A copy of the public section of your bank's most recent CRA performance evaluation. 0000007523 00000 n (h) CRA Disclosure Statement. 0000003114 00000 n 0000025776 00000 n Assessment Area Review (Live Mapping session). To find out more, please review our privacy policy. (2) Include the geographies in which the bank has its main office, its branches, and its deposit-taking ATMs, as well as the surrounding geographies in which the bank has originated or purchased a substantial portion of its loans (including home mortgage loans, small business and small farm loans, and any other loans the bank chooses, such as those consumer loans on which the bank elects to have its performance assessed). (j) Central data depositories. Banks and regulators have been dealing with similar reporting issues for several years under the Home Mortgage Disclosure Act (HMDA) and have gradually improved their data accuracy. The OCC prepares annually for each bank that reports data pursuant to this section a CRA Disclosure Statement that contains, on a state-by-state basis: (1) For each county (and for each assessment area smaller than a county) with a population of 500,000 persons or fewer in which the bank reported a small business or small farm loan: (i) The number and amount of small business and small farm loans reported as originated or purchased located in low-, moderate-, middle-, and upper-income geographies; (ii) A list grouping each geography according to whether the geography is low-, moderate-, middle-, or upper-income; (iii) A list showing each geography in which the bank reported a small business or small farm loan; and. "*%q6 MbE:)4;{0?c~r8_z`q Ycwu OZ,gE0]U> 3LA0S)dfL]ww7uAXAuAuPAQYpV:+ Examiners will develop a sample of your data to test it for reliability and this testing can lead to questions about your data that can prolong your exam and force you to refile data in some circumstances. A bank may collect and maintain in machine readable form (as prescribed by the OCC) data for consumer loans originated or purchased by the bank for consideration under the lending test. These research-based essays offer insight and analysis focused on advancing an economy where all can thrive. 0000001760 00000 n %PDF-1.6 % A recent OCC advisory letter (98-16) describes common mistakes banks make when recording data. Test the integrity of the data. This list must note any significant differences in services at particular branches. xb```b``e`e`` @160 The bank may charge a reasonable fee not to exceed the cost of copying and mailing (if applicable). (c) Location of public information. et400ut-- (f2)@ Credibility with examiners, as well as community groups that may analyze the data, could be compromised if inaccuracies occur. Place an emphasis on the importance of this data to the overall performance of the institution. If the bank is subject to reporting under part 1003 of this title, the location of each home mortgage loan application, origination, or purchase outside the MSAs in which the bank has a home or branch office (or outside any MSA) in accordance with the requirements of part 1003 of this title.
You can order both guides together for just $800 per year. iJv~Q!_ix1gWz$/uO+?ikgtY^b>zu, hilg*}Ih:cTNfW7/G61i-)JYWmnH/ijn/}eY6\MXW. 0000002170 00000 n The bank shall maintain data separately for each category, including for each loan: (i) A unique number or alpha-numeric symbol that can be used to identify the relevant loan file; (ii) The loan amount at origination or purchase; (iv) The gross annual income of the borrower that the bank considered in making its credit decision. 0000006186 00000 n 85 0 obj <>stream (ii) Within five calendar days of the request, all the information in the public file relating to the assessment area in which the branch is located. A bank shall provide in the public lobby of its main office and each of its branches the appropriate public notice set forth in appendix B of this part. In the case of a small business or small farm, the loan recipient's address is often reported incorrectly. Accountability within the bank is key to clearing up many of these problems.
