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5300 Frequently Asked Questions (FAQ)
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General Questions
Contact and Certification
Page (page 1)
Emergency Contact Page
(page 2)
Statement of Financial Condition
– Assets (pages 3-4)
Statement of Financial
Condition – Liabilities, Shares and Equity (pages 5-6)
Income and Expense (page7)
Miscellaneous Information
(page 8)
Delinquent Loans (page 9)
Loan Charge Offs and Recoveries
(page 10)
Liquidity, Commitments and Sources
(page 11)
Information Systems & Technology
(page 12)
PCA Net Worth Calculation
Worksheet (page 13)
Standard Components
of Risk Based Net Worth Requirement (page 14)
Schedule A – Specialized
Lending (pages 15-16)
Schedule B – Investments,
Supplemental Information (page 17)
Schedule C – Credit Union Service
Organization (CUSO) Information (page 16)
General Questions
How long should past copies of the call report be kept?
- Credit unions should print and sign a completed report, and retain a copy in their
permanent records. (These instructions are provided on the call report cover letter,
provided to the credit union each cycle.)
Contact and Certification Page (page
1)
1A. Can anyone at the credit union be appointed as the primary or secondary contact
for the credit union’s U.S.A. Patriot’s Act Information?
- No, only the individuals responsible for the Bank Secrecy Act and Customer Identification
programs at the credit union.
Emergency Contact Page (page 2)
2A. Can a credit union’s Disaster Recovery Center be the same location as its Vital
Records Center?
- Yes, a credit union’s Disaster Recovery Center and Vital Records Center can have
the same location. However, a P.O. Box is not an acceptable location for either
the Disaster Recovery Center or the Vital Records Center.
2B. Can a credit union’s Vital Records Center be the same as the credit union’s
main facility?
- No, Part 749 of the NCUA Rules and Regulations specifies that vital records must
be stored at a location far enough from the credit union’s office to avoid simultaneous
loss of both sets of records in the case of a disaster.
2C. Does an acceptable Disaster Recovery Test have to include shutting down and
restoring the computer systems at a hot site?
- No, there are several acceptable ways to test a disaster recovery plan. Information
on the different ways to conduct a disaster recovery test can be found in the 5300
instructions. More information on acceptable testing methods can be found in the
FFIEC Business Continuity Planning Booklet.
2D. If I use more than one settlement agent, which one should I report since there
is only space for one?
- Report the settlement agent that processes the most transactions for the credit
union.
Statement of Financial Condition – Assets (pages 3-4)
3A. Why won't the call report software permit me to enter a negative (credit) balance
for "Cash on Hand"? [Account 730A]
- "Cash on Hand" literally means coin, currency, and cash items on hand.
It is not possible to have negative cash on hand.
3B. Can loans other than real estate loans be reported in "Loans Held for Sale"?
[Account 003]
- Yes. Footnote 1 and Footnote 7 of the FFIEC Interagency Guidance on Certain Loans
Held for Sale explains that mortgage loans held for sale as well as other loans
held for sale should be included as discussed in the guidance. (Interagency guidance
issued March 26, 2001 & attached to NCUA Accounting Bulletin 01-01)
3C. Where should credit unions report overdraft protection program advances (also
referred to as bounced-check protection and courtesy pay)? [Account 397]
- Under "All Other Unsecured Loans/Lines of Credit". According to FFIEC
guidance, when overdrafts are paid by the credit union, credit is extended. Overdraft
balances should be reported on regulatory reports as loans. Accordingly, overdraft
losses should be charged off against the allowance for loan and lease losses. (FFIEC
Joint Guidance on Overdraft Protection Programs, issued February 18, 2005)
3D. Why won't the call report software permit me to enter a debit balance for "Allowance
for Loan & Lease Losses"? [Account 719]
- A debit ALLL balance is counterintuitive to GAAP guidelines and contrary to the
concept of an evaluation allowance for probable estimable losses.
3E. Why do the call report instructions direct us to report multi-coupon instruments
(step-ups) based on period remaining to maturity rather than the next step-up date?
- This data feeds into the credit union's Risk Based Net Worth (RBNW) calculation.
For PCA purposes, step-ups are risk-weighted at the period remaining to maturity.
(NCUA RR Part 702)
3F. Why do call report instructions direct us to report FHLB stock in the greater
than 1 year, but less than or equal to 3 year category? There is a 5 year notice
requirement from the FHLB.
- This data feeds into the credit union's Risk Based Net Worth (RBNW) calculation.
