Electronic Loan, Deposit, and Investment Data Collection

Federal RegisterOct 31, 2017

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NATIONAL CREDIT UNION ADMINISTRATION

Electronic Loan, Deposit, and Investment Data Collection

AGENCY:

National Credit Union Administration (NCUA).

ACTION:

Request for Information (RFI)

SUMMARY:

The National Credit Union Administration is conducting a comprehensive review of the loan, deposit, and investment information collected electronically during examinations of federally insured credit unions from the core data processing and offline systems used by credit unions.

DATES:

Comments must be received on or before January 2, 2018.

ADDRESSES:

Comments may be submitted using

one

of the methods below (Please do not send comments via multiple methods). Include [Your name and company name (if any)]—Electronic Data Collection Modernization in all correspondence.

•

Email:

Address to

BIMail@NCUA.gov.

Include “[Your name] Comments on Electronic Data Collection Modernization” in the email subject line. Any of the following formats is acceptable: HTML, ASCII, Word, RTF, or PDF.

•

Mail:

Please direct written comments to Amber Gravius, National Credit Union Administration, 1775 Duke Street, Alexandria, Virginia 22314.

NCUA will post all comments received by the deadline on the agency Web site (

www.ncua.gov

) without alteration or redaction, so commenters should not include information they do not wish public (

e.g.,

personal or confidential business information). SPAM or marketing materials will be discarded without publication.

FOR FURTHER INFORMATION CONTACT:

Kelly Lay, Business Innovation Director or Amber Gravius, Special Assistant for Business Innovation, Office of the Executive Director, at 1775 Duke Street, Alexandria, VA 22314 or telephone (703) 518-6313 (Ms. Lay) or (703) 548-2411 (Ms. Gravius). Media inquiries should be directed to the NCUA Office of Public and Congressional Affairs at (703) 518-6671 or

pacamail@ncua.gov.

SUPPLEMENTARY INFORMATION:

The National Credit Union Administration (NCUA) is conducting a comprehensive review of the loan, deposit, and investment information collected electronically during examinations of federally insured credit unions (FICUs). The overarching goal is to modernize, formalize, and standardize data formats collected during examinations from the core data processing and offline systems

used by credit unions. The purpose of this modernization effort is to:

Offline systems is defined as other IT systems not connected or linked to the core data processing system or third party vendors with loan, deposit, and investment data. These may include, but are not limited to, credit cards, mortgage loans, student loans, indirect loans, etc.

a. Achieve a more consistent examination process;

b. Promote agency efficiencies and reduce burden on credit unions;

c. Reduce onsite time by streamlining agency efforts to sort, organize, and format data;

d. Improve data reliability and quality to enable more offsite work;

e. Enhance the objectivity of examination conclusions with a more thorough and advanced portfolio analysis; and

f. Support the Exam Flexibility Initiative's

longer examination cycle, consistency between examiners, better communication, more efficient examination planning process, and better offsite monitoring tools.

https://www.ncua.gov/About/Documents/exam-flexibility/exam-flexibility-initiative-report-2016-oct.pdf

This RFI is a major step in NCUA's internal modernization efforts. After considerable research and analysis, the agency is now at a point where it can outline the scope of its planned improvements. In turn, NCUA seeks the views of the public on this initiative and is eager to gain input from interested stakeholders on a number of aspects related to the future data collection by NCUA. Specifically, this RFI explains NCUA's objectives and seeks insights from stakeholders in identifying the interrelated considerations and challenges that could arise if NCUA adopts a new standardized data format for loan, deposit, and investment data.

NCUA will use information furnished by stakeholders to help further define data fields to collect electronically, develop a standard data format (including field names and definitions), and comprise an implementation strategy that reduces burden without compromising the agency's ability to safeguard the National Credit Union Share Insurance Fund (NCUSIF).

A standard data format will not replace or eliminate all examiner data requests occurring during an examination. NCUA encourages responders to recommend other data sources that NCUA could standardize to improve exam efficiency.

Separate and apart from the normal examination data download process, FICUs with assets greater than $10B must comply with 12 CFR 702, subpart E which implements capital planning and stress testing.

The information collected as part of this process is not the focus of this RFI as it differs significantly in timing, purpose, and content.

Implemented in 2014, NCUA's Office of National Examination and Supervision (ONES) collects detailed loan level data and select share data to run stress test scenarios and loan portfolio analytics for supervisory purpose. Currently, these credit unions send monthly data to NCUA on a quarterly basis using standard templates with 191 unique data fields relevant to each data type including automobile, credit cards, student, real estate, member business loans, and other consumer loans. The sample formats in this RFI include 53 similar fields to those collected by ONES.

In addition to this RFI, the agency may seek clearance from the Office of Management and Budget to conduct stakeholder calls and form workgroups to gather additional information about barriers and benefits to this modernization initiative. NCUA invites interested parties to respond generally to this modernization initiative and specifically to the questions included in this RFI.

