We are having a CRA exam soon and have been reviewing the list of files the examiners have requested. For renewals, our mainframe system has been taking the date that the renewal was input on the system and transferring that to the CRA software as the action taken date. So, for example, we have a loan that renewed with a contract date of 5-11-02, but the date on the CRA LAR is 5-29-02 because that is the date the renewal was adjusted on the mainframe. Our mainframe has since corrected the problem, and we corrected most of the errors before submission, but do you think this will be a "material" error as far as the examiners are concerned? I'm looking for some feedback as to other's experiences- thanks!

I can see some examiners writing this up as a system wide violation, even if corrected by the bank. I assume when you say CRA LAR you are referring to the HMDA LAR since you are talking about the action date. Small business, farm and community development loans reported under CRA don't have the same info reported for HMDA. So much is keyed off the action date, so I would think the examiners are not going to be please that the system picked the date the loan was changed on the system as the action date.

Actually, I use the system process date for all of my loans regardless of new vs. renewal. I have done this for several years and the examiners have been fine with it as long as I was consistent. My justification for doing so is that the system effective process date is our interest start date and we consider that to be the action date. Our system process effective date is always the same as our disbursement date. We do not use the document dates because they can be drawn and held or changed and it's too hard to track. The system effective date works for us.

I assume that you have corrected your files internally, since once data is submitted to the FFIEC it cannot be changed. I suspect your regulator will require a manual scrub of your data for the period in question, so they are comfortable in using the data for analysis during their exam. Make sure you document when you discovered the "glich" in your system, when it was corrected and the procedures put into place to avoid problems of this nature in the future. Admit the problem, scrub the data and provide the solution. The bottom line manually scrub as many times as it takes before submission.

The data reported in the CRA LR is different than the HMDA LAR.

The HMDA LAR is a line by line report of each loan including application date and action date, which is defined in HMDA as the "Consumation" date.

The CRA LR is COMPOSITE data of the number and dollar amount of small business and small farm loans made in each size category, and the number and dollar amount of small business and small farm loans according to each revenue size category, and AGGRETATE data on the number and dollar amount of Community Development and Third Party/Consortia loans. You also send in the Assessment Area information which then reports the number of loans made inside/outside your assessment area.

The DATE of the loan is NOT required reporting for your CRA LR. So what are you supposed to scrub and re-submit?

The only place your action date shows is the Micro Loan data to your examiners. I suppose if they really want to be picayune, then they can make you go through the drill to correct their microloan data by the few days on the action date, but it would not serve any purpose except to know that you either have an examiner from hell, or you did something else to really cheese them off.

The only area this would be tricky would be loans that you "Actioned" late in one year, but did not get booked into your system until this year. IMHO, you an do one of two things in this case:
1. Demonstrate that you have been consistent year after year in reporting these loans so that you would not have counted the same loan twice from one year to the next,
2. Demonstrate to the examiners that the date on the note is irrelevant, and the only date that matters is when the thing got booked onto your system.

Finally, check out the Q&A, Question 42(a)2 for a list of what is required to be maintained. For the Action date, the Q & A states:
In addition, supplemental information contained in the file specifications includes a date associated with the origination or purchase..

Date ASSOCIATED WITH is a much looser definition than the CONSUMATION DATE for HMDA. Therefore, I would maintain that the date your system shows IS the "date associated with" that loan.

I concur with Bonnie M.

Can anyone tell me if the loan amount is rounded on CRA data collection? I can't seem to locate this in the FFIEC Guide to CRA Collection & Reporting?

The Origination Amount entered in the CRA Data Collection as well as HMDA Data Collection programs and reported to FRB should be rounded to the nearest $1,000.

Thanks for the info. Is the rounding exactly like HMDA with the break - up or down - at $500? Do you know where I can find this information in the Guide book or in the Reg itself? I still cannot seem to locate it.