Skip to Content

Notice

Electronic Loan, Deposit, and Investment Data Collection

Document Details

Information about this document as published in the Federal Register.

Document Statistics
Document page views are updated periodically throughout the day and are cumulative counts for this document including its time on Public Inspection. Counts are subject to sampling, reprocessing and revision (up or down) throughout the day.
Published Document

This document has been published in the Federal Register. Use the PDF linked in the document sidebar for the official electronic format.

Start Preamble

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.

Start Further Info

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.

End Further Info End Preamble Start Supplemental Information

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

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

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.[3] 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).

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

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.

Start Printed Page 50448

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 [5] 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.[6]

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).[7] NCUA did not increase the electronic data fields or modify the data format with this communication.

NCUA last changed the loan and share download in April 2003.[8] Beginning June 30, 2003, the member profile fields were consolidated and one new field was added for a total of eight fields.[9] 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.

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

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

12/31/20033/31/2017Change (%)
FICUs9,3695,737(63.33)
Total Assets$610.16B$1.34T119.62
Total Loans$376.11B$884.58B135.20
Consumer Loans 11$187.53B$390.07B108.00
Credit Card Loans$21.84B$51.59B136.21
Indirect Loans12 Not collected$172.56BNot available
Participation Loans$4.5B$29.97B566.00
Real Estate Loans 13$168.26B$438.93B160.86
Commercial/MBL$9.32B$68.89B639.16
Student Loans 14Not collected$3.99BNot available
Total Shares$528.34B$1.13T113.88
Average Assets$65.10M$233.0M257.91
Median Assets$10.55M$29.97M184.08
# Loans40.92M61.01M49.10
# Shares Accounts142.34M204.44M43.63

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 Start Printed Page 50449structure and fields for different loan types,[15] 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.

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 [16] and must meet these minimum information security requirements by using security and privacy controls recommended by the National Institute of Standards and Technology (NIST).[17] 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.

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.[18]

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? [19]

9. Should NCUA eliminate the “critical” and “optional” data Start Printed Page 50450categorizations 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.[20] 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,[21] and different data formats for loans based on the loan type.[22] 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.

Table 2—Deposit Electronic Fields

NumberApplies toFieldDescriptionExampleData formatCurrent NCUA standard field 23
D1All Share AccountsEffective date of the downloadEffective date of the data03312017DateNo.
D2All Share AccountsRecord CodeIndicate D for Deposits, L for Loans, I for InvestmentDD/L/IYes  .*
D3All Share AccountsTaxpayer IDNine digit code used by the U.S. Government (TIN). For individuals use Social Security number123456789NumberYes .*
D4All Share AccountsMember IDPrimary key identifier for the entity. This is the number used to uniquely identify the member/non-member such as an account numberABC123456TextYes .*
D5All Share AccountsMember NameFull legal name. Format: Last Name, Suffix (if applicable), First Name, Middle Initial for individuals. For business provide full legal nameLong Sr., John, STextYes .*
D6All Share AccountsAddress Line 1Street address7247 Circle SunTextYes .*
D7All Share AccountsAddress Line 2Address line 2P.O. Box 858TextYes
D8All Share AccountsCityCity where borrower resides. For business account, provide the city of the main or head officeFairfaxTextYes .*
D9All Share AccountsStatePost office state code where borrower resides. For business accounts, provide the state of the main or head officeNMTextYes .*
D10All Share AccountsZip CodeZip code where borrower resides. For business accounts, provide the zip code of the main or head office80521NumberYes .*
D11All Share AccountsInsiders and EmployeesIf 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/NETextYes.
Start Printed Page 50451
D12All Share AccountsNon-memberIndicator to identify non-member share accountsYY/NNo.
D13All Share AccountsShare BalanceCurrent balance of the share account, signed with two decimal places156.45NumberYes .*
D14All Share AccountsShare Type CodeSystem code to identify certificates, regular, draft, IRA, money market and other share deposit accountsRTextYes .*
D15All Share AccountsDividend RateCurrent dividend rate for each share account2NumberYes .*
D16All Share AccountsDate of Last ActivityDate of last deposit or withdrawal03312017DateYes .*
D17All Share AccountsShare Amount FrozenDollar amount of the account the member cannot access5000.00NumberYes .*
D18All Share AccountsLast Activity CodeIdentifies the type of account activity that occurred last by codeFMTextYes.
D19All Share AccountsAccrued Dividend InterestDollar amount of accrued dividends25.36NumberYes.
D20All Share AccountsLast File Maintenance DateLast date of any non-financial modification to the account (e.g., dividend rate, member address, etc.)03312017DateYes.
D21All Share AccountsLast File Maintenance User ID or InitialsApproving official or employee's transaction code or initialsAHTextYes.
D22All Share AccountsDate Negative SharesThe date the share account first went negative without cure03312017DateNo.
D23All Share AccountsJoint OwnerProvide 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 nameLong Sr., John, STextNo.
D24All Share AccountsMembership TypeProvide the membership type using the following identifiers: Single ownership, Joint ownership, Trustee, or BusinessBusinessTextNo.
D25All Share AccountsLast Statement DateDate the member statement was last generated03312017DateNo.
D26Share Certificate AccountsStep/Bump Dividend RateIndicator if the share certificate product has a term that allows the member to “step-up” or “bump-up” the dividend rateYY/NNo.
D27Share Certificate AccountsCertificate Date GrantedDate member opened the share certificate account03312017DateYes .*
D28Share Certificate AccountsCertificate Maturity DateDate the share certificate will mature03312017DateYes .*
D29Business AccountsName of BeneficiariesFull legal name of individuals who are beneficiaries on business accounts. Format: Last Name, Suffix (if applicable), First Name, Middle InitialLong Sr., John, STextNo.

