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#2450 - 06/20/01 08:01 PM CRA and Call Reporting Codes
Angel Eyes Offline
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Angel Eyes
Joined: May 2001
Posts: 4,599
I recently learned that we should be looking at the call report codes when scrubbing our CRA data. I also understand that depending on how the loans are classified on the call report can help determine if they may be "community development" loans. Can anyone out there reference what to look for on the call report codes?

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General Discussion
#2451 - 06/20/01 08:21 PM Re: CRA and Call Reporting Codes
Anonymous
Unregistered

We don't use call codes to compile our call report. The controller uses our purpose code system to complete the call report. We have put together a matrix that shows the call report category matched to the appropriate purpose, class, collateral and CRA codes. It took cooperation from our controller and loan admin along with myself to make sure our loans were being classified correctly. We found that some 7000 loans had been inaccurately coded. Centrax helped us to find this deficiency. It would be prudent of you to make sure your loan portfolio is accurately assessed before you rely on the call code. We thought we could and we were sorely mistaken.

Remember the call report is driven by purpose of the loan and when you look at CRA the purpose drives it. Inaccurate data can have severe reprecussions with the examiners.

I would be glad to share our matrix if you are interested.


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#2452 - 06/20/01 08:30 PM Re: CRA and Call Reporting Codes
Angel Eyes Offline
Power Poster
Angel Eyes
Joined: May 2001
Posts: 4,599
That would be greatly appreciated! I have no idea where to start , and this will give me my direction.

You can reach me at: jfoote@bankfirstnational.com
or you could fax the information to me at:
920-683-5693


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#2453 - 06/21/01 11:49 AM Re: CRA and Call Reporting Codes
RVFlyboy Offline
Power Poster
RVFlyboy
Joined: Oct 2000
Posts: 5,991
Soaring over Georgia
Brenda, I would also like to get a copy if I could. My e-mail is jim.bedsole@carolinafirst.com. My fax number is (803) 358-6008. Thanks.

------------------
Jim Bedsole, CRCM, CBA, CFSA

Opinions expressed are my own, and do not necessarily reflect those of my employer.

_________________________
Jim Bedsole, CRCM, CBA, CFSA, CAFP
My posts - my opinions

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#2454 - 06/21/01 08:05 PM Re: CRA and Call Reporting Codes
Anonymous
Unregistered

Brenda
Would you please add me to the list to receive the matrix. My Fax is (858) 573-2998 or
e-mail to compliance@crahelp.com

Thank You


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#2455 - 06/22/01 05:19 PM Re: CRA and Call Reporting Codes
Anonymous
Unregistered

The CALL code alone will not identify community development loans.

You can however, use it to help determine which loans are possibilities.

After you determine that loans are CALL coded correctly:

Review loans that are greater than 1 million dollars and are coded 4A and 1E.

Review loans (of any amount) that are coded 9B.

Review business purpose loans that are coded 1C or 1D.


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#2456 - 06/22/01 05:27 PM Re: CRA and Call Reporting Codes
Princess Romeo Offline

Power Poster
Princess Romeo
Joined: Jun 2001
Posts: 8,272
Where the heart is
Don't forget to look at any unsecured loans to a non-profit organization.

Unsecured loans to non-profits cannot be reported as a small business loan on the call report. So, if the purpose of the loan meets the community development test, you can list it as a CD loan.

Also, if residential property secures a loan to a non-profit, you cannot report it as small business, so you need to see if it meets the qualification for CD.

However, if the loan is secured by commercial property, then you are required to report it as a small business loan.

_________________________
CRCM,CAMS
Regulations are a poor substitute for ethics.
Just sayin'

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#2457 - 06/25/01 05:08 PM Re: CRA and Call Reporting Codes
dlwfnbsf Offline
New Poster
Joined: May 2001
Posts: 7
Sioux Falls SD USA
Brenda

Would you also fax me a copy of the matrix. My fax number is 605-335-5191. Or if e-mail is better my address is dlwalhof@fnbsf.com Thanks, Darlene

[This message has been edited by dlwfnbsf (edited 06-25-2001).]

_________________________
Darlene Walhof

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#2458 - 06/25/01 05:25 PM Re: CRA and Call Reporting Codes
Louise Offline
New Poster
Louise
Joined: May 2001
Posts: 9
Arroyo Grande, CA
Brenda, I would like a copy of your matrix as well - seems there are a lot of us who are interested. Maybe you could post it as an attachment.... might save you some time! My email address is: lschmelzer@americangeneralbank.com
_________________________
Opinions expressed are my own and do not necessarily reflect those of my employer.

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#2459 - 06/27/01 03:56 PM Re: CRA and Call Reporting Codes
Anonymous
Unregistered

The Q&A for .42(a) discusses what loans to report as small business and small farm. As a general rule, you can't count a loan under the lending test and as community development. The Federal Reserve Bank Dallas has a CRA Data Collection Grid post on its website which is helpful in identifying reporting category. The URL is www.dallasfed.org/htm/pubs/pubindex.html

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#2460 - 06/29/01 04:07 AM Re: CRA and Call Reporting Codes
Anonymous
Unregistered

The grid Diane is referring to is very helpful.