I. Background

Examiners obtain electronic data at the beginning of every examination, during some supervision contacts, and on an ad hoc basis from credit unions. This raw data, sometimes from multiple sources and in multiple data files, provides examiners with essential information in evaluating credit and deposit risks in FICUs and is integral to risk supervision which is central to safeguarding the integrity of the NCUSIF. Before 1995, this data was in written format. In 1995, NCUA initiated the first electronic data collection

encouraging FICUs to provide member data to examiners through standard download routines made available by their information processing vendor or written in-house instead of paper listings and reports. In this letter, NCUA requested 12 member profile, 24 loan and 4 share fields electronically for each member record.

NCUA Letter to Credit Unions Number 179, (September 1995).

The download file for both loans and shares include the 12 member profile fields.

In November 2000, NCUA encouraged adherence to the share and loan data record layout specifications to facilitate the import functions into NCUA's examination software, Automated Integrated Regulatory Examination System (AIRES).

NCUA did not increase the electronic data fields or modify the data format with this communication.

NCUA Letter to Credit Unions 00-CU-09 (November 2000).

NCUA last changed the loan and share download in April 2003.

Beginning June 30, 2003, the member profile fields were consolidated and one new field was added for a total of eight fields.

The unique loan fields increased by eight and the unique share fields increased by nine to total 39 loan and 20 share data fields in the electronic download. Although NCUA did not make electronic data collection a requirement, NCUA did identify fields as “critical” and “optional.” NCUA requested FICUs provide all critical fields for successful import and use in the examination process. The letter identifies 15 critical fields in the share file and 25 critical fields in the loan file.

NCUA Letter to Credit Unions 03-CU-05 (April 2003).

NCUA combined the member name, first name, last name, and middle initial into one field. Additionally, the zip code fields were consolidated and social security number was added to the share download resulting in the number of unique member profile fields to decline from 12 to 8. The member profile fields are currently included in each loan and each share download.

In 2009, NCUA informed federal credit unions (FCUs) of the membership data collection and information extracted from the electronic loan and share download gathered during examinations.

NCUA did not increase the electronic data fields or modify the data format with this communication.

NCUA Letter to Federal Credit Unions 09-FCU-03 (January 2009).

II. Reason for Modernization Initiative

The credit union industry is dynamic, with FICUs growing larger and more complex each year. NCUA must ensure its data collection vehicles evolve with industry practices and examination/supervision procedures so:

a. All material FICU risk exposures are captured;

b. data offering little insight into these exposures are no longer solicited; and

c. the reporting burden on supervised institutions—particularly small or non-complex credit unions—is minimized.

Increasing industry complexity, a desire for more effective offsite supervision, and evolving technologies necessitated a review of the current process in favor of opportunities to improve efficiencies and reduce the examination burden on credit unions. Table 1 illustrates the evolution of the FICU industry since NCUA last changed the electronic data collection in April 2003. Although the number of institutions has declined, FICUs continue to grow in assets, loans, shares, membership, and complexity.

Table 1—FICU Trends Since the Last Change in Electronic Data Collection

12/31/2003

3/31/2017

Change (%)

FICUs

9,369

5,737

(63.33)

Total Assets

$610.16B

$1.34T

119.62

Total Loans

$376.11B

$884.58B

135.20

Consumer Loans

$187.53B

$390.07B

108.00

Credit Card Loans

$21.84B

$51.59B

136.21

Indirect Loans

Not collected

$172.56B

Not available

Participation Loans

$4.5B

$29.97B

566.00

Real Estate Loans

$168.26B

$438.93B

160.86

Commercial/MBL

$9.32B

$68.89B

639.16

Student Loans

Not collected

$3.99B

Not available

Total Shares

$528.34B

$1.13T

113.88

Average Assets

$65.10M

$233.0M

257.91

Median Assets

$10.55M

$29.97M

184.08

# Loans

40.92M

61.01M

49.10

# Shares Accounts

142.34M

204.44M

43.63

Today, examiners

frequently request additional reports and data electronically during examinations above and beyond the loan and share download including, but not limited to: Investment data, credit cards, indirect loans, participation loans, and commercial/member business loans. These requests are compelled by increased complexity, more services, and extensive loan products offered to credit union members. These requests may be made before an examination begins or throughout the process. As NCUA has not defined a standard data

structure and fields for different loan types,

the characteristics of data presented in these files often differs from credit union to credit union and vendor to vendor. The unique formats can result in credit union resources to produce and explain their individual reports to examiners. This also creates examination inefficiencies for credit unions and examiners as the reports may not contain all information requested by the examiner and additional information requests may be made. Further, data limitations and inconsistency results in disparate evaluations of risk at different credit unions and across all FICUs.

Includes unsecured loans, lines of credit, vehicle loans, short-term, small dollar amount loans, and leases receivable. This number may include some overlap with indirect, participation, and commercial/MBLs based on categories of reporting on the 5300 Call Report.

The December 31, 2003 5300 Call Report only collected Indirect Loans Granted Year-To-Date. NCUA first started collecting total outstanding indirect loans with the March 31, 2014 Call Report. Credit unions reported a total of $97.35B indirect loans as of March 31, 2014. Since that initial reporting, indirect loans have increased 77.3%.

Total real estate loans includes commercial/MBLs secured by real estate.

