We have just this year become a "large" bank for CRA reporting purposes. What do the regulators (the OCC specifically) look for in terms of reporting income data on loans made to bank employees. We do not have that many loans to employees but if we segregate them it could potentially distort our statistics about lending volume and dollars in the four income categories. What do other banks do for this issue? Thanks.

We are a "Large Bank" for CRA reporting purposes. We are also regulated by the OCC. We report all employee incomes as NA for CRA and HMDA reporting purposes.

Since I'm sure all your co-workers (that is, the ones not in Compliance) are well paid, they would be middle- or upper-income anyway and would not distort your numbers.

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Al Miller, CRCM
Fremont Bank (CA)
(510) 790-5825
(510) 505-5211 FAX

Opinions expressed are my own and not necessarily shared by my employer.

From one fellow sufferer to another: welcome to the world of large bank CRA reporting. Oh what fun you're going to have! Believe me when I say that employee loans will be only the beginning of your headaches. Good luck.

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The opinions expressed are mine and not those of my employer

One thing to remember as far as CRA reporting goes - You only report SMALL BUSINESS and SMALL FARM loans with respect to individual loan information, and an aggregate number of Community Development and Consortia loans.

Most likely, you will not REPORT your employee loans for CRA. Now if your bank does a significant amount of consumer lending, and you either WANT the examiners to consider your consumer lending or you are required to have your consumer lending evaluated for CRA, then you will COLLECT information on all consumer loans (including employees) and keep the information on-hand for the examiners to look at.

One further item on collecting data for consumer loans - you only need to collect the data for the consumer loan type that makes up a substantial amount of your lending activitity. For instance, if you have a large automobile loan portfolio, but don't do much in the way of home equity loans, you would only need to collect the auto loan information. You would not need to collect the equity loan information (except for whatever you need to collect for HMDA.)

And the other posters are correct - Hold on tight because it's a wild ride from here on out!

[This message has been edited by Bonnie M (edited 07-31-2001).]

Bonnie M is exactly correct with her advice. Basically use the HMDA rule for dealing with employee income information. I was with a large bank and went through an examination. Since we were involved in mainly consumer lending I found the hardest part to be the Investment Test. Also remember, the examiners will take your HMDA data and your Small Business data. Make sure these are correct! It is scary but you WILL survive.