Guide to CRA Data Collection & Reporting

Question 1

What types of banks are required to report?

Answer 1

All state member banks, state nonmember banks, national banks, and savings associations that meet or exceed the asset size thresholds for both of the last two calendar years are subject to the data collection and reporting requirements of the CRA

Question 2

Do bank’s that don’t meet the asset size threshold need to submit data?

Can they?

Answer 2

Institutions that do not meet or exceed the asset size threshold have the option of submitting data voluntarily. An institution that submits data voluntarily retains the option of being examined as a large institution.

Question 3

When must the required CRA data be reported each year?

Answer 3

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

Question 4

What are the data collection and reporting requirements for the following scenario?

Two institutions are exempt from CRA collection and reporting requirements because neither met the asset size threshold. The
institutions merge.

Answer 4

No data collection is required for the year in which the merger takes place, regardless of the resulting asset size. Data collection and reporting
would begin after two consecutive years in which the combined institution
would have year-end assets
that meet or exceed the small institution asset size threshold

Question 5

What are the data collection and reporting requirements for the following scenario?

Institution A, an institution with assets that meet or exceed the asset size threshold, and Institution
B, an institution with assets below the asset size threshold, merge. Institution A is the surviving institution.

Answer 5

For the year of the merger,
data collection is required for Institution A’s transactions. Data collection is optional for the transactions of the previously exempt institution. For the following year, all transactions of the surviving institution must be collected and reported.

Question 6

What are the data collection and reporting requirements for the following scenario?

Two institutions that are each required to collect and report data merge.

Answer 6

Data collection is required
for the entire year of the merger and for subsequent years, provided the surviving institution is not
exempt. The surviving institution may file either a consolidated submission or separate submissions
for each institution for the year of the merger, but must file a consolidated report for subsequent years.

Question 7

What are the reporting requirements for a bank that did not originate or purchase small business or small farm loans?

Answer 7

An institution that has not originated or purchased any small business or small farm loans during the reporting period would not submit
the composite loan records for small business or small farm loans. However, all institutions subject to data reporting requirements must submit the information discussed below under “Reporting Requirements.”

• transmittal sheet
• definition of its AA
• record of CD loans
• info on small farm and small business loans if applicable.

Question 8

What information are applicable institutions required to report for CRA? (4)

Answer 8

At a minimum, an institution must submit, in electronic format:
• a transmittal sheet,
• a definition of its assessment area(s),
• a record of its community development (CD) loans. (If an institution does not have CD loans to report, the record should be sent
with “0” in the CD loan composite data fields), and
• information on small business and small farm loans, if applicable.

Question 9

True or false:

CRA data is aggregated on the Census Tract level. Each tract represents one record in an entire data submission.

Answer 9

True

For example:
• Six different small business loans made in the same census tract constitute one composite record.

• Six different small farm loans, three in one census tract and three in another, constitute two composite records.

Question 10

If a bank is not required to collect HMDA data, does it need to collect home mortgage data for CRA?

Answer 10

No, examiners will sample a bank’s home mortgage data in this instance to evaluate the home mortgage lending.

If a bank wants to ensure that examiners consider all of its home mortgage loans, it may collect and maintain data on these loans.

Question 11

What are Modification, extension and consolidation agreements (MECAs)?

Does a bank need to report these for CRA?

Answer 11

Transactions in which an
institution obtains loans from another institution without actually purchasing or refinancing the loans.

In some states, MECAs, which are not considered loan refinancings because the existing loan obligations are not satisfied and replaced, are common. Although these transactions
are not considered to be purchases or refinancings, as those terms have
been interpreted under CRA, they do achieve the same results. An institution may present information
about its MECA activities to
examiners for consideration under the lending test as “other loan data.”

Question 12

When reporting CRA data, what information needs to be included on the transmittal sheet? (8)

Answer 12

-Reporter’s ID number (RID) corresponds to the bank’s cert number

• Bank name
• contact name
• address
• phone number
• fax number
• email address
• record count of the total number of line entries on the submission

Question 13

When reporting CRA data, what information needs to be included regarding the bank’s AA?

Answer 13

List for each assessment area showing the geographies within the area. The assessment area may be reported by census tract; however, it is permitted to report the assessment area property location information at a summary level.

