CRA and Proper Loan Coding

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Question:

I recently started a new CRA role for a different bank. The new bank does not use Call Report codes to identify small business/small farm loans. They use class codes and collateral codes. I recently learned for all construction to perm loans originated for more than one year, that they are adjusting the class code to reflect what the class code will be after the construction phrase rather than reporting the loan to what is at the time of origination. Does anyone agree with this approach?

Answer:

"The new bank does not use Call Report codes to identify small business/small farm loans. They use class codes and collateral codes."

Get with your accounting department. There has to be a conversion chart that matches the class and collateral codes to the call reporting categories. No one does this by hand anymore.

If you are questioning your current procedures, get with your external accounting auditors, as they would be attesting to the accuracy of your call reporting and financial statements.