For PCA purposes, FHLB stock is risk-weighted at 6% (>1-3 year maturity). (NCUA
RR Part 702)
3G. Why is the maturity of membership capital (MC) and paid-in-capital (PIC) at
corporate credit unions limited to the greater than 1 year but less than or equal
to 3 year category? MC and PIC have a weighted-average life greater than 3
years.
- This data feeds into the credit union's Risk Based Net Worth (RBNW) calculation.
For PCA purposes, MC and PIC is risk-weighted at 6% (>1-3 year maturity). (NCUA
RR Part 702)
4A. If a credit union has repossessed collateral that has been written down to fair
value (less cost to sell), is it reported as delinquent on the call report? [Account
798A]
- No. The repossessed collateral should be written down to fair value (less cost to
sell) at the time of repossession. If the credit union intends to sell the repossessed
collateral, it should be moved out of loans and into "Foreclosed and Repossessed
Assets". There should be no delinquency balance remaining on the books when
moved because of the write down.
4B. In the instructions for "Foreclosed and Repossessed Assets", you refer
to but do not define "long-lived assets". What is a "long-lived asset?
[Account 798A]
- GAAP does not define "long-lived assets". Presumably they are depreciable
assets (automobiles, equipment and real estate) with a useful life in excess of
one year. An asset whose future benefit is expected for a number of years is also
called long-term asset.
4C. How do we treat lines of credit when reporting loans granted year-to-date? [Accounts
031A, 031B]
- Report 1 loan granted year-to-date for any line of credit (including credit card
loans) that has an advance on it in that year -- in any given year, the CU would
either report "1" (one or more advances in that year) or "0"
(no advances in that year). The amount reported would include all advances in that
year.
Statement of Financial Condition – Liabilities, Shares and
Equity (pages 5-6)
5A. We have implemented sweep programs involving share draft accounts and money
market accounts. Funds are swept between two subaccounts, a share draft subaccount
and a money market subaccount. Depending on the balances in the two subaccounts
on a particular day, we shift funds from the share draft subaccount to the money
market subaccount or vice versa. How should these sweep accounts be reported on
the call report?
- Funds must be reported where they reside. The share draft subaccount and money market
subaccount should be treated separately when a credit union reports its quarter-end
share information. Report share draft subaccount balances as share drafts. Report
money market subaccount balances as money market shares.
5B. We have an available line of credit at the FHLB which is based on percentages
of our stock ownership and real estate loan portfolio. How do we report this? [Accounts
883C, 881]
- FHLBs have varying borrowing programs. In the case of a line-of-credit, report
outstanding balances on page 3, line 1 Draws Against Lines of Credit and report
the total credit line on page 9, line 7a Total Credit Lines.
6A. What is reported in the applicable rows of the NCUA Insured Savings Computation?
- Report only the amount of uninsured shares and deposits. Do not include notes payable
or other forms of borrowings.
Income and Expense (page 7)
7A. For financial reporting purposes may credit unions net ATM fees and ATM expenses
on the Call Report or must they report gross ATM income and gross ATM expense in
the corresponding income and expense lines of the Call Report?
- A credit union must report gross ATM income in the income section of the income
statement and ATM expenses in the expenses section of the income statement; ATM
income and expenses may not be netted. The Call Report must be filed consistent
with generally accepted accounting principles (GAAP) and GAAP does not permit such
netting of ATM income and expenses. Netting of ATM income and expenses is an inappropriate
reporting practice that may provide an unfair advantage in ratio analysis or Unrelated
Business Income Tax (for Federally Insured State-Chartered Credit Unions only).
7B. Where do low-income designated federal credit unions report interest on deposits?
It is not under "Interest on Deposits" because this only applies to SCUs.
[Account 380]
- Under "Dividends on Shares". The Federal Credit Union Act authorizes low-income
designated FCUs to receive shares, share drafts, and share certificates from nonmembers.
The Act refers to these as shares, not deposits. We maintain the same nomenclature
in the call report. (FCU Act 107(6))
Miscellaneous Information (page 8)
If a credit union member has multiple accounts should these additional accounts
count towards the final “members” total on line 4?
- No, count only each member once, regardless of the number of accounts held by a
particular member.
Delinquent Loans (page 9)
How does a credit union with a member business loan that has real estate as the
collateral, report it on the delinquent loan schedule? Is there double counting?
The credit union would first report the loan in the applicable real estate delinquency
category. The same loan balance would then be reported on line 10 - Member Business
Loans excluding Agricultural loans. This line is one component of supplemental reporting
under the Additional Delinquency Information heading. The totals entered under this
heading do not count as additional delinquency totals for aggregate credit union
delinquency.