The combinations reported in these examples represent MSA or MD/State/County/Census Tract combinations. The examples are not meant to be exhaustive.
• 47894/NA/NA/NA—The assessment area encompasses all census tracts in MSA/MD 47894.
• NA/56/013/NA—The assessment area encompasses all census tracts in state 56 AND county 013 that are outside of an MSA/MD.

Question 14

Generally what must a bank collect regarding community development activities?

Answer 14

• Number and dollar amount of loans, investments, and services
• the CD purpose for each
• Location of the CD activity (in AA or in area the benefits broader statewide or regional area)

Question 15

What are the four community development purposes?

Answer 15

• Affordable housing
• Community Services
• Economic development
• Revitalization and Stabilization

Question 16

What are the requirements for a CD activity to meet the affordable housing purpose?

Answer 16

Must provide affordable housing (including multifamily housing) to low- moderate- income individuals.

Question 17

What are the requirements for a CD activity to meet the community services purpose?

Answer 17

Must offer community services that primarily target LMI persons.

Question 18

What are the requirements for a CD activity to meet the economic development purpose?

Answer 18

Must promote economic development by financing businesses or small farms that meet the SBA size standards or have GARs of $1MM or less.

(size and purpose test)

Question 19

What are the requirements for a CD activity to meet the Revitalization and Stabilization purpose?

Answer 19

Activities that revitalize or
stabilize
i. Low- or moderate-income
geographies;
ii. Designated disaster areas;
iii. Distressed or underserved
nonmetropolitan middle income geographies

Question 20

Is a bank required to collect and report information on affiliate lending?

Answer 20

An institution is not required to collect information on affiliate loans. However, an institution that elects to have its regulator consider loans by an affiliate, for purposes of the lending or community development test or an approved strategic plan,
must collect, maintain, and report for those loans the data that the institution would have collected, maintained, and reported had the loans been originated or purchased
by the institution.

Question 21

What are the reporting requirements for bank’s and affiliates if they are purchasing and selling loans to each other?

Answer 21

No affiliate may claim a loan
origination or loan purchase if another institution claims the same loan origination or purchase.

However, an institution can count as a purchase a loan originated by an affiliate that the institution subsequently purchases, or count as an origination a loan later sold to an affiliate, provided the same loans are not sold several times to inflate their value for CRA purposes.

Question 22

For banks subject to CRA data collection and reporting, what data do they need to collect and maintain for each small farm and small business loan? (4)

Answer 22

• a unique number or alphanumeric symbol that can be used to identify the relevant loan file;
• the loan amount at origination;
• the loan location; and
• an indicator of whether the loan was to a business or farm with gross annual revenues of $1 million or less

Question 23

What types of commercial loans are applicable bank’s required to collect and report for CRA?

Answer 23

Only those commercial loans included as “Loans to small businesses” as defined under the RC-C of the call report.

Question 24

What is the definition of a small business loan for the purpose of collecting and reporting CRA data?

same at the definition under the call report instructions

Answer 24

Small business loans are defined as those whose original amounts are $1 million or less and that were
reported on the institution’s Call Report as either “Loans secured by nonfarm or nonresidential real estate” or “Commercial and industrial
loans.”

Question 25

What is the definition of a small farm loan for the purpose of collecting and reporting CRA data? same as the definition under the call report instructions

Answer 25

Small farm loans are defined as those whose original amounts are $500,000 or less and were reported as either “Loans to finance agricultural production and other loans to farmers” or “Loans secured by farmland.”

Question 26

true or false: It is the original amount of a loan, not the annual revenue of a business or farm, that determines the classification of a loan as a small business or small farm loan.

Answer 26

True

Question 27

What supplemental information should be maintained for small business and small farm loans?

Answer 27

- census tract of the loan - date of origination or purchase - whether originated or purchased by an affiliate

Question 28

How should SBL be reported if they are secured by non farm residential real estate?

Answer 28

They must be reported as "loans secured by real estate" when the RE collateral taken is greater than 50% of the principal amount of the loan at origination unless the collateral is taken as an abundance of caution. If the value of the RE is 50% or less of the loan amount, the loan should be reported in another category based on the purpose of the loan (ex: commercial and industrial) If the loans promote community development they can be considered as CD loans. Otherwise, the bank may opt to collect and maintain data separately as "other secured loans/lines for purposes of small business"

Question 29

What are the aggregate SBL and Small farm reporting requirements for bank's subject to CRA reporting?

