Community Reinvestment Act (CRA)
Q&A on Completing the Survey
- Who requested that the survey of CRA lending be undertaken?
- What banking institutions were asked to complete the survey, and who received the mailing?
- Is the survey mandatory?
- Does the CEO have to complete the survey or can someone else?
- Will someone be able to identify an institution by the data made available to the public?
- Will responses be used by supervisory personnel during an institution’s examination?
- What if respondents have additional questions?
- How many parts does the survey contain?
What is a “CRA special lending program"?
Should respondents consider special affordable lending programs established by Fannie Mae and Freddie Mac to be special CRA lending programs?
Can I obtain another copy of the survey?
Returning the Questionnaire
- Does everything (the General Institutional Information page and all of Parts A and B) need to be completed and returned?
Should an institution return individual sections of the survey as they are completed?
Can the survey be completed electronically?
What is the deadline date for the submission of a completed survey, and to whom should a completed survey be sent?
- What should an institution do if it cannot finish the survey by the deadline of March 1, 2000?
Guidelines on How to Answer the Questions
What if a particular question is not applicable to an institution? For example, how should an institution answer a question about loan purchases if it does not purchase any loans?
What degree of precision should be used in responding to questions?
If a question seeks a numerical response and an institution does not have the information available to answer the question precisely as posed, what should the institution do?
- What if an institution does not know the answer to a question?
Through the Gramm-Leach-Bliley Act of 1999, Congress directed the Board of Governors of the Federal Reserve System to study the performance and profitability of lending undertaken by banking institutions in conformity with the Community Reinvestment Act of 1977 (CRA). After consulting with Congress, it was decided that the Board would conduct this special, comprehensive survey of bank and savings association experiences with CRA-related lending.
We anticipate gaining new and important insights and measures of the performance of CRA-related lending. This information will further the understanding of the effects of the CRA.
The survey was sent to the CEOs at the 500 largest retail banking institutions, including commercial banks and savings associations. These are institutions regulated by the Federal Deposit Insurance Corporation, the Federal Reserve, the Office of the Comptroller of the Currency, and the Office of Thrift Supervision. The survey was sent to individual banks and savings associations, not to holding companies.
No, the survey is voluntary, although your participation will be greatly valued.
The CEO does not have to complete the survey. Our interest is in obtaining accurate information, so we encourage institutions to forward the survey to those individuals most familiar with the institution’s experiences in the relevant areas. Because the survey collects information on a number of different credit products and programs, the involvement of several individuals may be required.
No. Although the Gramm-Leach-Bliley Act directs the Board to make the report data available to the public, we will do so in a way that makes the identification of any specific institution impossible.
No, responses will not be used for supervisory purposes.
If respondents have questions about his survey that are not answered here, they should contact the Federal Reserve Board using the toll-free “CRA Survey Assistance?voice mail box number (800-281-4930). Messages left at this number will be returned within one business day. As questions are received, those most frequently asked will be added to this page.
The survey contains a General Institutional Information page and two basic parts (Part A and Part B).
The General Institutional Information page requests limited background information about your institution.
Part A (Survey of CRA Lending) seeks to systematically collect information on CRA lending activity in four broad areas:
- * 1-4 family home-purchase and refinance lending,
- * other 1-4 family residential lending such as home improvement and home equity lending (excluding home equity lines of credit)
- * small business lending
- * community development lending (including multifamily residential lending).
A “CRA special lending program?is a program that an institution has developed (or participates in) specifically to enhance its CRA performance. A program meets this criterion only if one of the program’s documented purposes is to enhance an institution’s CRA performance.
CRA special lending programs may include special affordable lending programs that offer more flexible underwriting standards and special loan terms (such as discounted interest rates or waivers or discounts of fees); and special programs offered or developed in conjunction with third parties, such as lending consortia, nonprofit organizations, or government agencies that offer special lending programs in which an institution participates.
