Its unusual that the 2016 HMDA Disclosure Report was issued prior to the 2016 CRA Disclosure Report. Any rumblings on when the 2016 CRA Report will be available?

That's the question I have been asking. They normally release the data on or about August 15, but we are nearly 2 months after that date and they have released nothing and have said nothing explaining why the data is so late this year. I can only conjecture there must be a big problem with data integrity in the file.

Just wait until they have to process with the additional data. A Christmas gift?

Hi Len - do you think that this is also the reason CRA Wiz has not published 2016 Peer Small Business Data?

No one has the data. I have inquired with the FRB by e-mail and by phone about the status of the annual data and have not received a response. The normal publication date is August 15, and here we are on the eve of November and still no data and no explanation or announcement about when the file may be released. So today I filed a complaint with the Office of the Inspector General. Hopefully that will precipitate a response and an explanation. This data is the only national database containing CRA-related activity and is critical to understanding bank performance so it is really puzzling why the extraordinarily long delay and the failure to explain the delay and provide information about when the data may be released. Bankers need it. Community activists need it. Examiners need it. The data has been provided for decades and there was no change in the file structure. It makes you wonder what is causing the very long delay and no explanation. Maybe the Russians have hacked the file!!!!!!

The FDIC just issued this press release. https://www.fdic.gov/news/news/press/2017/pr17088.html

The FFIEC CRA site is not yet updated.

I now see that 2016 is available on the pull down menu on this page. https://www.ffiec.gov/craadweb/DisRptMain.aspx

It's there - I would be especially careful about using the data until we can be sure it doesn't have problems. Something highly unusual delayed the release of the data for a very long time. The FFIEC isn't saying much, but I think it owes an explanation for the delay. Maybe they should be assessed CMP's for not filing on a timely basis!

We usually run the files through some edit checks and routines to identify problems. In the last 10 years we discovered at least 3 significant errors and reported them to the FFIEC which acknowledged the mistakes and corrected the first two but never corrected last year's mistakes which were mostly concentrated in Oklahoma.

Well, I can tell you after looking at our bank's DS, I am seeing an error on nearly every page of the Loans by County tables. The error is in the County totals section, if the bank had 2 loans for 25,000, the county total shows 4 loans for 50,000. It is doubling the county totals. I am just starting to review, so there may be others.

We aren't a CRA reporter, but use the aggregate data to compare our internally compiled data to. I just checked our three MSAs and all of them are doubling the tract counts when showing the county totals.

I noticed that as well when looking at our DS.

We've reviewed the "flat files" that contain all the data which we use to create market rank and market share reports. The small business loan data appears to be in order. But, the small farm data has errors in it. We've contacted the FFIEC regarding the errors.

In the meantime, we are making available free statewide market rank and market share reports - one per requesting bank. Just contact me at my private e-mail, LenSuzio@gmail.com.

The FFIEC will be re-releasing corrected disclosure reports. https://www.ffiec.gov/cra/whatsnew.htm

As a service to BOL readers we are making available free Small Business Lending Market Rank and Market Share reports on a state by state basis. Just visit: Small Business Lending Market Rank & Market Share Reports by State

Thanks!