Answer 29

An institution subject to data reporting requirements must report the aggregate number and amount of loans for each geography in which it originated or purchased a small business or small farm loan. Loans to businesses and farms are reported by origination amounts of: * $100,000 or less; * more than $100,000 but less than or equal to $250,000; and * more than $250,000. Institutions must also report loans to businesses and farms with gross annual revenues of $1 million or less, using the revenues that the institution considered in making its credit decisions.

Question 30

When collecting and reporting information on purchased small business and small farm loans, does the bank report the origination amount or the purchase amount? What amount should be used when assessing the volume of SBL and SFL under the lending test?

Answer 30

A bank collects and reports the amount of the loan at origination NOT at the time of purchase. this is because the origination amount is used to determine if a loan is a SBL or SFL according to call report. Under the lending test, the examiner's will evaluate the bank's activity based on the amounts at purchase.

Question 31

When collecting and reporting information on purchased CD loans, what amount should the bank use?

Answer 31

A bank collects and reports the amount of the loan that was purchased. Same for participations, only the amount of the participation purchase. HOWEVER, the bank uses the amount at origination to determine if the loan meets the definition of a SBL, SFL, or CD loan.

Question 32

What amount should be reported in the following example? A bank purchases a $400,000 participation in a business credit that has a CD purpose, and origination amount of the credit by the lead lender is over $1MM.

Answer 32

The bank would report the $400,000 as a CD loan.

Question 33

How should a bank collect information about SBLs and SFLs that it refinances or renews?

Answer 33

The information should be collected as if it was an origination. However, a bank may only report one origination per loan, per year, unless an increase in the loan amount is granted.

Question 34

If a bank increases the amount of a small business or small farm loan when it extends the term of the loan, how should the loan be reported?

Answer 34

The bank should report the amount of the increase as a small business or small farm loan origination. It should only be the amount of the increase if the bank has already reported the original or remaining amount of the loan once that year.

Question 35

How should the following loan be reported? A financial institution makes a term loan for $25,000; principal payments have resulted in a present outstanding balance of $15,000. In the next year, the customer requests an additional $5,000, which is approved, and a new note is written for $20,000.

Answer 35

In this example, the institution should report both the $5,000 increase and the renewal or refinancing of the $15,000 as originations for that year. However, the institution may report the $5,000 increase together with the renewal or refinancing of the $15,000 as a single origination of $20,000.

Question 36

True or false: A demand loan that is reviewed on an annual basis should be reported as a renewal because the term of the loan has been extended.

Answer 36

False: This should not be reported as a renewal because the term of the loan has NOT been extended.

Question 37

Should community development loans that are renewed or refinanced be reported as originations?

Answer 37

Yes, but Community development loan refinancings and renewals are subject to the reporting limitations that apply to refinancings and renewals of small business and small farm loans.

Question 38

How should a bank report lines of credit? SBL and SFL

Answer 38

- collect and report in the same way as loan originations - LOCs are considered originated at the time the line is approved or increased and an increase is considered a new origination. - The full amount of the credit line is considered origination. In the case of an increase to an existing line, the amount of the increase is the amount that is considered originated and that amount should be reported. However, consistent with Call Report instructions, if an increase to an existing line would cause the total line of credit to exceed $1 million, in the case of a small business line, or $500,000, in the case of a small farm line, the institution would not report the increase.

Question 39

How should renewals of lines of credit be reported? SBL and SFL

Answer 39

Renewals of lines of credit for small business, small farm, or consumer purposes should be collected and reported, if applicable, in the same manner as renewals of small business or small farm loans. HMDA reporters continue to collect and report home equity lines of credit at their option, in accordance with the HMDA requirements

Question 40

Is a loan to a fishery or forestry as SBL or SFL?

Answer 40

Either Instructions for part I of the Call Report include loans “made for the purpose of financing fisheries and forestries, including loans to commercial fishermen” as a component of the definition of “Loans to finance agricultural production and other loans to farmers.” Part II of Schedule RC-C of the Call Report, which serves as the basis of the definition for small business and small farm loans in the regulation, captures both “Loans to finance agricultural production and other loans to farmers” and “Loans secured by farmland.” These loans are reported as small business or small farm loans.

Question 41

How should HELOCs uses predominately for Small business purposes be reported?

