Data Collection/Reporting

Hey all!

When you gather data to report for CRA, do you nearly exclusively use call report codes 1e1, 1e2, and 4 for small business and 1b and 3 for small farm?

I think we may have gotten too complicated in how we gather what loans to report. Unless it is a community development loan, it would have to be one of those 5 call report codes, correct?

In other words, all CRA Loan type 1 - Small Business loans MUST have a call report code of either 1E1, 1E2, or 4 as the call report defines them. (assuming the original loan amount is $1MM or less, of course) Am I thinking through this correctly?

Any ideas on how you collect that data is also welcome

Since we are getting close to having to report, I'm interested in this as well.

You may very well have an over-complicated process, but without knowing how accurate your call report process is, I would hesitate to say "yeah - just go with those call codes."

Having said that, if you start with the definition in the Regulation, 12 CFR 228.12(v), it's pretty clear you need to start with the Call Report instructions and determine which loans meet the definition.
- (v) Small business loan means a loan included in “loans to small businesses” as defined in the instructions for preparation of the Consolidated Report of Condition and Income.
- (w) Small farm loan means a loan included in “loans to small farms” as defined in the instructions for preparation of the Consolidated Report of Condition and Income.

As you indicated, the current Call Report instructions will direct you to the call report codes you have identified for the loans that must be reported. Now, if your Call Report process has some holes, then you will need a more complicated process to find the loans that should:
1. Be reported on the CRA LR, and
2. Have the Call Report code corrected in your system of record.

I agree with PR. I "just go with those call codes" but am also brainstorming ideas for queries to attempt to identify any loans that were incorrectly call coded and should have been reported. Kind of the old audit philosophy of "trust, but verify".

This helps so much. Thank you for your input! The call report codes can be somewhat complicated when selecting one for a loan, so I should probably find out how those codes are being chosen to, hopefully, gain comfort in that process. Thanks again!

So, as an example... lol

A loan is secured by Farmland and call report coded as 1b. However, the purpose of the loan is to purchase real commercial real estate. And the borrower is a commercial business. This would still be considered a small farm loan since the call report code is 1b - secured by farmland and the amount is less than $500K?

It's a hypothetical and may never happen, but I wanted to make sure that I'm thinking this through properly....