Table 3—Security and Non-Negotiable CD Investment Electronic Fields 24

NumberFieldDescriptionExampleData formatCurrent NCUA standard field
I1Download Cut-off dateEffective date of the data03312017DateNo.
I2Record CodeReport D for Deposits, L for Loans, I for InvestmentLD/L/INo.
I3CUSIP NumberCommittee on Uniform Securities Identification Procedures number. Security identifier23345abcdTextNo.
Start Printed Page 50452
I4Original Face ValueOriginal face value of the investment100,000NumberNo.
I5Current Face ValueCurrent face value of the investment100,000NumberNo.
I6Book ValueCurrent book value of the investment102,000NumberNo.
I7Fair ValueCurrent fair value of the investments102,000NumberNo.
I8Maturity DateMaturity date of investment12312017DateNo.
I9Coupon/RateStated coupon or rate of investment5NumberNo.
I10Floating RateIndicator if the investment has floating rateYY/NNo.
I11IssuerName of issuer of the investmentWells Fargo BankTextNo.
I12Settlement DateDate funds are exchanged10312015DateNo.

Table 4—Consumer and Credit Card Loan Electronic Fields

NumberFieldDescriptionExampleData formatCurrent NCUA standard field 25ILDR Field 26
C1Effective date of the downloadEffective date of the data03312017DateNoNo.
C2Record CodeIndicate D for Deposits, L for Loans, I for InvestmentLD/L/IYes*No.
C3Taxpayer IDNine digit code used by the US Government (TIN). For individuals use social security number123456789NumberYes*Yes.
C4Borrower IDPrimary key identifier for the entity. This is the number used to uniquely identify the member/non-member such as an account numberABC123456TextYes*Yes.
C5Member NameFull legal name. Format: Last Name, Suffix (if applicable), First Name, Middle Initial for individuals. For business provide full legal nameLong Sr., John, STextYes*Yes.
C6Address Line 1Street address7247 Circle SunTextYes*Yes.
C7Address Line 2Address line 2PO Box 858TextYesYes.
C8CityCity where borrower resides. For business accounts, provide the city of the main or head officeFairfaxTextYes*Yes.
C9StatePost office state code where borrower resides. For business accounts, provide the state of the main or head officeNMTextYes*Yes.
C10Zip CodeZip code where borrower resides. For business accounts, provide the zip code of the main or head office80521NumberYes*Yes.
C11Insiders and EmployeesIf 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/NETextYesYes.
C12Business TypeProvide the member's North American Industry Classification System (NAICS) code where majority of their revenue is generated from54194TextNoYes.
C13Branch IDIdentifies the originating service facility01CTextYesYes.
C14Loan IDUnique identifier for each loanATextNoYes.
Start Printed Page 50453
C15Loan CategoryThe type of loan. Provide “Commercial/MBL”, “Residential Real Estate”, or “Consumer”CommercialTextNoNo.
C16Loan TypeThe 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 LOCTextYes*Yes.
C17Purpose CodeDescription of what the proceeds will be used for; Reason for loanAuto purchaseTextYes*Yes.
C18Origination DateThe note date; date the loan was originated. Do not report the date of last advance03312017DateYes*Yes.
C19Original Loan AmountThe original principal amount of the loan1500.45NumberYes*Yes.
C20Payment AmountAmount of regularly scheduled payment780.25NumberYes*Yes.
C21Loan TermThe contractual number of payments required by the note or modification of the note60NumberYes*Yes.
C22Payment FrequencyThe interval of time payments are contractually required (monthly, quarterly, annually, balloon/maturity, etc.)MTextYes*Yes.
C23Balloon FlagIndicator the loan is a balloon loanYY/NNoNo.
C24Balloon TermNumber of months from origination until balloon date84NumberNoNo.
C25Interest Only FlagIndicator the borrower pays only the interest on the principal balance for a set period of time, with the principal balance unchangedYY/NNoNo.
C26Interest Only TermThe length of time (in months) during which the borrower pays only interest on the principal balance12NumberNoNo.
C27First Payment DateDate the first payment was/is due03312017DateNoNo.
C28Maturity DateDate when full payment on the loan is contractually due. For balloon loans, this should be the same as the balloon expiration date03312017DateNoYes.
C29Interest RateThe contractual rate of interest currently applied to this loan at origination5.000NumberYes*Yes.
C30Loan TypeThe 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 LOCTextYesYes.
C31Current Interest RateThe contractual rate of interest currently applied to this loan5NumberNoYes.
C32First Rate Adjustment DateInitial date the interest rate will/did adjust on variable rate loans03312017DateNoNo.
C33Next Rate Adjustment DateFuture date interest rate will adjust on variable rate loans03312017DateNoNo.
C34Lifetime Interest Rate CapThe maximum rate the loan can reach over its contractual term18.000NumberNoYes.
C35Interest Rate FloorThe minimum rate the loan can reach over its contractual term4.000NumberNoNo.
C36Variable Rate IndexInterest rate base index used when the loan's rate varies with an indexPrimeTextNoYes.
C37Variable Rate MarginThe margin added or subtracted from the index to get the rate2NumberNoNo.
C38Current Credit LimitThe maximum a borrower can currently incur2500.00NumberNoNo.
C39Date ClosedDate a line of credit was closed03312017DateNoNo.
C40Credit Score at OriginationCredit 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 score825NumberYes*Yes.
C41Original Credit Score DateDate of the primary borrower's credit score at origination03312017DateNoNo.