Answer 41

Institutions that have chosen to report home equity lines of credit under HMDA report only the portion of a home equity line used for home improvement purposes. That portion of the loan would then be considered when examiners evaluate home mortgage lending. If the line meets the regulatory definition of a “community development loan,” the institution should collect and report information on the entire line as a community development loan. If the line does not qualify as a community development loan, the institution has the option of collecting and maintaining (but not reporting) the entire line of credit as “Other secured lines/loans for purposes of small business.”

Question 42

How should a bank report credit cards lines to business employees?

Answer 42

If an institution agrees to issue credit cards to a business’s employees, the institution reports all of the credit card lines opened on a particular date for that single business as one small business loan origination rather than reporting each individual credit card line, assuming the criteria in the “small business loan” definition in the regulation are met. The credit card program’s “amount at origination” is the sum of all of the employee/ business credit cards’ credit limits opened on a particular date. If subsequently issued credit cards increase the small business credit line, the added amount is reported as a new origination.

Question 43

If a bank collects GARs should a bank report adjusted GAR or GAR?

Answer 43

The regulations do not require institutions to request or consider revenue information when making a loan; however, if institutions do gather this information from their borrowers, they should use the gross annual revenue rather than the adjusted gross annual revenue of their small business or small farm borrowers to report whether the borrower has gross annual revenue of a) more than $1 million dollars; or b) $1 million dollars or less.

Question 44

Does CRA require bank's to verify GARs provided by businesses or small farms?

Answer 44

No, the bank may rely on the GAR amount provided by the borrower. They should rely on the revenues it considered when making its credit decision.

Question 45

If a bank does not collect GARs how should they report small business revenues?

Answer 45

The bank should indicate "revenues not known" These loans may not be included in the loans to businesses or farms with GARs of $1MM or less when reporting.

Question 46

How should the bank evaluate the GAR in the following example: In the case of affiliated businesses, the bank considered the revenues of a parent company and subsidiary when making the credit decision. Vs. The bank considered only the revenues of the entity to which the loan is extended.

Answer 46

the institution would aggregate the revenues of both corporations to determine whether the revenues are $1 million or less. the institution should rely solely upon whether gross annual revenues are above or below $1 million for that entity.

Question 47

If a bank considered and relied upon the revenues or income of a cosigner or guarantor that is not an affiliate of the borrower, should the bank include this income in determining GAR for SBL reporting?

Answer 47

No, a bank should not adjust the borrower's revenues for reporting purposes.

Question 48

For a start up business, can a bank use the pro forma projected revenue figures when determining GAR for reporting?

Answer 48

No because these figures may not accurately reflect revenue. The bank should use the actual GAR to date, including $0 if the borrower has had no revenue.

Question 49

How should a bank report the location of a SBL or SFL if the address is unknown? What if they use a PO box?

Answer 49

If the borrower uses a PO box, they should work to determine the address and if not use the CT in which the PO box is located. If neither the address or CT is known, the bank should report it as "NA"

Question 50

What is the definition of a community development loan? What about for wholesale or limited purpose banks?

Answer 50

Loan that: • Has as its primary purpose community development; and • Except in the case of a wholesale or limited-purpose institution: — has not been reported or collected by the institution or an affiliate for consideration in the institution’s assessment as a home mortgage, small business, small farm, or consumer loan, unless it is a multifamily dwelling loan; and — benefits the institution’s assessment area(s) or a broader statewide or regional area that includes the institution’s assessment area(s).

Question 51

What types of commercial loans cannot be reported as small business loans, but can be collected as other loan data? (2)

Answer 51

- Commercial loans/small business loans secured by residential RE, where the value of the RE collateral (after deducting senior liens by others) is less than 50%of the principal amount of the loan at origination. - Small business loans where the security interest in the non farm residential RE was taken only as an abundance of caution Information on these loans should not be reported but should be collected and maintained for CRA review.

Question 52

What are the reporting requirements for loan commitments and letters of credit?

Answer 52

Institutions are not required to collect data on loan commitments and letters of credit. They may, however, provide for examiner consideration information on letters of credit and commitments.

Question 53

What are the reporting requirements for commercial and consumer leases?

Answer 53

Commercial and consumer leases are not considered small business or small farm loans or consumer loans for purposes of the data collection requirements for commercial or consumer loans. However, if an institution wishes to collect and maintain data about leases, it may provide these data to examiners as “other loan data.”

Question 54

What are the data reporting requirements for consumer loans?