A CRA special lending program may involve housing-related, small business, consumer, and other types of loans. However, for this survey, a CRA special lending program does not include (1) traditional government-backed lending programs, such as those offered by the Federal Housing Administration (FHA), Department of Veterans Affairs (VA), and Small Business Administration (SBA), unless the institution provides a special enhancement to these programs, such as a formal program of homebuyer education or a waiver of fees, and (2) programs that focus on making community development loans (as defined in the CRA regulations).
All the questions in Part B and a few of the questions in Part A concern CRA special lending programs. Institutions should use the above definition of such programs in responding to all of these questions.
Yes, if one of the documented reasons that an institution participates in these programs is to enhance its CRA performance. Respondents may aggregate all lending under these programs and report them as a single lending program.
Yes. You can download the survey (in PDF format) from the following page on the Federal Reserve Board's web site:
Because Part B was written using a booklet format so that all the columns would show for each question, you will need to place two consecutively numbered pages (beginning with pages 2 and 3) side by side to mirror the mailed booklet format of Part B. (The remaining side-by-side pages will be 4-5, 6-7, 8-9, 10-11, 12-13, 14- 15, 16-17, 18-19, and 20 by itself).
Returning the Questionnaire
Yes. All the forms should be sent back and, depending on the lending activities of your institution, each form will have some responses completed as described below.
The General Institutional Information page should be completed in its entirety.
In Part A, at least one question in each of the four sections must be answered even if an institution does not do the particular type of lending that the section focuses on--that question is the first “General Question?in each of the four sections. If an institution does not do the particular type of lending being asked about in that section, its response will be “No?to the first general question, and the remaining questions in that section need not be answered. We will, however, expect to receive that section with a response to question 1, and that response will tell us what we need to know.
Please note, however, that no questions in a section of Part A should be left blank if an institution does any lending of the sort addressed in that section. For example, if an institution does any 1-4 family mortgage lending, then no question in section 1 should be left blank; if an institution does any small business lending, then no question in section 3 should be left blank, and so on.
For Part B, no questions in the columns pertaining to CRA special lending programs should be left blank if you have any such programs. For example, if an institution has three CRA special lending programs, then no questions in columns A through C should be left blank. In addition, all institutions should complete column F if they have 2 or more CRA special lending programs. Again, even if an institution does not have any CRA special lending programs, the institution must answer question 1 in Part B.
No. Institutions should submit the whole survey after it is completed and NOT submit it in stages.
No. Unfortunately, the tight timeframe established for the study precluded the development of an electronic data entry tool.
The due date for the completed survey is March 1, 2000. All completed parts of the survey should be sent to the following address:
Federal Reserve Board
Attention: CRA Lending Survey
1709 New York Avenue NW, Fifth Floor
Washington, DC 20006
Institutions should make every effort to complete the survey as close as possible to March 1 and send it as soon as it is completed. We realize that the survey has a tight time schedule. We have tried to facilitate its completion by breaking Part A into four separate, self-contained units that may be distributed individually to staff with expertise in the particular area of lending. Part B consists of only one section.
If an institution is unable to meet the March 1 deadline, we would nonetheless appreciate the return of the survey as soon as it is completed.
Guidelines on How to Answer the Questions
If an institution does the particular type of lending being asked about in a given section, we would like the institution to answer every question in that section. Therefore, if a question is not applicable, please check the “N/A?box provided.
Dollar amounts should be rounded to the nearest thousand, with $500 rounded to $1,000, and expressed without commas (for example, if the dollar amount is $62,495,500, your response should be 62496; if the dollar amount is $85,589,433, your response should be 85589).
Percents should be rounded to the nearest whole percent. Percentage points should be rounded to the nearest hundredth of a percentage point.
We are seeking a response to all questions. We strongly urge respondents to make calculations and assessments using hard data whenever possible. Please make all efforts to respond to the questions in the manner asked.
If respondents lack the data to provide an exact answer, they should provide a reasonable estimate or educated guess if they feel they can. In this case, respondents should use their best judgment in deciding the particular data, assumptions, and procedures that would produce the most appropriate answer to the question.
If an institution does not know the answer to a question, the respondent should write “Don’t Know?or “DK?anywhere in the appropriate response area. If a response area is left completely blank, then we may contact respondents to determine the appropriate response.