Start Printed Page 50454
C42Current Credit ScoreMost recent primary borrower credit score obtained by the credit union745NumberNoNo.
C43Current Credit Score DateMost recent date of updated credit score for the primary borrower03312017DateNoNo.
C44GuarantorName of entity/person that guarantees the loan. With multiple guarantors, give the primary oneLong Sr., John, STextNoYes.
C45Co-Maker/Co-Borrower/GuarantorThe 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-borrowersLong Sr., John, STextNoYes.
C46Co-Maker/Co-Borrower Credit Score at OriginationCredit score of the co-maker/co-borrower at the time of origination680NumberNoNo.
C47Current Credit Score Date of Co-BorrowerMost recent date of updated credit score of the co-borrower/co-maker03312017DateNoNo.
C48Original Credit Score Date of Co-BorrowerCredit 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 score800NoNo.
C49Loan OfficerCode or loan officer name responsible underwriting and/or borrower relationshipBBTextNoYes.
C50Loan ApproverCode or name of approving official. Indicate if approved by the Credit Committee or Board of DirectorsAGTextYesNo.
C51Loan Risk GradeCredit union internal risk rating at origination. The credit union's internal loan risk grade (e.g., A, B, C, or D paper)ATextYesYes.
C52Collateral Protection InsuranceIndicator loan has coverage for when insurance coverage lapsesYY/NNoNo.
C53GAP IndicatorIndicator the member purchased gap insurance on the collateralYY/NNoNo.
C54Credit LifeIndicator loan has a life insurance policy designed to pay off the borrower's debt if they dieYY/NNoNo.
C55Credit DisabilityIndicator loan has disability insurance designed to pay the borrower's debt if they become disabledNY/NNoNo.
C56Loan CollateralThe narrative description of the collateral (e.g., year, make and model; 38 unit apartment building, etc.)1996 Ford MustangTextNoYes.
C57Collateral CodeThe system code associated with the collateral type (e.g., residential real estate, etc.)Residential real estateTextYes*Yes.
C58Origination Collateral ValueTotal value of collateral at loan origination50000.00NumberNoYes.
C59Collateral Valuation/Appraisal Date (Origination)Date collateral was appraised or valued at loan origination20170313DateNoYes.
C60Current Collateral ValueDollar value of collateral when last assessed by the credit union45150.65NumberNoNo.
C61Most Recent Collateral Value/Appraisal DateDate collateral was last appraised or valued03312017DateNoYes.
C62Lien PositionThe 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 position1NumberNoYes.
C63VIN NumberVehicle Identification Number/unique identifier for collateral1GTV2TEH8EZ173011TextNoNo.
Start Printed Page 50455
C64Current Loan BalanceCurrent 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)84500.01NumberYes*Yes.
C65Date of Last PaymentDate the last payment was made03312017DateNoYes.
C66Number of Remaining PaymentsThe remaining contractual number of payments required by the loan24NumberYes*No.
C67Next Payment Due DateThe date the next payment, principal or interest, is due. For delinquent loans, this will be in the past03312017DateYes*Yes.
C68Accrued InterestTotal amount of interest accrued and not yet received on a loan180.32NumberYes*Yes.
C69Late ChargesLate charges currently due and unpaid95.06NumberNoYes.
C70Debt to Income RatioDebt payments divided by gross or net income calculated at time of loan origination35.670NumberNoNo.
C71Days Past DueNumber 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 zero75NumberYes*Yes.
C72Delinquency Counter 30-59 DaysNumber of times past due 30-59 days since origination date2NumberYesYes.
C73Delinquency Counter 60-89 DaysNumber of times past due 60-89 days since origination date4NumberYesYes.
C74Delinquency Counter 90-119 DaysNumber of times past due 90-119 days or more since the origination date0NumberYesYes.
C75Delinquency Counter 120 Days +Number of times past due 120+ days or more since the origination date1NumberYesYes.
C76Last Renewal DateThe date the loan was last renewed03312017DateNoYes.
C77Loan ModificationIndicator 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 loanYY/NNoNo.
C78Date of Loan ModificationDate of last loan modification20170313DateNoYes.
C79Capitalized Interest AmountAmount of interest added to the loan principal balance259.63NumberNoYes.
C80Amount of last advanceDollar amount of the last advance55000.00NumberNoNo.
C81Interest rate reset intervalTime between periodic reset dates for variable or adjustable rate loans expressed in days.30NumberNoYes.
C82Troubled Debt RestructureIndicates if a loan is currently a troubled debt restructure as defined by GAAPYY/NNoYes.
C83NonaccrualIndicate if the loan is currently on nonaccrualNY/NNoYes.
C84Charge-Off FlagIndicator if entire loan has been charged offYY/NNoNo.
C85Charge Off AmountAmount of principal charged off this loan5000.00NumberYesYes.
C86Charge Off DateDate the loan was charged off03312017DateNoNo.
C87Last File Maintenance DateDate of last file maintenance change on this loan03312017DateYesNo.
C88Last File Maintenance User ID or InitialsUser ID of person who made last file maintenance changeJB100TextYesNo.
C89Last File Maintenance action CodeDescription of what was last changed on the member loan (e.g., due date, name, loan status, etc.)DDTextNoNo.
Start Printed Page 50456
C90Interest Rate SpreadInterest 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 2.252.25NumberNoYes.