Answer 54

There are no data reporting requirements for consumer loans. An institution that chooses to collect and maintain information on consumer loans collects the gross annual income of all primary obligors for consumer loans, to the extent that the institution considered the income of the obligors when making the decision to extend credit. Primary obligors include coapplicants and co-borrowers, including cosigners. An institution does not, however, collect the income of guarantors on consumer loans, because guarantors are only secondarily liable for the debt.

Question 55

When would examiners evaluate consumer loans under CRA?

Answer 55

- If the bank choses to collect and wants the data reviewed, or - If consumer lending constitutes a substantial majority of the bank's business.

Question 56

If consumer lending constitutes a substantial majority of a bank's business, how would it be reviewed?

Answer 56

If consumer lending constitutes a substantial majority of an institution’s business, its supervisory agency will evaluate the institution’s consumer lending in one or more of the following categories: motor vehicle, credit card, home-equity, other secured, and other unsecured loans. In addition, at an institution’s option, its supervisory agency will evaluate one or more categories of consumer lending, if the institution has collected and maintained, as required in section __.42(c)(1), the data for each category that the institution elects to have its supervisory agency evaluate.

Question 57

If a bank chooses to collect consumer loan data, how must it be collected? (2) And what must they collect? (4)

Answer 57

- Must collect data for all loans originated or purchased within the consumer loan category (ex: motor vehicle, credit card) - must maintain the data separately for each category it chooses to collect data. -The data collected must include: • a unique number or alphanumeric symbol that can be used to identify the relevant loan file; • the loan amount at origination or purchase; • the loan location; and • the gross annual income of the borrower that the institution considered in making its credit decision.

Question 58

True or false: Guidance concerning collection of data on small business and small farm loans—including, for example, guidance regarding collecting loan location data and data in connection with refinanced or renewed loans—will also apply to consumer loans.

Answer 58

True

Question 59

How should bank's collect borrower income for consumer loans (if they choose to collect consumer loan data)?

Answer 59

- If banks gather this information from their borrowers, the bank should collect the borrower's GAR - The bank need not verify the income, and can rely on the GAR provided by the borrower. - CRA does not require a bank to consider income with making a loan. If the bank does not do this then the bank need not collect income information. - A bank can list 0 in the income field on consumer loans made to employees as permitted under HMDA.

Question 60

How should a bank submit the CRA data if they keep separate registers for different branches or types of loans?

Answer 60

All registers must be consolidated and submitted to the Board in a single package with one transmittal sheet.

Question 61

What steps should a bank make before submitting CRA data?

Answer 61

- Review the completed data submission and certify the data is accurate before submitting to the board for processing. - Verify the transmittal sheet is accurate and contains all the required information. - data must be checked using edits supplied by the FFIEC.

Question 62

Can you submit CRA data for multiple institutions together?

Answer 62

No, a separate and complete submission must be transmitted for each institution. Prepare and submit individually the submission for each institution.

Question 63

How often should CRA data be submitted to the Board?

Answer 63

No later than March 1 of each calendar year, for applicable banks

Question 64

What happens after the data is submitted?

Answer 64

- the Board runs a Data automation cycle to verify there are no errors. - if the bank has errors, they must resubmit the data. - if the bank has no errors, they receive an institution register summary (IRS) that they must sign and return to the board.

Question 65

What type of data is made publicly available? Where must bank's disclose that it is publicly available?

Answer 65

- Small business, small farm and CD lending - If the bank chooses to have consumer loan data evaluated, then this data would be public as well. Banks provide the public disclosures in their public files.

Question 66

What are the AA requirements for a Wholesale or Limited purpose bank?

Answer 66

-Must consist of one or more MSAs/MDs or one or more contiguous political subdivisions (counties, cities, towns) in which the bank has its main office, branches and deposit taking ATMs.

Question 67

What are the AA requirements for bank's other than Wholesale or limited purpose banks? (5)

Answer 67

- consist of one or more MSAs/MD or one or more contiguous political subdivisions (counties, towns, cities) AND - include the geographies in which the bank has its main office, branches, deposit taking ATMS, and surrounding geographies in which the bank originated or purchased a substantial portion of its loans (HMDA, SBL, SFL, other loans) - Must consist of only whole geographies, may not reflect illegal discrimination, may not arbitrarily exclude LMI geographies, taking into account the bank's size and financial condition - and may not extend substantially beyond an MSA boundary or beyond a state boundary unless the AA is located in a multistate MSA - should represent the area in which the bank is reasonably expected to serve.