Non-federally guaranteed student loans as reported on the 5300 Call Report. NCUA first started collecting this information with the March 31, 2014 Call Report. Credit unions reported a total of $2.84B non-federally guaranteed student loans as of March 31, 2014. Since that initial reporting, these loans have increased 40.49%.

Most credit unions must obtain reports from other systems and third party vendors for real estate, commercial/member business loans, student loans, credit cards, participation, and indirect loans. Examiners primarily receive consumer and real estate loan information in the current loan and share download limited to the data fields defined in NCUA Letter to Credit Unions 03-CU-05.

As part of the broader enterprise modernization effort, NCUA desires to improve loan and deposit portfolio analytics used during FICU examinations to provide for more consistent analysis of risk within and across institutions to mitigate losses to the NCUSIF. Data standardization is paramount to effectively use more robust analytic tools and will also benefit credit unions outside of the examination context, as credit unions have been known to use the download when two credit unions are merging to transfer records. It has also been used with some third party vendors for analytics, reporting, and data processing conversions.

NCUA acknowledges there are challenges with a standard data format. Credit unions use dozens of data processing systems and third party vendors for originating, recording, and monitoring loans, deposits, and investments. Additionally, there are many variations and platforms, including credit union developed information technology systems, with varying data content and formats. Responses to the questions in this RFI will inform NCUA of the extent to which FICUs can provide data electronically in a standard format and identify data fields available for electronic collection. Additionally, NCUA welcomes suggested implementation strategies that reduce burden without compromising the agency's ability to safeguard the NCUSIF.

III. Information Security

NCUA exercises great care in protecting sensitive and personally identifiable information. As a federal agency, NCUA must comply with mandatory security standards for federal information and information systems

and must meet these minimum information security requirements by using security and privacy controls recommended by the National Institute of Standards and Technology (NIST).

In addition to NIST standards and guidelines, NCUA is subject to federal statutes such as the Federal Information Security Modernization Act (FISMA) of 2014, the E-Government Act of 2002, the Privacy Act of 1974 and various OMB policies and guidance concerning federal information management, FISMA reporting, and privacy.

FIPS Publication 199,

Standards for Security Categorization of Federal Information and Information Systems;

FIPS Publication 200,

Minimum Security Requirements for Federal Information and Information Systems.

NIST Special Publication 800-53 (Rev. 4),

Security and Privacy Controls for Federal Information Systems and Organizations.

NCUA uses administrative, technical, and physical controls, including but not limited to: Periodic review and authorization of information systems; proactive threat assessment and continuous monitoring; and annual general and role-based security training for employees and contractors. We also leverage independent tests and evaluations from other government agencies and third-party assessors.

The Office of the Inspector General (OIG) conducts independent audits, investigations and other activities to verify NCUA's compliance with applicable standards, laws and regulations related to privacy and information security and keeps the NCUA Board and U.S. Congress fully and currently informed of their work. The OIG conducts a FISMA and Federal Managers' Financial Integrity Act (FMFIA) audit annually to ensure NCUA has effectively implemented all appropriate security and privacy controls.

The results of these audits are reported both internally and externally to ensure completion of all remedial findings. Credit Unions and their members can review OIG Audit Reports, Semiannual Reports and Letter to Congress at

https://www.ncua.gov/About/Pages/inspector-general/reports.aspx.

Request for Comment:

NCUA is providing questions about major aspects of this electronic data modernization to target issues the public would like addressed by the effort. The questions are not intended to limit discussion. Indeed, responders may explore an issue relevant to this initiative.

Responses containing references to studies, research, or data not widely available to the public should include copies of referenced materials. A description of the commenter's organization and its interest in the electronic data will help NCUA use the input provided.

a. Electronic Data Collection Modernization Questions

1. To the extent an FICU offers the loan and deposit services and has the investment instruments identified in the section b, are there any example data fields listed in this RFI that cannot be reasonably provided electronically? What other data fields could be provided that NCUA should consider collecting electronically?

2. For electronic data, what file formats (

e.g.,

Microsoft Excel, CSV, etc.) are available?

3. If a FICU cannot provide data electronically, to what extent is the limitation due to the IT systems (

e.g.,

the field is not available in the IT system to be captured electronically)? To what extent is the limitation because a credit union is not electronically collecting the data now (

e.g.,

loan underwriting information captured in the loan file, such as a calculated debt to income ratio, but is not stored in an IT system that can capture that data)?

4. What is the number of vendors, systems, or service providers the FICU uses for loans (all types), deposits, and investments you currently can or would extract data for examination purposes? Specifically, how many are used for each category (

e.g.,

loans, deposits, and investments)?

5. To what extent does the FICU rely on a third party vendor to create and produce raw data downloads? Does the vendor provide the credit union with the flexibility to self-customize reporting for data attributes?

6. What are the technological challenges NCUA should consider with a standardized data format (

e.g.,

specific file names, format, etc.)?

7. What additional initial and annual costs would you estimate a FICU could incur to generate and provide data electronically in a standard format (

e.g.,

pass through costs from vendors, in-house development resources, etc.)?

8. Does the credit union or vendor have the ability to retain and create the current loan and share download data format (with no changes) as well as new download data formats?