A bank that elects to have the OCC consider loans by an affiliate, for purposes of the lending or community development test or an approved strategic plan, shall collect, maintain, and report for those loans the data that the bank would have collected, maintained, and reported pursuant to paragraphs (a), (b), and (c) of this section had the loans been originated or purchased by the bank. (3) Small banks. A list of servicesincluding hours of operation, available loan and deposit products, and feesoffered at your bank's branches. I9w0'vkoG0 fE,:7d+Y=My"&lT5F@E.|k2" -mK_zF\1 lue4joG7.%SV1Faiz3^ a," zF0;"000 The assessment area(s) for a bank other than a wholesale or limited purpose bank must: (1) Consist generally of one or more MSAs or metropolitan divisions (using the MSA or metropolitan division boundaries that were in effect as of January 1 of the calendar year in which the delineation is made) or one or more contiguous political subdivisions, such as counties, cities, or towns; and. The assessment area(s) for a wholesale or limited purpose bank must consist generally of one or more MSAs or metropolitan divisions (using the MSA or metropolitan division boundaries that were in effect as of January 1 of the calendar year in which the delineation is made) or one or more contiguous political subdivisions, such as counties, cities, or towns, in which the bank has its main office, branches, and deposit-taking ATMs. Please know that if you continue to browse on our site, you agree to this use. Once an institution has this information available, it should assign census tracts or block numbering areas to the location (geocode) and report it. Bridges is a regular review of regional community and economic development issues. Each bank's assessment area(s): (1) Must consist only of whole geographies; (2) May not reflect illegal discrimination; (3) May not arbitrarily exclude low- or moderate-income geographies, taking into account the bank's size and financial condition; and. The OCC makes the aggregate disclosure statements, described in paragraph (i) of this section, and the individual bank CRA Disclosure Statements, described in paragraph (h) of this section, available to the public at central data depositories.
The CRA regulation's focus on lendingand in particular, lending to low-to-moderate individuals and areasgives the data produced from lending records utmost importance. O5}x>C/&xj5,%WY A bank that received a less than satisfactory rating during its most recent examination shall include in its public file a description of its current efforts to improve its performance in helping to meet the credit needs of its entire community. 0000028126 00000 n This will allow you to make quick corrections and hold responsible those who are making errors. One of the most important documents in your systems and procedures is a complete and reliable data entry guide for CRA and HMDA data. (e) Limitations on the delineation of an assessment area. When it comes to preventing data integrity problems, the stakes are high. CRA regulations say, "The institution should record the loan by either the location of the business headquarters or the location where the greatest portion of the proceeds are applied, as indicated by the borrower." A map of the bank's assessment area showing its boundaries and identifying the various geographic areas within it, either on the map or in a separate list. Structure this ongoing trainingconducted by a compliance officer or auditor who can answer questions on data collection and reportingto the specific needs of your loan processing personnel. Data errors can not only force you to resubmit data. 60 FR 22184, May 4, 1995, unless otherwise noted. In the case of a credit-line increase, many institutions report the total amount of a line of credit instead of the increase alone. The statement contains information about small business and small farm loans and the population's income levels for each county where the bank operates. 0000006920 00000 n endstream endobj 991 0 obj <>/Metadata 109 0 R/OCProperties<>/OCGs[1001 0 R]>>/Outlines 269 0 R/PageLayout/SinglePage/Pages 983 0 R/StructTreeRoot 328 0 R/Type/Catalog>> endobj 992 0 obj <>/ExtGState<>/Font<>/Properties<>/XObject<>>>/Rotate 0/StructParents 0/Type/Page>> endobj 993 0 obj <>stream gY7M5yJM>ggwb_-;:}8Op If a bank serves a geographic area that extends substantially beyond an MSA boundary, the bank shall delineate separate assessment areas for the areas inside and outside the MSA. The OCC, in conjunction with the Board of Governors of the Federal Reserve System and the Federal Deposit Insurance Corporation, prepares annually, for each MSA or metropolitan division (including an MSA or metropolitan division that crosses a state boundary) and the nonmetropolitan portion of each state, an aggregate disclosure statement of small business and small farm lending by all institutions subject to reporting under this part or parts 195, 228, or 345 of this title. '~iY ,|a6J#3&5giu)H7XS0/0[`P\GkiCl(00EmxM/.y This means you have a guide that has been prepared professionally and is automatically updated as changes occur. Geocoding. (b) Loan information required to be reported. ! o Your bank must place the copy in its public files within 30 business days after receiving it. A copy of your bank's strategic plan if the bank is evaluated by one. A bank shall include the last sentence of the notices only if it is an affiliate of a holding company that is not prevented by statute from acquiring additional banks.