Question 68

In addition to the 4 standard Community development purposes, what is the 5th CD purpose that is less common?

Answer 68

Loans, investments, and services that— i. Support, enable or facilitate projects or activities that meet the “eligible uses” criteria described in Section 2301(c) of the Housing and Economic Recovery Act of 2008 (HERA), Public Law 110-289, 122 Stat. 2654, as amended, and are conducted in designated target areas identified in plans approved by the United States Department of Housing and Urban Development in accordance with the Neighborhood Stabilization Program (NSP); ii. Are provided no later than two years after the last date funds appropriated for the NSP are required to be spent by grantees; and iii. Benefit low-, moderate- and middle-income individuals and geographies in the bank’s assessment area(s) or areas outside the bank’s assessment area(s) provided the bank has adequately addressed the community development needs of its assessment area(s).

Question 69

What is a community development loan?

Answer 69

Loan that: • Has as its primary purpose community development; and • Except in the case of a wholesale or limited-purpose institution: — has not been reported or collected by the institution or an affiliate for consideration in the institution’s assessment as a home mortgage, small business, small farm, or consumer loan, unless it is a multifamily dwelling loan; and — benefits the institution’s assessment area(s) or a broader statewide or regional area that includes the institution’s assessment area(s).

Question 70

What is a CD service?

Answer 70

A service that has as its primary purpose community development, is related to the provision of financial services, and has not been considered in the evaluation of the institution’s retail banking services.

Question 71

What is a consumer loan?

Answer 71

A loan to one or more individuals for household, family, or other personal expenditures. A consumer loan does not include a home mortgage, small business, or small farm loan. Consumer loans include the following categories of loans: * Motor vehicle loan, which is a consumer loan extended for the purchase of and secured by a motor vehicle; * Credit card loan, which is a line of credit for household, family, or other personal expenditures that is accessed by a borrower’s use of a credit card; * Home equity loan, which is a consumer loan secured by a residence of the borrower; * Other secured consumer loan, which is a secured consumer loan that is not included in one of the other categories of consumer loans; and * Other unsecured consumer loan, which is an unsecured consumer loan that is not included in one of the other categories of consumer loans

Question 72

What is a Home mortgage loan?

Answer 72

A “home improvement loan,” a “home purchase loan,” or a “refinancing” as defined in Regulation C (12 CFR part 1003), which implements the Home Mortgage Disclosure Act.

Question 73

What is the definition of each income level?

Answer 73

• Low‑income, which means an individual income that is less than 50 percent of the area median income, or a median family income that is less than 50 percent, in the case of a geography; • Moderate‑income, which means an individual income that is at least 50 percent and less than 80 percent of the area median income, or a median family income that is at least 50 and less than 80 percent, in the case of a geography; • Middle‑income, which means an individual income that is at least 80 percent and less than 120 percent of the area median income, or a median family income that is at least 80 and less than 120 percent, in the case of a geography; and • Upper‑income, which means an individual income that is 120 percent or more of the area median income, or a median family income that is 120 percent or more, in the case of a geography.

Question 74

What is a limited purpose institution?

Answer 74

An institution that offers only a narrow product line (such as credit card or motor vehicle loans) to a regional or broader market and for which a designation as a limited-purpose institution from its supervisory agency is in effect.

Question 75

What is a qualified investment?

Answer 75

A lawful investment, deposit, membership share, or grant that has as its primary purpose community development.

Question 76

What is a small farm loan?

Answer 76

A loan included in “loans to small farms” as defined in the instructions in the institution’s “Consolidated Report of Condition and Income” (Call Report).

Question 77

What is a special purpose institution?

Answer 77

An institution that does not perform commercial or retail banking services by granting credit to the public in the ordinary course of business, other than as incident to its specialized operations. These institutions include banker’s banks, and institutions that engage in only one or more of the following activities: providing cash-management controlled-disbursement services or serving as correspondent institutions, trust companies, or clearing agents.

Question 78

What is a wholesale institution?

Answer 78

An institution that is not in the business of extending home mortgage, small business, small farm, or consumer loans to retail customers, and for which a designation as a wholesale institution from its supervisory agency is in effect.

Question 79

If a small institution is designated a wholesale or limited purpose institution, must it collect data that it would not otherwise be required to collect because it is a small institution?

Answer 79

No. However, small institutions that are designated as wholesale or limited purpose institutions must be prepared to identify those loans, investments, and services to be evaluated under the community development test.