NCUA is modernizing our examination platform and analytics. The new data format will be used with these technological advancements. Until the current systems that use the existing download are retired, examiners will need the current download file as existing tools may not be able to accommodate a new download data format.

9. Should NCUA eliminate the “critical” and “optional” data

categorizations discussed in NCUA Letter to Credit Unions 03-CU-05? If yes, what approaches would you propose NCUA use to collect standardized data for better analytics and examination efficiencies?

10. With the exception of the example data formats based on data type discussed in this RFI, what alternatives would you propose for NCUA to collect data in a standardized format that minimizes the credit union burden?

11. What implementation strategies and timeline should NCUA consider with this modernization? For example, what is the anticipated timeframe for a FICU or vendor to provide the sample data fields and the associated format? How should NCUA ensure FICUs use the standard data format?

12. What specific information security controls or assurances are expected from NCUA to reasonably safeguard the electronic loan, share, and investment data?

Commenters are also encouraged to discuss any other relevant issues they believe NCUA should consider with respect to the electronic collection of loan, deposit, and investment data.

b. Sample Loan, Deposit, and Investment Electronic Data Collection

NCUA is requesting input and feedback on sample data fields and the associated format.

The information in tables 2-9 is preliminary and is presented for discussion and input purposes only. For sample purposes only, NCUA is presenting one data format for all deposit types, one for investment data,

and different data formats for loans based on the loan type.

To the extent the FICU offers these loan and deposit services and has these investment instruments, NCUA is asking stakeholders to identify if FICUs can provide these and other data fields electronically in their response to the RFI. Similar to the download process today, credit unions would be permitted to submit multiple data files electronically for loans, deposits, and investments.

These data formats include 9 member profile, 18 deposit, 120 loan, and 12 investment unique data files. They include all data fields listed in Letter to Credit Unions 03-CU-05, except three data fields that would be overlapping with new data fields—Date of Last Activity, Last Activity Code, and Credit Limit at origination.

As of March 31, 2017, FICUs reported the following investments: Securities: 40.9% of all FICUs; Non-negotiable CDs: 83.7%.

Loan types include consumer, indirect, participations, residential real estate, student loans, and commercial/member business loans. As of March 31, 2017, FICUs reported the following loan services: Consumer: 100% of FICUs; Indirect: 33.1%; Participation: 27.2%; Real estate: 75.6%; Non-guaranteed federal student Loans: 12.1%; Commercial/MBL: 37.9%.

Identifies fields requested in NCUA Letter to Credit Unions 03-CU-05 (April 2003). Fields identified with an asterisk (*) are categorized as “critical” fields by NCUA in Letter to Credit Unions 03-CU-05.

Table 2—Deposit Electronic Fields

Number

Applies to

Field

Description

Example

Data

format

Current NCUA

standard

field

All Share Accounts

Effective date of the download

Effective date of the data

03312017

Date

No.

All Share Accounts

Record Code

Indicate D for Deposits, L for Loans, I for Investment

D/L/I

Yes .*

All Share Accounts

Taxpayer ID

Nine digit code used by the U.S. Government (TIN). For individuals use Social Security number

123456789

Number

Yes .*

All Share Accounts

Member ID

Primary key identifier for the entity. This is the number used to uniquely identify the member/non-member such as an account number

ABC123456

Text

Yes .*

All Share Accounts

Member Name

Full legal name. Format: Last Name, Suffix (if applicable), First Name, Middle Initial for individuals. For business provide full legal name

Long Sr., John, S

Text

Yes .*

All Share Accounts

Address Line 1

Street address

7247 Circle Sun

Text

Yes .*

All Share Accounts

Address Line 2

Address line 2

P.O. Box 858

Text

Yes

All Share Accounts

City

City where borrower resides. For business account, provide the city of the main or head office

Fairfax

Text

Yes .*

All Share Accounts

State

Post office state code where borrower resides. For business accounts, provide the state of the main or head office

Text

Yes .*

D10

All Share Accounts

Zip Code

Zip code where borrower resides. For business accounts, provide the zip code of the main or head office

80521

Number

Yes .*

D11

All Share Accounts

Insiders and Employees

If data supports, report “D” for directors, supervisory committee, and credit committee members, “O” for executive officers, and “E” for employees who are not executive officers. If the CEO is also the Board Treasurer, report as an executive officer—“O”. If the credit union or vendor data does not support this scheme, simply identify insider status with Y/N

Text

Yes.

D12

All Share Accounts

Non-member

Indicator to identify non-member share accounts

Y/N

No.

D13

All Share Accounts

Share Balance

Current balance of the share account, signed with two decimal places

156.45

Number

Yes .*

D14

All Share Accounts

Share Type Code

System code to identify certificates, regular, draft, IRA, money market and other share deposit accounts

Text

Yes .*

D15

All Share Accounts

Dividend Rate

Current dividend rate for each share account

Number

Yes .*

D16

All Share Accounts

Date of Last Activity

Date of last deposit or withdrawal

03312017

Date

Yes .*

D17

All Share Accounts

Share Amount Frozen

Dollar amount of the account the member cannot access

5000.00

Number

Yes .*

D18

All Share Accounts

Last Activity Code

Identifies the type of account activity that occurred last by code

Text

Yes.