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#2461 - 03/28/03 04:11 PM Re: CRA and Call Reporting Codes
Anonymous
Unregistered

Please, please, could you email or fax me a copy of your matrix. Call codes are like reading a different language to me and I keep stuttering!!! I'm a registered user of BOL, just in a rush and didn't log in. phemphill@ctb-bank.com or 318-322-1618

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#2462 - 03/28/03 04:38 PM Re: CRA and Call Reporting Codes
Anonymous
Unregistered

Could you please send me a copy as well? my email address is
erzi@emprisebank.com
greatly appreciated!!!!

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#2463 - 03/28/03 05:10 PM Re: CRA and Call Reporting Codes
Anonymous
Unregistered

Would you please send me a copy of your matrix?
I am registered but did not log in.
ccrowley@republicebank.com

We are trying to get more organized in this area.

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#2464 - 03/28/03 05:12 PM Re: CRA and Call Reporting Codes
Don_Narup Offline

Power Poster
Joined: Jul 2001
Posts: 3,708
Las Vegas Nevada
There are 4 call codes used on the call report to identify Small Business and Small Farm loans. 1E and 4A for Small Business and 1b and 3 for Small Farm. As an internal practice, some institution use their purpose codes to catorgize which loan are Small Business or Small Farm for Call Report purposes. Using internal purpose, class, collateral code certainly eases the burden in assigning Call Codes,, it will increase the accuracy of Call Report reporting, but there may still not be a tie in to what the Compliance dept (officer) is actually inputting on the CRA annual submission report.

Smaller institution usually have someone assign a Call Code when the loan is boarded. This is where you will find a vast difference between whats reported on the Call report as Small Business/Farm and whats reported in the annual CRA submision. I.E note dept boards and assigns small business call code, compliance officer reviews loan and decides its not Small Business, so doesn't inclue in annual CRA submission. Usually no one goes back and changes the call report code.

The matrix may be a great tool, just remember that your institution is going to have entirely different class, collateral,and purpose codes.

_________________________
Compliance Analysis and Research - Software for your CRA/HMDA analysis needs

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#2465 - 03/28/03 05:28 PM Re: CRA and Call Reporting Codes
RebekahL CRCM Offline
Platinum Poster
RebekahL CRCM
Joined: Feb 2003
Posts: 875
Big Sky Country
Quote:

Smaller institution usually have someone assign a Call Code when the loan is boarded. This is where you will find a vast difference between whats reported on the Call report as Small Business/Farm and whats reported in the annual CRA submision






Don, could you provide more info about this? My bank just became a "large bank" and just began collecting data this year. Based on what I read from FFIEC's instructions, I thought the easiest way to make sure the proper loans were being collected was to tie them to the FDIC Call Code. I have tasked my loan review specialists with entering this info on FFIECs free software (I am a relatively small shop with only 5 locations doing this).

We are only reporting small biz, small farm, and community development loans. I plan to scrub and analyze the CD loans on my own at year end, but for the first two, I am depending on the call code to properly identify them!

Now I'm wondering if this was a bad decision. Could you advise? We have always gotten "outstandings" as a small bank, and I'm learning now just how difficult that rating is to obtain as a large bank. I'd like to do everything I can to get it right!

Thanks,

Rebekah
_________________________
Me, Type A? Maybe - I'm not done analyzing it yet.

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#2466 - 03/28/03 05:55 PM Re: CRA and Call Reporting Codes
Don_Narup Offline

Power Poster
Joined: Jul 2001
Posts: 3,708
Las Vegas Nevada
Rebekah

I have to leave the office for a couple of hours and can't respond right away. But do have some thought for you




_________________________
Compliance Analysis and Research - Software for your CRA/HMDA analysis needs

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#2467 - 03/28/03 10:13 PM Re: CRA and Call Reporting Codes
HRH Dawnie Offline
Power Poster
HRH Dawnie
Joined: Aug 2002
Posts: 7,353
Anchorage Alaska
Rebekah, using just the call code to determine if a loan is CD is probably a stretch. I don't think I'd do it. The problem is that although the loan itself may feel CD (lets say a refi with cash out to a multi-family property in a low income tract) the use of the funds must also be consistant with the goals of CRA. The refi with cash out could be to remodel the units and provide for a better living arrangement for the tenants...yup, totally CRA, but what if the refi was just a quick rate relief with cash out to build the slum lord a new swimming pool on his own property?

I think perhaps the call report might be a starting place...but you'd do better to pull the files on all loans over one million and review them for CD potential. Also pull all multi-family and check those out, then start working on the non-profits that couldn't be reported...

I always start out with the big number deals and work my way down. Spending an hour writing up a $25,000 loan to a non-profit verses finding a $14,000,000 large deal in the loans over one million is in my mind...a waste of my time. I want the most bang for my buck I can get...then when time allows I work my way down.
_________________________
Dawn Coursey VP/CRA Queen

CRA Rating is in...Oh who cares...I'm home with the baby.

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#2468 - 03/28/03 10:32 PM Re: CRA and Call Reporting Codes
Anonymous
Unregistered

Brenda -
Would you consider adding your matrix to BOL's tools? Please please?

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