Loan Charge Offs and Recoveries (page 10)
10A. My CPA says GAAP requires timely and consecutive payments over a 3-month period
consistent with restructured terms before re-aging a troubled debt restructured
loan. Call report instructions require timely and consecutive payments over a 6-month
period. Which is it?
- Six months. NCUA call report instructions are consistent with the other banking
regulators. GAAP does not address delinquency reporting. (See FFIEC 031 and 041
Glossary, Nonaccrual Status, Page A-61)
10B. How does a credit union with a participation loan that has real estate as the
collateral, report it on the Loan Charge offs and Recoveries schedule? Is there
double counting?
- The credit union would first report the balance of the loan charge off in the applicable
real estate category directly under the heading titled Loan Loss Information. The
same loan balance would then be reported on line 20 – Participation Loans. This
line is one component of supplemental reporting under the Additional Loan Loss Information
heading. The totals entered under this heading do not count as additional charge
off totals for aggregate credit union charge offs.
Liquidity, Commitments and Sources (page 11)
11A. We offer a courtesy pay program where we do not return a member's NSF check
to the depositor but instead charge the member the NSF fee and give them a number
of days to make it good. There is no specific amount committed to a member for which
we will do this. How do we determine the amount of unfunded overdraft protection
program commitments? [Account 822]
- NCUA RR 701.21(c)(3) requires credit unions to establish a cap on the total dollar
amount of all overdrafts the credit union will honor. FFIEC guidance requires the
establishment of well-defined and properly documented dollar limit decision criteria.
Credit unions should report their cap amount minus any outstanding advances. (NCUA
RR Part 701.21(c)(3); FFIEC Joint Guidance on Overdraft Protection Programs)
11B. The instructions for "Loans Transferred with Recourse" tell us not
to include loan participations transferred with substantial recourse. Why? [Account
819]
- If a loan is transferred with "substantial recourse" per GAAP, the credit
union is required to keep the loan on its books. There would be a loan booked, but
no contingent liability.
11C. If a credit union uses an open-end loan form (such as Loanliner) for secured
loans, is the difference between the approved limit and the outstanding balance
reportable as an unfunded commitment? [Account 816]
- Yes. Credit unions using open-end loan forms should reported the difference between
approved limits and outstanding balances under “Other Unfunded Commitments”.
Information Systems & Technology (page 12)
12A. We have a printable form on our website that member’s can fill out and mail
or bring to the credit union to get a new loan, but it cannot be submitted electronically
through our website. Do I check the box on item 5 indicating that this is an electronic
service we offer?
- No. If the form is available to print, but still must be “physically” delivered
to the credit union, it is not an electronic service. This applies to Member Applications,
New Loans, and New Share Accounts.
12B. We have a debit card program, is that considered Electronic Cash on question
5?
- No. Electronic cash is stored on a variety of media and the amount of cash available
is stored on the card itself. Debit cards, credit cards and most gift cards rely
on sending information over networks to a centralized server to determine if the
amount of the transaction is available or not.
12C. We offer home banking through a link from our website to a third party vendor.
Since members do not directly perform transactions on our website, what type of
website should we report? [Account 892A]
- Transactional. Call report instructions indicate you should report based on the
degree of information and/or services you offer online. You are providing online
transactional services to your members via the third party.
PCA Net Worth Calculation Worksheet (page 13)
How can the optional Total Assets Elections on lines 9-11 benefit a credit union?
By using one of the optional total assets Elections as the Denominator in the net
worth calculation, a credit union may receive a higher net worth ratio. As a result,
a credit union could improve its net worth position to above 7% and not be subject
to PCA requirements if the standard net worth calculation was below 7%.
Standard Components of Risk Based Net Worth
Requirement (RBNW) (page 14)
14A. Are all credit unions subject to the RBNW requirement?
- No, a RBNW requirement is only applicable for those credit unions with assets greater
than $10 million and a RBNW requirement greater than 6%.
Schedule A – Specialized Lending (pages 15-16)
15A. When reporting number and amount of loans outstanding on the real estate loan
schedule, do we report based on original maturity, remaining maturity, or period
remaining until next adjustment?
- Report fixed-rate loans based on original maturity. Report balloons/hybrids based
on the period the original interest rate remains fixed. Report adjustable-rate loans
based on the adjustment period. These accounts capture product type. On the day
the loan was originated, how would you report it? – report it the same way as long
as it remains on the books.