Train loan operations staff in-depth on what constitutes a HMDA or CRA reportable loan. A bank shall delineate one or more assessment areas within which the OCC evaluates the bank's record of helping to meet the credit needs of its community. For each geography in which the bank originated or purchased a small business or small farm loan, the aggregate number and amount of loans: (i) With an amount at origination of $100,000 or less; (ii) With amount at origination of more than $100,000 but less than or equal to $250,000; (iii) With an amount at origination of more than $250,000; and. For banks other than small banks, information on your bank's consumer loans or any affiliates' consumer loans for the previous two years. 0000021233 00000 n The OCC publishes at least 30 days in advance of the beginning of each calendar quarter a list of banks scheduled for CRA examinations in that quarter. A bank that has been approved to be assessed under a strategic plan shall include in its public file a copy of that plan. At its option, a bank may provide other information concerning its lending performance, including additional loan distribution data. For home mortgage loans, the bank shall also be prepared to identify the home mortgage loans reported under part 1003 of this title by the affiliate. In fact, some institutions have spent upwards of a million dollars cleaning up their HMDA data. (a) In general. 54 32
(3) Home mortgage loans. Learn more about the Econ Lowdown Teacher Portal and watch a tutorial on how to use our online learning resources. An adjustment is particularly appropriate in the case of an assessment area that otherwise would be extremely large, of unusual configuration, or divided by significant geographic barriers. (c) Optional data collection and maintenance(1) Consumer loans. Ultimately, the potential for errors is large, and data integrity issues will persist unless bank management gives proper attention to the problem and takes corrective action. 0000030588 00000 n (d) Data on affiliate lending. A bank that elects to have the OCC consider community development loans by a consortium or third party, for purposes of the lending or community development tests or an approved strategic plan, shall report for those loans the data that the bank would have reported under paragraph (b)(2) of this section had the loans been originated or purchased by the bank. In addition, a bank that elected to have the OCC consider the mortgage lending of an affiliate shall include in its public file the name of the affiliate and a written notice that the affiliate's HMDA Disclosure Statement may be obtained at the Bureau's Web site. The bank shall place the written notice(s) in the public file within three business days after receiving notification from the Federal Financial Institutions Examination Council of the availability of the disclosure statement(s).
AA40,\ 0IIII,E s 0000005111 00000 n A small bank or a bank that was a small bank during the prior calendar year shall include in its public file: (i) The bank's loan-to-deposit ratio for each quarter of the prior calendar year and, at its option, additional data on its loan-to-deposit ratio; and. 0000010172 00000 n <<1897CF794E0E0E4E829A23AD6D46F015>]>> (iv) The number and amount of small business and small farm loans to businesses and farms with gross annual revenues of $1 million or less; (2) For each county (and for each assessment area smaller than a county) with a population in excess of 500,000 persons in which the bank reported a small business or small farm loan: (i) The number and amount of small business and small farm loans reported as originated or purchased located in geographies with median income relative to the area median income of less than 10 percent, 10 or more but less than 20 percent, 20 or more but less than 30 percent, 30 or more but less than 40 percent, 40 or more but less than 50 percent, 50 or more but less than 60 percent, 60 or more but less than 70 percent, 70 or more but less than 80 percent, 80 or more but less than 90 percent, 90 or more but less than 100 percent, 100 or more but less than 110 percent, 110 or more but less than 120 percent, and 120 percent or more; (ii) A list grouping each geography in the county or assessment area according to whether the median income in the geography relative to the area median income is less than 10 percent, 10 or more but less than 20 percent, 20 or more but less than 30 percent, 30 or more but less than 40 percent, 40 or more but less than 50 percent, 50 or more but less than 60 percent, 60 or more but less than 70 percent, 70 or more but less than 80 percent, 80 or more but less than 90 percent, 90 or more but less than 100 percent, 100 or more but less than 110 percent, 110 or more but less than 120 percent, and 120 percent or more; (3) The number and amount of small business and small farm loans located inside each assessment area reported by the bank and the number and amount of small business and small farm loans located outside the assessment area(s) reported by the bank; and. 4. gYpV:+ Reporting the renewal of a small-business loan as an origination. Examiners know this and they frequently have found problems with the HMDA and CRA data provided to them by banks. (e) Updating. All loans should have addresses that can be geocoded to indicate the location (i.e., the census tract or block numbering area) of the loan. Track the flow of the data. Your bank must maintain a public file, updated as of April 1 each year, that includes the following information: Make a difference with a job at the nation's central bank. If the bank maintains data for loans in a certain category, it shall maintain data for all loans originated or purchased within that category. Depending on the severity of the problem, test at least quarterly, if not more often. 