Question 80

Should institutions collect and report data on all agricultural loans of $500,000 or less at origination?

Answer 80

Institutions are to report those farm loans that they capture in the Call Report, Schedule RC-C, Part II and Schedule SB of the TFR. Small farm loans are defined as those whose original amounts are $500,000 or less and were reported as either “Loans to finance agricultural production and other loans to farmers” or “Loans secured by farmland” in Part I of the Call Report or TFR.

Question 81

Which location should an institution record if a small business loan’s proceeds are used in a variety of locations?

Answer 81

The institution should record the loan location by either the location of the small business borrower’s headquarters or the location where the greatest portion of the proceeds are applied, as indicated by the borrower.

Question 82

What information about community development loans must institutions report?

Answer 82

Institutions subject to data reporting requirements must report the aggregate number and amount of community development loans originated and purchased during the prior calendar year.

Question 83

For a small bank that collects and reports CRA data, what years should be analyzed and presented for the PE?

Answer 83

- examiners should analyze the most recent two full calendar years - they should present the most recent full calendar year with aggregate data. (the AA concentration table should present all years analyzed)

Question 84

For an intermediate small bank that collects and reports CRA data, what years should be analyzed and presented for the PE? Analysis and presentation should be determined separately for each loan type included.

Answer 84

Same as a large bank that collects and reports: - Analyze all full calendar years since the LX (includes the year the prior evaluation was performed) - Present the most recent full calendar year with agg data. (AA concentration table should present all years analyzed)

Question 85

For an large bank that collects and reports CRA data, what years should be analyzed and presented for the PE? Analysis and presentation should be determined separately for each loan type included.

Answer 85

Same as ISB that collects and reports: - Analyze all full calendar years since the LX (includes the year the prior evaluation was performed) - Present the most recent full calendar year with agg data. (AA concentration table should present all years analyzed)

Question 86

For a small bank that collects but does not report CRA data, what years should be analyzed and presented for the PE? Analysis and presentation should be determined separately for each loan type included.

Answer 86

Analyze - Most recent two full calendar years (if data is collected and found to be invalid, sample and analyze the most recent full calendar year) Present- Most recent full calendar year. (for not reported data, the bank's performance should not be compared to aggregate data) AA concentration should have all years analyzed.

Question 87

For an Intermediate small bank that collects but does not report CRA data, what years should be analyzed and presented for the PE? Analysis and presentation should be determined separately for each loan type included.

Answer 87

Same as Large bank that collects but does not report Analyze- all full calendar years since the prior evaluation (including the year the LX was performed) Present- Most recent full calendar year (non-reported data should not be compared to aggregate) AA concentration should have all years analyzed

Question 88

For a large bank that collects but does not report CRA data, what years should be analyzed and presented for the PE? Analysis and presentation should be determined separately for each loan type included.

Answer 88

Same as ISB that collects but does not report Analyze- all full calendar years since the prior evaluation (including the year the LX was performed) Present- Most recent full calendar year (non-reported data should not be compared to aggregate) AA concentration should have all years analyzed.

Question 89

For a small bank that does not collect CRA data, what years should be analyzed and presented for the PE? Analysis and presentation should be determined separately for each loan type included.

Answer 89

Analysis and Presentation: Most recent full calendar year (as long as bank confirms that one year is representative of the entire evaluation period. Same as Large bank and ISB that don't collect

Question 90

For a large bank that does not collect CRA data, what years should be analyzed and presented for the PE? Analysis and presentation should be determined separately for each loan type included.

Answer 90

Analysis and Presentation: Most recent full calendar year (as long as bank confirms that one year is representative of the entire evaluation period. Same as small bank and ISB that don't collect

Question 91

For an ISB that does not collect CRA data, what years should be analyzed and presented for the PE? Analysis and presentation should be determined separately for each loan type included.

Answer 91

Analysis and Presentation: Most recent full calendar year (as long as bank confirms that one year is representative of the entire evaluation period. Same as small bank and large bank that don't collect

Question 92

When would reviewing a partial year of data be appropriate? For banks that collect data.

Answer 92

Review of partial year data would only be appropriate when there is a short evaluation cycle, such as a previous adverse CRA rating or a de novo institution.

Question 93

Community development data (loans, investments, and services) should be reviewed for the _____ _____ ______.

Answer 93

Entire evaluation cycle.