D19

All Share Accounts

Accrued Dividend Interest

Dollar amount of accrued dividends

25.36

Number

Yes.

D20

All Share Accounts

Last File Maintenance Date

Last date of any non-financial modification to the account (

e.g.,

dividend rate, member address, etc.)

03312017

Date

Yes.

D21

All Share Accounts

Last File Maintenance User ID or Initials

Approving official or employee's transaction code or initials

Text

Yes.

D22

All Share Accounts

Date Negative Shares

The date the share account first went negative without cure

03312017

Date

No.

D23

All Share Accounts

Joint Owner

Provide the name of the joint owner's full legal name. Format: Last Name, Suffix (if applicable), First Name, Middle Initial for individuals. For businesses, provide full legal name

Long Sr., John, S

Text

No.

D24

All Share Accounts

Membership Type

Provide the membership type using the following identifiers: Single ownership, Joint ownership, Trustee, or Business

Business

Text

No.

D25

All Share Accounts

Last Statement Date

Date the member statement was last generated

03312017

Date

No.

D26

Share Certificate Accounts

Step/Bump Dividend Rate

Indicator if the share certificate product has a term that allows the member to “step-up” or “bump-up” the dividend rate

Y/N

No.

D27

Share Certificate Accounts

Certificate Date Granted

Date member opened the share certificate account

03312017

Date

Yes .*

D28

Share Certificate Accounts

Certificate Maturity Date

Date the share certificate will mature

03312017

Date

Yes .*

D29

Business Accounts

Name of Beneficiaries

Full legal name of individuals who are beneficiaries on business accounts. Format: Last Name, Suffix (if applicable), First Name, Middle Initial

Long Sr., John, S

Text

No.

NCUA has not previously published a standard structure for investment data. This will facilitate robust analytics with a dynamic, quantitative third-party service platform for interest rate risk assessment of individual securities and portfolios without requiring the examiner to reformat data files or request additional data from the credit union.

Table 3—Security and Non-Negotiable CD Investment Electronic Fields

Number

Field

Description

Example

Data

format

Current NCUA

standard

field

Download Cut-off date

Effective date of the data

03312017

Date

No.

Record Code

Report D for Deposits, L for Loans, I for Investment

D/L/I

No.

CUSIP Number

Committee on Uniform Securities Identification Procedures number. Security identifier

23345abcd

Text

No.

Original Face Value

Original face value of the investment

100,000

Number

No.

Current Face Value

Current face value of the investment

100,000

Number

No.

Book Value

Current book value of the investment

102,000

Number

No.

Fair Value

Current fair value of the investments

102,000

Number

No.

Maturity Date

Maturity date of investment

12312017

Date

No.

Coupon/Rate

Stated coupon or rate of investment

Number

No.

I10

Floating Rate

Indicator if the investment has floating rate

Y/N

No.

I11

Issuer

Name of issuer of the investment

Wells Fargo Bank

Text

No.

I12

Settlement Date

Date funds are exchanged

10312015

Date

No.

NCUA reviewed the Interagency Loan Data Request (ILDR) issued in March 2013. The ILDR provides a standard format for banks to electronically provide loan data. In comparison to the 82 data fields in the ILDR, the sample loan formats include 61 similar loan fields.

https://www.fdic.gov/news/news/financial/2013/fil13012.html

Table 4—Consumer and Credit Card Loan Electronic Fields

Number

Field

Description

Example

Data

format

Current NCUA

standard field

ILDR Field

Effective date of the download

Effective date of the data

03312017

Date

No.

Record Code

Indicate D for Deposits, L for Loans, I for Investment

D/L/I

Yes*

No.

Taxpayer ID

Nine digit code used by the US Government (TIN). For individuals use social security number

123456789

Number

Yes*

Yes.

Borrower ID

Primary key identifier for the entity. This is the number used to uniquely identify the member/non-member such as an account number

ABC123456

Text

Yes*

Yes.

Member Name

Full legal name. Format: Last Name, Suffix (if applicable), First Name, Middle Initial for individuals. For business provide full legal name

Long Sr., John, S

Text

Yes*

Yes.

Address Line 1

Street address

7247 Circle Sun

Text

Yes*

Yes.

Address Line 2

Address line 2

PO Box 858

Text

Yes

Yes.

City

City where borrower resides. For business accounts, provide the city of the main or head office

Fairfax

Text

Yes*

Yes.

State

Post office state code where borrower resides. For business accounts, provide the state of the main or head office

Text

Yes*

Yes.

C10

Zip Code

Zip code where borrower resides. For business accounts, provide the zip code of the main or head office

80521

Number

Yes*

Yes.

C11

Insiders and Employees

Text

Yes

Yes.

C12

Business Type

Provide the member's North American Industry Classification System (NAICS) code where majority of their revenue is generated from

54194

Text

Yes.

C13

Branch ID

Identifies the originating service facility

01C

Text

Yes

Yes.

C14

Loan ID

Unique identifier for each loan

Text

Yes.

C15

Loan Category

The type of loan. Provide “Commercial/MBL”, “Residential Real Estate”, or “Consumer”

Commercial

Text

No.

