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How can I minimize reporting errors under CRA?

One way to minimize reporting errors is to coordinate with your bank's chief financial offer, or whoever prepares the Call Report. You should be reporting loans defined as "small business loans" in the Call Report. The Call Report is a "static" report, i.e., a snapshot of loans outstanding at a moment in time, while the CRA loan register is a "dynamic" report, i.e., a history of loans made over a period of time. This means you can't reconcile the two reports. Nevertheless, your bank must have a means for tracking and identifying loans to be reported as small business loans in the Call Report. This same system may be used to identify small business loans to be reported under CRA.

Meet with your chief financial officer and discuss this issue with him/her. Although not infallible, coordination of the collection of data for both reports will assure that you and the chief financial officer are classifying and reporting loans consistently. There is nothing more embarrassing than having an examiner question why you have not reported a "small business" loan under CRA that your chief financial officer did report in the small business section of the Call Report.

 

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