yearof the merger, but must file aconsolidated report for subsequentyears.A Guide to CRA Data Collection and ReportingInstitutions That Did NotOriginate or Purchase SmallBusiness or Small FarmLoansAn institution that has not originatedor purchased any small businessor small farm loans during thereporting period would not submitthe composite loan records forsmall business or small farm loans.However, all institutions subjectto data reporting requirementsmust submit the information dis cussed below under t a minimum, an institution mustsubmit, in electronic format: a transmittal sheet, a definition of its assessmentarea(s), a record of its community devel opment (CD) loans. (If an institu tion does not have CD loans toreport, the record should be sentwith “0” in the CD loan compositedata fields), and information on small businessand small farm loans, if applicable.CRA data are aggregated on thecensus tract level. Each tract rep resents one record in an entire datasubmission. For example: Six different small business loansmade in the same census tractconstitute one composite record. Six different small farm loans,three in one census tract andthree in another, constitute twocomposite records.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 CRAexam. Examiners will sample aninstitu tion’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 trans actions 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.”File Specificationsand Edit ValidationsThe FFIEC makes available freeCRA Data Entry Software to anyinstitution that wishes to use it. Thesoftware includes several basicanalytical reports regarding aninstitution’s data. The latest versionof the CRA Data Entry Softwarecan be downloaded, free of charge,from the FFIEC CRA website . Ifan institution finds that the FFIEC’ssoftware does not meet its needs, itmay create a data submission usingthe File Specifications ( http://www.ffiec.gov/cra/fileformats.htm ) and5

Edit Validation Rules ( http://www.ffiec.gov/cra/edits.htm ) thathave been set forth to assist withelectronic data submissions. Forinformation about specific electronicformatting procedures, contact theCRA Assistance Line at crahelp@frb.gov or click on “SubmittingData” 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.Syntactical (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 indicatethat the property combination for that record identifier was used morethan once. These records will not be reflected in your disclosure state ment until the appropriate corrections have been made.Validity (V) — Records containing incorrect information. The most com mon validity errors are incorrect census tracts. These records will not bereflected in your disclosure statement until the appropriate correctionshave 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 qual ity edits, if the data are correct, no changes are necessary and the datawill be reflected.Edit Validation RulesWhen an institution choosesto create 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 dividedinto three edit types: syntactical,validity, and quality. Each typecorresponds to errors of a differentdegree of severity, and each mustbe thoroughly understood to ensurethat the data are accurate andcomplete.A Guide to CRA Data Collection and Reporting6

Collecting the DataCollecting theDataComposite Loan DataReportingTransmittal SheetFor institutions covered by CRAreporting requirements, the institu tion must collect and report a listfor each assessment area show ing the geographies within thearea. The assessment area maybe reported by census tract; how ever, it is permitted to report theassessment area property locationinformation at a summary level. Forexample, "NA" in the MSA/MD fieldrepresents an area outside of anymetropolitan statistical area. "NA"in the state, county, or census tractfield(s) represents the defined area(state, county, or census tract) in itsentirety. Also, an "NA" entry in thecensus tract field represents allcensus tracts for the MSA orMD/state/county combinationrepresented.The transmittal sheet is used toidentify each institution. Institutionsare asked to provide a reporter’sidentification (RID) number. Thisnumber corresponds to the certifi cate number for FDIC-supervisedinstitutions, and the charter numberfor OCC-supervised institutions. If aninstitution is supervised by the Fed eral Reserve System, the Research,Statistics, Supervision and Regula tion, and Discount and Credit (RSSD)Number is used. Institutions that donot know their reporter identifica tion number should contact the CRAAssistance Line at crahelp@frb.govto obtain it.The transmittal sheet provides valu able institution and contact informa tion. It is important that the institu tion’s name, contact name, address,phone number, fax number, ande-mail address be correct since allfuture correspondence will be basedon that information.DelineationBelow are the examples of how theproperty location information canbe reported on the assessment arearecord. Assume that each of theseexamples are individual assessmentareas. The combinations reportedin these examples represent MSAor MD/State/County/Census Tractcombinations. The examples are notmeant to be exhaustive.For institutions other than those des ignated as wholesale or limited-pur pose (see the glossary), assessmentareas must consist generally of oneor more metro politan statistical divi sion (MSA/MD) or one or more con tiguous political subdivisions such ascounties, cities, or towns. An institu tion must include the geogra phiesin which its main office, branches,and deposit-taking ATMs are locatedas well as the surrounding geogra phies in which it has originated orpurchased a substantial portion ofits loans. Refer to section .41 ofthe regulations and the InteragencyQs&As for further guidance. 47894/NA/NA/NA—The assess ment area encompasses all cen sus tracts in MSA/MD 47894. NA/56/013/NA—The assessmentarea encompasses all censustracts in state 56 AND county013 that are outside of anMSA/MD. 47894/51/059/NA—The assess ment area encompasses allcensus tracts in MSA/MD 47894,state 51, AND county 059. 47894/51/059/4220.00—Theassessment area encompassesonly census tract 4220.00 incounty 059, state 51, and MSA/MD 47894.Assessment Area(s)Delineation and ReportingA Guide to CRA Data Collection and Reporting7

Reporting AssessmentAreas Using Includesand ExcludesA current explanation of how toreport assessment areas is coveredbelow and at the FFIEC CRAwebsite under “Explanation ofAssessment Area Edits”.Another example demonstrates anassessment area that encompassesan entire MSA/MD, less threecounties:Include/Exclude MSA/( /–)MDState CountyCensusTract 3067NATo include or exclude property loca tions in the assessment area, a " "or "-" is required in the field prior tothe property location

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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