C16

Loan Type

The type of loan product as defined by the vendor or credit union (e.g. New or Used Auto, Credit Card Fixed, Credit Card Variable, etc.)

Capital LOC

Text

Yes*

Yes.

C17

Purpose Code

Description of what the proceeds will be used for; Reason for loan

Auto purchase

Text

Yes*

Yes.

C18

Origination Date

The note date; date the loan was originated. Do not report the date of last advance

03312017

Date

Yes*

Yes.

C19

Original Loan Amount

The original principal amount of the loan

1500.45

Number

Yes*

Yes.

C20

Payment Amount

Amount of regularly scheduled payment

780.25

Number

Yes*

Yes.

C21

Loan Term

The contractual number of payments required by the note or modification of the note

Number

Yes*

Yes.

C22

Payment Frequency

The interval of time payments are contractually required (monthly, quarterly, annually, balloon/maturity, etc.)

Text

Yes*

Yes.

C23

Balloon Flag

Indicator the loan is a balloon loan

Y/N

No.

C24

Balloon Term

Number of months from origination until balloon date

Number

No.

C25

Interest Only Flag

Indicator the borrower pays only the interest on the principal balance for a set period of time, with the principal balance unchanged

Y/N

No.

C26

Interest Only Term

The length of time (in months) during which the borrower pays only interest on the principal balance

Number

No.

C27

First Payment Date

Date the first payment was/is due

03312017

Date

No.

C28

Maturity Date

Date when full payment on the loan is contractually due. For balloon loans, this should be the same as the balloon expiration date

03312017

Date

Yes.

C29

Interest Rate

The contractual rate of interest currently applied to this loan at origination

5.000

Number

Yes*

Yes.

C30

Loan Type

The type of loan product as defined by the vendor or credit union (e.g. New or Used Auto, Credit Card Fixed, Credit Card Variable, etc.)

Capital LOC

Text

Yes

Yes.

C31

Current Interest Rate

The contractual rate of interest currently applied to this loan

Number

Yes.

C32

First Rate Adjustment Date

Initial date the interest rate will/did adjust on variable rate loans

03312017

Date

No.

C33

Next Rate Adjustment Date

Future date interest rate will adjust on variable rate loans

03312017

Date

No.

C34

Lifetime Interest Rate Cap

The maximum rate the loan can reach over its contractual term

18.000

Number

Yes.

C35

Interest Rate Floor

The minimum rate the loan can reach over its contractual term

4.000

Number

No.

C36

Variable Rate Index

Interest rate base index used when the loan's rate varies with an index

Prime

Text

Yes.

C37

Variable Rate Margin

The margin added or subtracted from the index to get the rate

Number

No.

C38

Current Credit Limit

The maximum a borrower can currently incur

2500.00

Number

No.

C39

Date Closed

Date a line of credit was closed

03312017

Date

No.

C40

Credit Score at Origination

Credit score of the primary borrower (e.g. FICO or Beacon) obtained from a credit bureau that was used in the underwriting of the credit. If two bureau scores were used, provide the highest score. If the credit union obtains all three bureau scores, provide the middle score

825

Number

Yes*

Yes.

C41

Original Credit Score Date

Date of the primary borrower's credit score at origination

03312017

Date

No.

C42

Current Credit Score

Most recent primary borrower credit score obtained by the credit union

745

Number

No.

C43

Current Credit Score Date

Most recent date of updated credit score for the primary borrower

03312017

Date

No.

C44

Guarantor

Name of entity/person that guarantees the loan. With multiple guarantors, give the primary one

Long Sr., John, S

Text

Yes.

C45

Co-Maker/Co-Borrower/Guarantor

The name of the co-maker/co-borrower whose signature(s) appears on the promissory note or loan agreement. Provide the first one when there are multiple co-makers/co-borrowers

Long Sr., John, S

Text

Yes.

C46

Co-Maker/Co-Borrower Credit Score at Origination

Credit score of the co-maker/co-borrower at the time of origination

680

Number

No.

C47

Current Credit Score Date of Co-Borrower

Most recent date of updated credit score of the co-borrower/co-maker

03312017

Date

No.

C48

Original Credit Score Date of Co-Borrower

Credit score of the co-borrower/co-maker (e.g. FICO or Beacon) obtained from a credit bureau that was used in the underwriting of the credit. If two bureau scores were used, provide the highest score. If the credit union obtains all three bureau scores, provide the middle score

800

No.

C49

Loan Officer

Code or loan officer name responsible underwriting and/or borrower relationship

Text

Yes.

C50

Loan Approver

Code or name of approving official. Indicate if approved by the Credit Committee or Board of Directors

Text

Yes

No.

C51

Loan Risk Grade

Credit union internal risk rating at origination. The credit union's internal loan risk grade (e.g., A, B, C, or D paper)

Text

Yes

Yes.

C52

Collateral Protection Insurance

Indicator loan has coverage for when insurance coverage lapses

Y/N

No.

C53

GAP Indicator

Indicator the member purchased gap insurance on the collateral

Y/N

No.

