Under Reg O, do I report the total outstanding loan on the call report, or the amount that the insider is limited to through his guaranty? For example: Mr. S has a loan for $500,000, but only guarantees 10% of that loan. Should $500,000 or $50,000 be reported on the call report?
We are reviewing our collateral and purpose codes. Are the codes standardized in the industry or are we free to create our own? Do they flow to the call report?
In relation to Reg O, or whatever applicable regulation, where does it state that on the call report the Bank must disclose the entire amount of a Line of Credit? We are working on a Reg O audit, but would like to reference something concrete that states they should disclose the entire amount of the LOC, not just the current balance.
I'm doing a CRA coding review, and would like to know where I could go to find a list of CRA codes. For example: What is a collateral code of 260? Class code of 20? Purpose code? As you can probably tell, this is new for me.
In general, how are banks managing the withdrawal limitations of Reg D on money market deposit accounts with sweep activity? (Going from the money market account to a demand deposit account.) Some years ago I heard of one bank that treated their MMDAs as a "repurchase" agreement for reporting purposes (CALL Reports). How would that affect reserve requirements? Is this a usual practice for banks, or was someone just being creative?
This is a Regulation D question regarding savings accounts. We are looking at moving the balances of all savings accounts that have ACH debits currently set up, as well as all accounts that have an ATM or debit card, into a separate general ledger and classifying those accounts as "Transaction Accounts" for call report purposes. These accounts would not be closed or transferred to another type of account. This would leave the savings accounts as they are now. This would be an internal move only of the balances to a transaction account that the customer would not be aware of. The accounts would continue to earn interest and the customer would continue to pay the bank's excessive W/D fees. Would this eliminate the necessity to notify customers of limitation requirements on existing accounts? Could this make monitoring of any of the savings accounts possibly unnecessary? Could you continue to pay interest on this type of account? Or would this be considered a total violation of Reg. D?
Question: I know the FDIC is using call reports to identify the person to contact for 314(a).
Let's say we have a business loan that has real estate collateral that was taken out of an abundance of caution -- 1st mortgage on a single family residence. Loan is made to an individual. Is a 1098 form needed for this business loan? I have learned from Ken Golliher’s response that the purpose of the loan or the use to which the collateral is put is irrelevant. However, our question is that, since the collateral is taken by the lender out of an abundance of caution, is it all right if we do not treat the loan as a real estate loan for Call Report purposes? (See FFIEC 031 and 041 Glossary page A-58 (6-01).)
With Section 314(a) now in play, we have some questions about the compliance process - and some frustrations.
The almost annual event for CRA has occurred.