0000000936 00000 n A bank may maintain data for one or more of the following categories of consumer loans: motor vehicle, credit card, other secured, and other unsecured. +no5'BgrmS%PDlCXQijtiO|m&8l~l. Answers on everything from accountability to the Feds role, Regular review of community and economic development issues, Podcast about advancing a more inclusive and equitable economy, Interesting graphs using data from our free economic database. (4) The number and amount of community development loans reported as originated or purchased. 0000003656 00000 n For a large bank, its CRA disclosure statement, prepared every year by its regulator. 0000005648 00000 n 0000001502 00000 n
Conversations with experts on their research and topics in the news, Podcast featuring economists and others making their marks in the field, Economic history from our digital library, Scholarly research on monetary policy, macroeconomics, and more. We use cookies on our website to give you the best online experience. A bank required to report home mortgage loan data pursuant part 1003 of this title shall include in its public file a written notice that the institution's HMDA Disclosure Statement may be obtained on the Consumer Financial Protection Bureau's (Bureau's) Web site at www.consumerfinance.gov/hmda. Except as otherwise provided in this section, a bank shall ensure that the information required by this section is current as of April 1 of each year. H\0~ (f) Small banks electing evaluation under the lending, investment, and service tests. The OCC uses the assessment area(s) delineated by a bank in its evaluation of the bank's CRA performance unless the OCC determines that the assessment area(s) do not comply with the requirements of this section. 0000030314 00000 n Call our corporate office and we will connect you with a team member who can help. For banks required to report Home Mortgage Disclosure Act (HMDA) data, a written notice about the HMDA disclosure statement. 0000027839 00000 n Human error, especially keystroking mistakes. endstream endobj 55 0 obj <>/Metadata 52 0 R/AcroForm 56 0 R/Pages 48 0 R/Type/Catalog/PageLabels 46 0 R>> endobj 56 0 obj <>/Encoding<>>>>> endobj 57 0 obj <>/ColorSpace<>/Font<>/ProcSet[/PDF/Text/ImageB]/ExtGState<>>>/Type/Page>> endobj 58 0 obj <> endobj 59 0 obj [/ICCBased 74 0 R] endobj 60 0 obj <> endobj 61 0 obj <> endobj 62 0 obj <>stream Often, the lender will record a home address of the small-business borrower or another location, which is neither where the headquarters are located nor where the proceeds of the loan will be used. The aggregate number and aggregate amount of community development loans originated or purchased; and. (a) Loan information required to be collected and maintained. (2) Banks required to report Home Mortgage Disclosure Act (HMDA) data. Data integrity is one of the big issues with respect to HMDA and CRA today. They include: 1. For the current year and two previous years, all written comments from the public about how your bank is helping meet community credit needs. endstream endobj 63 0 obj <>stream (2) Other loan data. A bank, except a small bank, shall collect, and maintain in machine readable form (as prescribed by the OCC) until the completion of its next CRA examination, the following data for each small business or small farm loan originated or purchased by the bank: (1) A unique number or alpha-numeric symbol that can be used to identify the relevant loan file; (4) An indicator whether the loan was to a business or farm with gross annual revenues of $1 million or less. GeoDataVision has developed guides for the records reported under each regulation and offers the guides as a subscription to community banks. An HMDA disclosure statement of any affiliate mortgage lending considered under the lending test for the previous two years. A bank may adjust the boundaries of its assessment area(s) to include only the portion of a political subdivision that it reasonably can be expected to serve. (5) Banks with less than satisfactory ratings. In the case of HMDA data it can lead to civil and monetary penalties. (i) Aggregate disclosure statements. You can always block or disable cookies using your browser settings. 2. Borrowers' addresses in rural areas frequently consist of only rural route numbers or post office boxes. xref (c) Geographic area(s) for other banks. A bank, except a small bank or a bank that was a small bank during the prior calendar year, shall report annually by March 1 to the OCC in machine readable form (as prescribed by the OCC) the following data for the prior calendar year: (1) Small business and small farm loan data. The Q&As do give an exception to this "if the institution cannot determine the borrower's street address and does not know the census tract or block numbering area." 0000016770 00000 n In reviewing a bank's performance under the CRA regulation, the examiners primary tool is the data reported on the loan application register for HMDA and the loan register for CRA.