C54

Credit Life

Indicator loan has a life insurance policy designed to pay off the borrower's debt if they die

Y/N

No.

C55

Credit Disability

Indicator loan has disability insurance designed to pay the borrower's debt if they become disabled

Y/N

No.

C56

Loan Collateral

The narrative description of the collateral (e.g., year, make and model; 38 unit apartment building, etc.)

1996 Ford Mustang

Text

Yes.

C57

Collateral Code

The system code associated with the collateral type (e.g., residential real estate, etc.)

Residential real estate

Text

Yes*

Yes.

C58

Origination Collateral Value

Total value of collateral at loan origination

50000.00

Number

Yes.

C59

Collateral Valuation/Appraisal Date (Origination)

Date collateral was appraised or valued at loan origination

20170313

Date

Yes.

C60

Current Collateral Value

Dollar value of collateral when last assessed by the credit union

45150.65

Number

No.

C61

Most Recent Collateral Value/Appraisal Date

Date collateral was last appraised or valued

03312017

Date

Yes.

C62

Lien Position

The credit union's lien position on the collateral (e.g., 1st, 2nd, 3rd, etc.). If more than one collateral, identify the primary collateral's lien position

Number

Yes.

C63

VIN Number

Vehicle Identification Number/unique identifier for collateral

1GTV2TEH8EZ173011

Text

No.

C64

Current Loan Balance

Current outstanding principal balance of the loan. If the member has overpaid the note and the credit union is carrying a credit balance, provide the number as a negative balance with a minus sign as the first character (e.g., −33.56)

84500.01

Number

Yes*

Yes.

C65

Date of Last Payment

Date the last payment was made

03312017

Date

Yes.

C66

Number of Remaining Payments

The remaining contractual number of payments required by the loan

Number

Yes*

No.

C67

Next Payment Due Date

The date the next payment, principal or interest, is due. For delinquent loans, this will be in the past

03312017

Date

Yes*

Yes.

C68

Accrued Interest

Total amount of interest accrued and not yet received on a loan

180.32

Number

Yes*

Yes.

C69

Late Charges

Late charges currently due and unpaid

95.06

Number

Yes.

C70

Debt to Income Ratio

Debt payments divided by gross or net income calculated at time of loan origination

35.670

Number

No.

C71

Days Past Due

Number of days the note is past due beyond the due date as of the effective date of the download. If loan is current or paid ahead, report as zero

Number

Yes*

Yes.

C72

Delinquency Counter 30-59 Days

Number of times past due 30-59 days since origination date

Number

Yes

Yes.

C73

Delinquency Counter 60-89 Days

Number of times past due 60-89 days since origination date

Number

Yes

Yes.

C74

Delinquency Counter 90-119 Days

Number of times past due 90-119 days or more since the origination date

Number

Yes

Yes.

C75

Delinquency Counter 120 Days +

Number of times past due 120+ days or more since the origination date

Number

Yes

Yes.

C76

Last Renewal Date

The date the loan was last renewed

03312017

Date

Yes.

C77

Loan Modification

Indicator if the loan has been modified. A loan modification permanently restructures the terms of an existing loan. A loan modification is not a new loan, but a renegotiation of an existing loan

Y/N

No.

C78

Date of Loan Modification

Date of last loan modification

20170313

Date

Yes.

C79

Capitalized Interest Amount

Amount of interest added to the loan principal balance

259.63

Number

Yes.

C80

Amount of last advance

Dollar amount of the last advance

55000.00

Number

No.

C81

Interest rate reset interval

Time between periodic reset dates for variable or adjustable rate loans expressed in days.

Number

Yes.

C82

Troubled Debt Restructure

Indicates if a loan is currently a troubled debt restructure as defined by GAAP

Y/N

Yes.

C83

Nonaccrual

Indicate if the loan is currently on nonaccrual

Y/N

Yes.

C84

Charge-Off Flag

Indicator if entire loan has been charged off

Y/N

No.

C85

Charge Off Amount

Amount of principal charged off this loan

5000.00

Number

Yes

Yes.

C86

Charge Off Date

Date the loan was charged off

03312017

Date

No.

C87

Last File Maintenance Date

Date of last file maintenance change on this loan

03312017

Date

Yes

No.

C88

Last File Maintenance User ID or Initials

User ID of person who made last file maintenance change

JB100

Text

Yes

No.

C89

Last File Maintenance action Code

Description of what was last changed on the member loan (e.g., due date, name, loan status, etc.)

Text

No.

C90

Interest Rate Spread

Interest rate variance from the index rate changed on the note. Express in terms of a percentage. For example, the premium of a note written at Prime +2.25% would be expressed as 2.25

2.25

Number

Yes.

Table 5—Indirect Loan Electronic Data Fields

Number

Field

Description

Example

Data

format

Current NCUA field

ILDR field

Includes all fields from

Table 4: Consumer and Credit Card Loan Electronic Data Fields

and the following:

ID1

Dealer Code

Name of sales agent for indirect auto loans

Hanks Auto Sales

Text

Yes.

ID2

Indirect Loan Flag

Indicator if the loan was originated through an indirect loan program

Y/N

No.

ID3

Dealer Reserve Balance

Current dealer reserve against the note

3,000

Number

Yes.