15B. Should "table funded" loans be reported as loans sold in the secondary
market? [Account 736]
- No. Loans that are not funded by the credit union and at settlement are assigned
to the party advancing the funds should not be reported as loans sold. (See NCUA
RR Part 760 for a definition of table funded loan.)
15C. If a credit union participates out real estate loans, should the portion participated
out be reported as sold but serviced by the credit union? [Account 779A]
- Yes, as long as the credit union still services the loan. The account was added
in 2004 to identify linkages between loan servicing and associated fee income and
expenses.
15D. Account 712 captures the amount of real estate loans outstanding that will
contractually refinance, reprice or mature within the next 5 years. Do I also report
real estate loan cash flows over the next five years on loans not refinancing, repricing
or maturing in the next 5 years? [Account 712]
- No. Account 712 is used to calculate the amount of long-term real estate loans for
Risk Based Net Worth (RBNW) purposes. “Long-term real estate loans” is defined in
Part 702.104(a) of NCUA’s Rules and Regulations. The definition does not exclude
near-term cash flows on long-term real estate loans. Account 712 is also used to
calculate the ratio of net long-term assets. Reporting cash flows on long-term real
estate loans results in an underreporting of the credit union’s RBNW requirement
and ratio of net long-term assets.
16A. Account 718A asks for the portion reported as real estate loans on the real
estate loan schedule which are also reported as business loans on the business loan
schedule. Account 718 asks for the portion reported as real estate loans on the
real estate loan schedule which are business purpose loans that qualify for RBNW.
Do these accounts capture the same thing? [Accounts 718A, 718]
- No. 718A captures RE secured business loans based on the regulatory definition --
718A is used to calculate net long-term assets. 718 captures RE secured business
loans that qualify for RBNW -- 718 is used to calculate a credit union's RBNW requirement.
(Refer to NCUA RR Part 702 for a discussion of business loans as they relate to
PCA).
16B. A credit union has $35,000 in business purpose loans to
a member and makes a $40,000 business purpose loan to the same member. How much
does the credit union report as a member business loan -- $40,000, $25,000, or $75,000?
[Account 400A]
- $40,000, and the credit union would comply with all of the requirements of Part
723 in making this loan because the loan caused the aggregate amount of business
purpose loans to the member to exceed the $50,000 threshold in RR 723.1(b)(3). (Federal
Register / Vol. 68, No. 190)
16C. The instructions for Account 400 (loans and participation interests qualifying
for RBNW) indicate we should include portions of business loans that are guaranteed
by any agency of the federal government, a state or any political subdivision of
such state. However, based on the regulatory definition, these guaranteed portions
are excluded as business loans. Aren't the call report instructions providing conflicting
instructions? [Account 400]
- No, the instructions are accurate. Loans that are fully guaranteed by a federal
or state agency are not considered member business loans, and would not be reported
in Account 400. However, if the loan is partially guaranteed (such as SBA loans),
the portion that is partially guaranteed is excluded from the regulatory net business
loan balance but included for RBNW purposes. The loan must meet the regulatory $50,000
threshold before it is reported as a member business loan, or reported for RBNW
purposes. Once a loan is deemed to be a member business loan, the outstanding balance
of the member business loan (including any guaranteed portions) must be risk-weighted
until the loan is paid off. (NCUA RR Part 702)
Schedule B – Investments, Supplemental Information (page 17)
17A. Once an investment passes the last call date, is it still reported as an investment
with an embedded option? [Account 786A]
- No. Once the final call passes, the investment no longer has an embedded option
associated with the call feature. (NCUA RR Part 703.2 and 703.12(b))
17B. Are CDs purchased through the SimpliCD program reported as brokered CDs on
the call report? [Account 788]
- Yes. SimpliCDs are not direct purchases and therefore should be reported as brokered
CDs on the call report.
Schedule C – Credit Union Service Organization (CUSO) Information
(page 18)
18A. What is a Tax ID Number?
A tax id number is a number issued to a business by the Internal Revenue Service.
It is a nine digit number whose format is ## - #######. If you don’t know the CUSO’s
tax ID number, you should contact the CUSO to get their tax ID number. Do not leave
this blank. Do not use someone’s social security number as the Tax ID number.
18B. Does my CUSO have to have a Tax ID Number?
State regulations may vary, but under NCUA Rules and Regulations Part 712, a CUSO
that is owned or invested in by a Federal Credit Union must be organized as a corporation,
limited liability company or limited partnership. These types of corporate entities
are required to have a Tax ID number issued by the IRS. The IRS permits a sole proprietorship
or a self-employed individual to use a social security number as a Tax ID.