#33: The Devil Is in the Details but Don’t Let It Get to Your Data, Too!

The purpose of CRA data collection and maintenance is to enable examiners and the public to evaluate (through issuance of a CRA Performance Evaluation) whether a bank is helping to meet the credit needs of its communities through its small business and small farm loans. Accurate data leads to accurate assessments of fair lending and CRA lending performance. When data errors do occur, not only is the bank subject to reputational risk, but costly remediations and an erosion of consumer confidence may also ensue.Three Common Challenges: • Determining which commercial loan transactions are reportable and/or which ones are not reportable (based on Call Report Schedule RC-C etc.) and then capturing reportable loans data fields accurately.• Correctly identifying community development loans.• Correctly identifying loan types based on size and definition tests.If you are new to the CRA or to data integrity elements of the CRA, start with a review of the call report Schedule RC-C instructions to learn about the common loan definitions that are consistent with the CRA and the FFIEC guide to CRA Data Collection and Reporting. Yes, I know this is a dated publication, but it is still relevant, compliant and a good guide to answer your questions regarding CRA data elements. Quotes• “Make sure that you map out how you extract data through your core systems into your CRA proprietary database that then goes to your loan register. So, you need to look end to end to make sure that you have data integrity.” (03:12-03:29)Want to learn more about the CRA? Sign up for CRA Today’s free course: https://hub.cratoday.com/freecourseLinks• A Guide to CRA Data Collection and Reporting: https://www.ffiec.gov/cra/guide.htm • Call Report Instructions: https://www.fdic.gov/regulations/resources/call/crinst-051/2017/2017-03-051-rc-c2.pdf • CRA Today Website: https://cratoday.com/ For more information on the CRA Hub, a membership for bankers to connect, inspire, and master the art of CRA: https://cratoday.com/hub/ Copyright © 2021 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by HiveCast.fm