Table 6—Participation Loan Electronic Data Fields

Number

Field

Description

Example

Data

format

Current NCUA field

ILDR field

Includes all fields from

Table 4: Consumer and Credit Card Loan Electronic Data Fields

and the following:

Participation Sold (Original Amount)

The original amount of this note that was sold

9,000,000

Number

Yes.

Participation Sold (Current Balance)

The current balance of the amount sold

8,750,000

Number

Yes.

Participation Purchases (Original Amount)

The original amount of this note that was purchased

9,000,000

Number

No.

Participation Purchases (Current Balance)

The current balance of the amount purchased

8,750,000

Number

No.

Purchase percentage

Shows the percentage of the total participation loan owned by the credit union for individual loan purchases

20.000

Number

No.

Originating/Lead Lender

Shows the name of the originating/lead lender in the participation

ABC FCU

Text

No.

Sold Percentage

Identify the percentage of total participation loan the credit union sold

90.999

Number

No.

Table 7—Residential Real Estate Loan Electronic Data Fields

Number

Field

Description

Example

Data

format

Current NCUA field

ILDR field

Includes all fields from

Table 4: Consumer and Credit Card Loan Electronic Data Fields

and the following:

Property Type

Indicate the property type (

e.g.,

Single, Multi, Condominium, etc.)

Condo

Text

No.

Collateral State

Post office state code where collateral property is located

Text

No.

Collateral City

City where collateral property is located

Phoenix

Text

No.

Collateral County

County where collateral property is located

Maricopa

Text

No.

Collateral Zip Code

Zip code where collateral property is located

85255

Number

No.

Property in Flood Zone

Indicator if the collateral securing the loan is in a designated flood zone

Y/N

No.

Draw Period

Remaining period of time (in months) a borrower can withdraw funds from a credit account

120

Number

No.

Current Escrow Balance

Amount currently in escrow for payment to third parties such as insurance and real estate taxes. In the case of a negative escrow balance, report the data in this field with a minus sign in the first character position (

e.g.,

−350)

2,585

Number

Yes.

Number of Renewals

Indicate the number of times the loan has been renewed

Number

Yes.

Table 8—Commercial/Member Business Loan Electronic Data Fields

Number

Field

Description

Example

Data

format

Current NCUA field

ILDR field

Includes all fields from

Table 4: Consumer and Credit Card Loan Electronic Data Fields

and the following:

CL1

Current Loan Risk Grade Commercial/MBL

Credit union internal risk rating at recent review/evaluation of commercial/MBL; Number or letter grade determined based on the level of risk

Text

Yes.

CL2

Date of Current Loan Risk Grade Commercial/MBL

Date the most recent internal risk rating at recent review/evaluation of commercial/MBLs

03312017

Date

Yes.

CL3

Debt Service Coverage Ratio (DSCR)

Debt service coverage ratio calculated for the loan at origination

1.05

Number

No.

CL4

Personal guaranty status

Identify the level of personal guaranty of the principals (

e.g.,

full, limited, or none)

Full

Text

No.

CL5

Environmental Review Level at origination

Identify the level of environmental review at origination (

e.g.,

borrower questionnaire, record search, phase 1, or phase 2)

Phase 1

Text

No.

CL6

Environmental Review Date

Date of environmental review at origination

03312017

Date

No.

CL7

Last Periodic Review

Date of last periodic/annual file review

03312017

Date

No.

CL8

Property Type

Indicate the property type (

e.g.,

Single, Multi, Condominium, etc.)

Condo

Text

No.

CL9

Collateral State

Post office state code where collateral property is located

Text

No.

CL10

Collateral City

City where collateral property is located

Phoenix

Text

No.

CL11

Collateral County

County where collateral property is located

Maricopa

Text

No.

CL12

Collateral Zip Code

Zip code where collateral property is located

85255

Number

No.

CL13

Property in Flood Zone

Indicator if the collateral securing the loan is in a designated flood zone

Y/N

No.

CL14

Draw Period

Remaining period of time (in months) a borrower can withdraw funds from a credit account

120

Number

No.

CL15

Current Escrow Balance

e.g.,

−350)

2,585

Number

Yes.

CL16

Policy Exception

Indicator if the loan is an exception to policy

Y/N

No.

CL17

Number of Renewals

Indicate the number of times the loan has been renewed

Number

Yes.

CL18

Specific Reserve

Amount of specific reserve for loan losses on this note which is not available to offset losses on any other loan

50,000

Number

Yes.

Table 9—Student Loan Electronic Data Fields

Number

Name

Description

Example

Data

format

Current NCUA field

ILDR field

Includes all fields from

Table 4: Consumer and Credit Card Loan Electronic Data Fields

and the following:

Time to Repayment

For deferred loans: Amount of time, in months, until repayment period begins

Number

No.

Deferred Status

Indicator if student loan is in deferred status

Y/N

No.

By the National Credit Union Administration Board on October 19, 2017.

Gerard Poliquin,

Secretary of the Board.

[FR Doc. 2017-23219 Filed 10-30-17; 8:45 am]

BILLING CODE 7535-01-P

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.