Although new Community Reinvestment Act rules took effect Monday, many bankers still don't know what examiners will demand.
To clear up the confusion, the Federal Financial Institutions Examination Council last week released 10 pages of answers to frequently asked questions about CRA compliance.
Paul Sachtleben, director of the Federal Deposit Insurance Corp.'s division of compliance and consumer affairs, said the list covers both technical matters and more general questions from bankers.
"Any new data collection system is going to have various issues that need to be clarified," Mr. Sachtleben said. "Hopefully, this will do that."
Jim McLaughlin, director of agency relations with the American Bankers Association, said the list was definitely needed and "gave a lot of helpful information."
Questions and answers were broken down into six categories.
Small-business loan data collection and reporting:
*Maintain an identifying number or letter for the file, the amount of the loan at origination, the location of the loan, and whether the loan was to a business with gross annual revenues of less than $1 million.
*Report the number and amount of loans under $100,000, between $100,000 and $250,000, and between $250,000 and $1 million. Also, institutions have to provide the number and amount of loans to businesses with gross annual revenues under $1 million.
*Determine the size of a business using the revenues the bank considered in making its credit decision.
*When determining which address to record for a specific loan, use either the headquarters or the site generating the most profits.
*Banks may opt to report data on loans, purchases, and lines of credit secured by residential real estate to small businesses, but it is not required.
General reporting questions:
*A bank must collect this data unless it has less than $250 million in assets at the end of either of the past two calendar years. The data must be reported for the first time on March 1, 1997.
*If two small banks merge, they must begin reporting after the combined bank has two straight yearend asset totals exceeding $250 million.
*In a merger of a small and a large bank, the large bank must report its data, but filing is optional for the small bank the year the deal is completed.
*In a merger of two large banks, the surviving bank can either file consolidated reports or separate ones. But for each following year, banks should consolidate the reports.
*If no small-business loans are made, a bank should submit a transmittal sheet and a definition of its assessment area.
*Small, exempted banks may receive a copy of the collection software by mailing a request to CRA Processing, Federal Reserve System, 1709 New York Ave. NW, 5th Floor, Washington, D.C., 20006.
General lending questions:
*Collect and report information on loan refinancings, but not renewals.
*Do not keep data on loan commitments or letters of credit.
*Report line-of-credit data at the time of origination or increase, and in the same manner loan origination data is provided.
Small-farm loan data collection and reporting:
*Differentiate farm loans from business loans.
*Report loans to the fishing industry as small-farm loans.
Community development loan data:
*Report the total number and amount of community development loans originated and purchased in the prior calendar year.
*Do not report a community development loan if it can also be defined as a home mortgage, small-business, or small-farm loan. However, a multifamily affordable housing loan that can be reported as a home mortgage loan under the Home Mortgage Disclosure Act may also be reported as a community development loan.
Consumer loan data:
*Banks may collect and maintain data on car loans, credit cards, home equity lines, and other secured or unsecured consumer lending, but it is not required.