I have read in several "unoffical" places that the Call Codes to use when reporting Small Business loans on the CRA LR are 01e0 or 04a0. I have also read that reporting CRA Small Business loans without these Call Codes would be incorrect. Could someone please point me to where I could find something "official" to hang my hat on regarding the use of these codes to determine what loans go on the CRA LR? We are regulated by the FDIC. Thank you.

http://www.ffiec.gov/cra/guide.htm

You'll find both the "Getting it Right" book here, as well as the call code booklet. The two should be used in conjunction when determining the reportability of a loan.

The regulator, by the way, has no effect on this. We all report the same (or at least we're all supposed to)

Dawnie, how does this reportability square with the CRADES software? Is it a matter of educating the credit analysts handling the loans to do their end (call codes) correctly?

I'm not familiar with CRADES Ron, but I can share how we determine call codes and CRA codes.

We have a listing of loan codes that filter themselves down to the correct CRA and Call Codes. We begin with a purpose code (determined by the description of the loan) as the primary code used to determine the balance of the codes. (A few examples if I can make this work via cut and paste:)

Purpose Code CC Description CRA Code(s) Call Report Line Item #
410 5X Loans to Individuals or Business Entities Engaged in Commercial Fishing or Mari culture 2 or 9 3
430 5X Loans to Individuals or Business Engaged in Forestry Related Businesses 2 or 9 3
195 15 Tax Exempt Not Secured by Real Estate 9 8
196 15 Tax Exempt Secured by Real Estate - Non Farm/Non Residential 9 8
197 15 Tax Exempt Secured by Real Estate - HMDA HMDA 8
110 12 Raw Land Non Farm/Non Residential - Commercial Purpose 9 1a
111 12 Raw Land - Consumer Purpose 7 1a
112 12 Land Acquisition & Development - Commercial Purpose 9 1a
113 12 Land Acquisition & Development - Consumer Purpose 7 1a
114 12 Construction 1-4 Family Units - Commercial Purpose 3 or 9 1a
115 11 Construction 1-4 Family Units Owner Occupied - Consumer Purpose 7 1a
116 12 Construction Multi-Family - Commercial Purpose (Term less than 18 months) 3 or 9 1a
117 12 Construction Non Farm/Non Residential - Commercial Purpose 9 1a
118 12 Improved Lot - Commercial Purpose 9 1a
119 12 Improved Lot - Consumer Purpose 7 1a
120 12 Farm Land 2 or 9 1b
167 13 Home Equity Line of Credit 1st Lien 4 1c 1
168 13 Home Equity Line of Credit Junior Lien 4 1c 1
131 1 or 11 FHA 1-4 Family Home Purchase HMDA 1c 2 a
133 1 or 11 FHA 104 Family Refinance HMDA 1c 2 a
134 22 FHA 1-4 Family Purchased MSR - 1c 2 a
135 22 FHA 1-4 Family Refinanced MSR - 1c 2 a
136 8 or 11 VA 1-4 Family Home Purchase HMDA 1c 2 a
138 8 or 11 VA 1-4 Family Home Refinance HMDA 1c 2 a
139 23 VA 1-4 Family Home Purchase MSR - 1c 2 a
140 23 VA 1-4 Family Refinanced MSR - 1c 2 a
141 9 or 11 Conventional 1-4 Family 1st Lien Home Purchase HMDA 1c 2 a
142 9 or 11 Conventional 1st Lien Home Improvement HMDA 1c 2 a
143 9 or 11 Conventional 1-4 Family 1st lien Refinance HMDA 1c 2 a
144 12 Conventional 1-4 Family 1st Lien Non-HMDA - Commercial Purpose 3 or 9 1c 2 a
145 12 Conventional 1-4 Family 1st Lien Non-HMDA Equity Extraction - Commercial Purpose 3 or 9 1c 2 a
146 11 Conventional 1-4 Family 1st Lien Non-HMDA Equity Extraction - Consumer Purpose 4 1c 2 a
147 24 Convential 1-4 Family Purchased MSR - 1c 2 a
148 24 Conventional 1-4 Family Refinannced MSR - 1c 2 a
149 12 Commercial Purpose 1-4 Family 1st Lien HMDA Refinance HMDA 1c 2 a
132 1 or 11 FHA 1-4 Family Home Improvement HMDA 1c 2 b
137 8 or 11 VA 1-4 Family Home Improvement HMDA 1c 2 b
152 11 or 12 Conventional 1-4 Family Junior Lien Home Improvement HMDA 1c 2 b
153 11 Conventional 1-4 Family Junior Lien Refinance HMDA 1c 2 b
155 12 Conventional 1-4 Family Junior Lien Non-HMDA Equity Extraction - Commercial Purpose 3 or 9 1c 2 b
156 11 Conventional 1-4 Family Junior Lien Non-HMDA Equity Extraction - Consumer Purpose 4 1c 2 b
150 12 Commercial Purpose 1-4 Family 1st Lien HMDA Purchase HMDA 1c 2a

When an option for a code (ie CRA 1 or 9) is listed, it's normally based on size. Our system will not allow for an improper mix of these codes. A rejected report is produced daily for improper combinations. So you wouldn't see a CRA code of 1 on a consumer purpose code of say 146.

We have our lenders (and yes it's often the loan secretaries) choose the code, but we also audit during our data integrity audit to ensure that proper coding is applied. Normally the threat of a monetary fine (for improper call reporting) is enough to get them all to take this seriously. Occasionaly I am called in to figure out a wierd loan, and do so, hopefully without developing a new purpose code, but that has happened a couple of times. If a new purpose code is necessary, I am sure to get the in put of ALL of the parties involved so we get the class/purpose/cra and call report codes all lined up correctly. It might be an elaborate system, but it works and it protects the entire bank, verses me alone having a nice clean CRA LR.

That didn't work well...tabs and BOL do not get along! I hope it makes sense!

Thanks Dawnie Pie!

LOL You're very welcome Ronnie Pie

My last remaining bit of confusion covers the use of 1a or 04A or 030 or 06B. What is the difference between the Type codes and the other codes which I believe are call codes?

I also need to mention that my computer is crashing everytime I try to use a PDF so I am asking instead of hunting on my own.

CRA Loan Type codes identify the type of loan being reported.

1= Small Business
2= Small Farm
3= Other Lines and Loans for a Small Business Purpose
4= Home Equity
5= Motor Vehicle
6= Credit Card
7= Other Secured Consumer Loans
8= Other Unsecured Consumer Loans
9= Other Loan Data.

The federal call codes are not used in the annual CRA reporting, but do identify loans for the Quarterly Call Report that meet the definition of Small Business and Small Farm.

The definition of the call codes used in the Call Code instructions is the definition used to identify Small Business/Farm Loans.

Call codes are a 4 digit number which vary from bank to bank. Some may be using 004a 04a0 4a00 or some other variation of the number.

Thanks Don.