Table 5—Indirect Loan Electronic Data Fields

NumberFieldDescriptionExampleData formatCurrent NCUA fieldILDR field
Includes all fields from Table 4: Consumer and Credit Card Loan Electronic Data Fields and the following:
ID1Dealer CodeName of sales agent for indirect auto loansHanks Auto SalesTextNoYes.
ID2Indirect Loan FlagIndicator if the loan was originated through an indirect loan programYY/NNoNo.
ID3Dealer Reserve BalanceCurrent dealer reserve against the note3,000NumberNoYes.

Table 6—Participation Loan Electronic Data Fields

NumberFieldDescriptionExampleData formatCurrent NCUA fieldILDR field
Includes all fields from Table 4: Consumer and Credit Card Loan Electronic Data Fields and the following:
P1Participation Sold (Original Amount)The original amount of this note that was sold9,000,000NumberNoYes.
P2Participation Sold (Current Balance)The current balance of the amount sold8,750,000NumberNoYes.
P3Participation Purchases (Original Amount)The original amount of this note that was purchased9,000,000NumberNoNo.
P4Participation Purchases (Current Balance)The current balance of the amount purchased8,750,000NumberNoNo.
P5Purchase percentageShows the percentage of the total participation loan owned by the credit union for individual loan purchases20.000NumberNoNo.
P6Originating/Lead LenderShows the name of the originating/lead lender in the participationABC FCUTextNoNo.
P7Sold PercentageIdentify the percentage of total participation loan the credit union sold90.999NumberNoNo.