0000001635 00000 n Large banks are facing a new but familiar challengeensuring clean and accurate data reportingas they adjust to revisions in the Community Reinvestment Act (CRA), which includes the collection of small business and small farm data. (g) Use of assessment area(s). yum A bank shall maintain a public file that includes the following information: (1) All written comments received from the public for the current year and each of the prior two calendar years that specifically relate to the bank's performance in helping to meet community credit needs, and any response to the comments by the bank, if neither the comments nor the responses contain statements that reflect adversely on the good name or reputation of any persons other than the bank or publication of which would violate specific provisions of law; (2) A copy of the public section of the bank's most recent CRA Performance Evaluation prepared by the OCC. Prefer speaking with a human to filling out a form? 0000007170 00000 n A bank shall make available to the public for inspection upon request and at no cost the information required in this section as follows: (1) At the main office and, if an interstate bank, at one branch office in each state, all information in the public file; and, (i) A copy of the public section of the bank's most recent CRA Performance Evaluation and a list of services provided by the branch; and. (g) Assessment area data. (4) Banks with strategic plans. Notwithstanding the requirements of this section, a bank whose business predominantly consists of serving the needs of military personnel or their dependents who are not located within a defined geographic area may delineate its entire deposit customer base as its assessment area.
Ensuring your institution's data is clean will prevent you from spending unnecessary time and money "scrubbing" HMDA and CRA data before submission. 0000006299 00000 n However, testing the integrity of HMDA and CRA data is still at the forefront of compliance examination concerns for large banks. /g#~H)HYGM E>>T*!K{_i-tyMQ~Svv6Y|_~%dB0f?.6Mc{A_k{6K^}|?,82=_y[1~{JN;m0uHoKr ^W\,`%+VX-Urx'x3^)d The bank shall place this copy in the public file within 30 business days after its receipt from the OCC; (3) A list of the bank's branches, their street addresses, and geographies; (4) A list of branches opened or closed by the bank during the current year and each of the prior two calendar years, their street addresses, and geographies; (5) A list of services (including hours of operation, available loan and deposit products, and transaction fees) generally offered at the bank's branches and descriptions of material differences in the availability or cost of services at particular branches, if any. (f) Banks serving military personnel. Advancing Careers for Low-Income Families, Center for Financial Innovation and Stability (CenFIS), Center for Quantitative Economic Research (CQER), Center for Workforce and Economic Opportunity, Community Development at the Federal Reserve, Southeastern Rental Affordability Tracker, Mortgage Analytics and Performance Dashboard, Renter Households Vulnerable to COVID-19 by Region, Better Employment and Training Strategies, Funding and Financing Workforce Development, Looking at Your Bank's CRA PerformanceThe Big Picture, Standards Used to Evaluate Your Bank's CRA Performance, What Your Bank's Public CRA File Must Show, Where You Can Find Your Bank's CRA Public File, How You Can Comment on Your Bank's CRA Performance. 0000018001 00000 n Keep a log of who is keying in the data, making the determination of whether the loan is HMDA- or CRA-reportable, and creating the loan registers.
During testing, make sure your employees scrutinize the files as closely as your regulatory agency does.