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#885169 - 01/10/08 03:13 PM CRA Submission
OneDayAt a Time Offline
New Poster
Joined: Jan 2007
Posts: 12
First time doing submission- question, I have decided to outsource the banks data,I have reviewed all data to make sure it's error free, when I oustsource the files do I provide all files in and out of our AA, or do I provide only the files within our AA.

HELP!!!

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CRA
#885443 - 01/10/08 06:07 PM Re: CRA Submission OneDayAt a Time
Len S Offline
Diamond Poster
Joined: Oct 2004
Posts: 2,090
Connecticut
You should provide all loan records pertinent to CRA whether inside or outside your AA.

There are some very inexpensive software programs that will edit check and prepare your data for submission. Why are you going to outsource?
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#893696 - 01/25/08 03:52 PM Re: CRA Submission Len S
dollars & sense Offline
Gold Star
Joined: Oct 2006
Posts: 344
I am also a first time submitter. Any help on the steps to take and what to do????

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#893792 - 01/25/08 04:58 PM Re: CRA Submission dollars & sense
Len S Offline
Diamond Poster
Joined: Oct 2004
Posts: 2,090
Connecticut
(1) Use either the FFIEC CRA software (for free) or get a good software program (cost about $1K/yr).
(2) The next step is to identify your CRA-reportable small business loans. Since your bank must assign Call Report codes for these loans talk to the Department responsible for the Call Report codes and find out what loans they are identifying as small business or small farm. That is not infallible (since that department can make mistakes), but a good start.
(3) Once you have identified the reportable transactions, get the required information (GAR, geocoded addresses, etc) and enter it into the software.
(4) Run edit checks on the data entered into the software (edit checks are in FFIEC software and/or good CRA software) and
(5) correct any errors identified.
(6) Submit data electronically using your CRA software.
(7) Say a prayer!!!
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CRA Exam Preparation, CRA Performance Evaluations, Key Performance Benchmarks, & maps

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#893888 - 01/25/08 06:02 PM Re: CRA Submission Len S
Don_Narup Offline

Power Poster
Joined: Jul 2001
Posts: 3,708
Las Vegas Nevada
If you have not been entering loan data during the year and are just now only going to take loans someone else has assigned a CRA Small Business and Small Farm Fed Call code to, then you had better start a scrub of the files to see that they actually qualify as such. Do not take it for granted that they do.

The next thing is make sure you have the correct address to geocode,and the revenue codes are correct.

If you report loans incorrectly then in an exam regulators will make you scrub and refile your data.

If you are just now going to enter data manually in the FFIEC Data Collection software then you should pull the files to make sure the data entered is correct.

One of the larger errors is reporting loans secured by Residential RE as a Small Business loan because a loan officer calls it an abundance of caution. Lots of posts about this on BOL do a search.

You may have other loans that have NOT been coded with a reportable Fed Call code that qualify for reporting purposes. If you have not tracked any of this during the year then you have a large task ahead of you.

As far as error checking, in the FFIEC software as you enter an individual loan if there is an error it will show and must be corrected before the program accepts the loan being entered.

If you import data the run the Batch Edit and then the individual error reports for the Small Farm and Business loans

You need to know the TOTAL number and dollar amount of all Community Development activities. Those totals must be entered in the CD page. Only totals are entered individual loan information is not
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