Table 7—Residential Real Estate Loan Electronic Data Fields

NumberFieldDescriptionExampleData formatCurrent NCUA fieldILDR field
Includes all fields from Table 4: Consumer and Credit Card Loan Electronic Data Fields and the following:
R1Property TypeIndicate the property type (e.g., Single, Multi, Condominium, etc.)CondoTextNoNo.
R2Collateral StatePost office state code where collateral property is locatedAZTextNoNo.
R3Collateral CityCity where collateral property is locatedPhoenixTextNoNo.
R4Collateral CountyCounty where collateral property is locatedMaricopaTextNoNo.
R5Collateral Zip CodeZip code where collateral property is located85255NumberNoNo.
R6Property in Flood ZoneIndicator if the collateral securing the loan is in a designated flood zoneYY/NNoNo.
R7Draw PeriodRemaining period of time (in months) a borrower can withdraw funds from a credit account120NumberNoNo.
Start Printed Page 50457
R8Current Escrow BalanceAmount 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)2,585NumberNoYes.
R9Number of RenewalsIndicate the number of times the loan has been renewed2NumberNoYes.

Table 8—Commercial/Member Business Loan Electronic Data Fields

NumberFieldDescriptionExampleData formatCurrent NCUA fieldILDR field
Includes all fields from Table 4: Consumer and Credit Card Loan Electronic Data Fields and the following:
CL1Current Loan Risk Grade Commercial/MBLCredit union internal risk rating at recent review/evaluation of commercial/MBL; Number or letter grade determined based on the level of risk1TextNoYes.
CL2Date of Current Loan Risk Grade Commercial/MBLDate the most recent internal risk rating at recent review/evaluation of commercial/MBLs03312017DateNoYes.
CL3Debt Service Coverage Ratio (DSCR)Debt service coverage ratio calculated for the loan at origination1.05NumberNoNo.
CL4Personal guaranty statusIdentify the level of personal guaranty of the principals (e.g., full, limited, or none)FullTextNoNo.
CL5Environmental Review Level at originationIdentify the level of environmental review at origination (e.g., borrower questionnaire, record search, phase 1, or phase 2)Phase 1TextNoNo.
CL6Environmental Review DateDate of environmental review at origination03312017DateNoNo.
CL7Last Periodic ReviewDate of last periodic/annual file review03312017DateNoNo.
CL8Property TypeIndicate the property type (e.g., Single, Multi, Condominium, etc.)CondoTextNoNo.
CL9Collateral StatePost office state code where collateral property is locatedAZTextNoNo.
CL10Collateral CityCity where collateral property is locatedPhoenixTextNoNo.
CL11Collateral CountyCounty where collateral property is locatedMaricopaTextNoNo.
CL12Collateral Zip CodeZip code where collateral property is located85255NumberNoNo.
CL13Property in Flood ZoneIndicator if the collateral securing the loan is in a designated flood zoneYY/NNoNo.
CL14Draw PeriodRemaining period of time (in months) a borrower can withdraw funds from a credit account120NumberNoNo.
CL15Current Escrow BalanceAmount 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)2,585NumberNoYes.
CL16Policy ExceptionIndicator if the loan is an exception to policyYY/NNoNo.
CL17Number of RenewalsIndicate the number of times the loan has been renewed2NumberNoYes.
CL18Specific ReserveAmount of specific reserve for loan losses on this note which is not available to offset losses on any other loan50,000NumberNoYes.
Start Printed Page 50458

Table 9—Student Loan Electronic Data Fields

NumberNameDescriptionExampleData formatCurrent NCUA fieldILDR field
Includes all fields from Table 4: Consumer and Credit Card Loan Electronic Data Fields and the following:
S1Time to RepaymentFor deferred loans: Amount of time, in months, until repayment period begins65NumberNoNo.
S2Deferred StatusIndicator if student loan is in deferred statusYY/NNoNo.
Start Signature

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

Gerard Poliquin,

Secretary of the Board.

End Signature End Supplemental Information

Footnotes

1.  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.

Back to Citation

3.  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.

Back to Citation

4.  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.

Back to Citation

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

Back to Citation

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

Back to Citation

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

Back to Citation

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

Back to Citation

9.  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.

Back to Citation

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

Back to Citation

11.  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.

12.  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%.

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

14.  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%.

Back to Citation

15.  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.

Back to Citation

16.  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.

Back to Citation

17.  NIST Special Publication 800-53 (Rev. 4), Security and Privacy Controls for Federal Information Systems and Organizations.

Back to Citation

18.  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.

Back to Citation

19.  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.

Back to Citation

20.  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.

Back to Citation

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

Back to Citation

22.  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%.

Back to Citation

23.  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.

Back to Citation

24.  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.

Back to Citation

25.  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.

26.  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.

Back to Citation

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

BILLING CODE 7535-01-P