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

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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

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Foreword

In response to numerous requests and inquiries, the Federal Financial Institutions Examination Council (FFIEC) has developed this guide for Community Reinvestment Act (CRA) data reporters. Data collection, maintenance, and reporting are important aspects of large-institution evaluations under CRA. This guide can be used as a resource when collecting and maintaining data, creating a submission, and posting lending data in the CRA public file. It is designed to reduce burden on the approximately 2,000 financial institutions subject to the reporting requirements of the CRA regulations.

Users of this guide should be aware of its limitations. It relates only to the collection, maintenance, and reporting of small-business and small-farm loan data and to the collection, maintenance, and reporting (as applicable) of other loan data (except data on home mortgage loans) that may be considered during CRA evaluations. Although this guide addresses many issues relating to these matters, new issues arise often; they should be directed to the CRA Assistance Line at (202) 8727584 or crahelp@. Use of this guide is not a substitute for familiarity with the CRA regulations and the interagency questions and answers (Qs&As) that interpret 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 cra.

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Executive Summary: Compliance Responsibilities

Purpose of CRA

The Community Reinvestment Act of 1977 (CRA) is implemented by regulations of the Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System (Board), the Federal Deposit Insurance Corporation (FDIC), and the Office of Thrift Supervision (OTS) (collectively, the agencies) in 12 CFR parts 25, 228, 345, and 563e. The CRA regulations require that information on business, farm, and community development lending by large insured depository institutions be made available to the public.

CRA directs the agencies to encourage insured depository institutions to help meet the credit needs of the communities in which they are chartered. CRA does not prohibit any activity, nor is it intended to encourage unsafe or unsound practices or the allocation of credit.

CRA requires that each insured depository institution's record in helping to meet the credit needs of its entire community, including lowand moderate-income neighborhoods, be assessed periodically. That record is taken into account when considering an institution's applications for deposit facilities, including mergers and acquisitions.

The CRA regulations contain different evaluation methods for different types of institutions: the lending, investment, and service tests for large retail institutions; the community development test for wholesale or limited-purpose institutions; the streamlined performance standards for small institutions; and the strategic-plan

option for institutions with approved strategic plans.

The Consumer Compliance Task Force of the FFIEC promotes consistency in the implementation of the CRA regulations by periodically publishing interagency Qs&As and examination procedures and by facilitating uniform data reporting.

Who Must Report

All state member banks, state nonmember banks, national banks, and savings associations that are not small or special-purpose institutions are subject to the data collection and reporting requirements of the CRA. For the purpose of collecting and reporting small business and smallfarm loan data, a small institution is a bank or thrift that, as of December 31 of either of the prior two calendar years, had total assets of less than $250 million and was independent or an affiliate of a holding company that, as of December 31 of either of the prior two calendar years, had total banking and thrift assets of less than $1 billion. Institutions that are not small are considered large institutions (see the glossary, beginning on page 23, for definitions).

When to Report

Data for a given year must be submitted to the Board, the designated processor for all of the agencies, by March 1 of the following year.

Merging Institutions

Following are three scenarios describing data collection and

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