Find answers below to frequently asked questions about the NCUA's 5300 Call Report.
For information about the March 2022 Call Report changes, view the following video:
How long must I keep copies of the 5300 Call Report?
Part 749 of the NCUA regulations requires credit unions to keep either a hard copy or an electronic copy in their permanent records.Close and return to top
Do I have to certify my Profile before I correct a 5300 Call Report?
The Profile must be certified before you can submit corrections to a 5300 Call Report.Close and return to top
Is NCUA waiving late filing fees for the March 2022 cycle?
The NCUA is not imposing civil money penalties for the March 2022 Call Report cycle.Close and return to top
Will the quarterly download file that lists account codes and descriptions (AcctDesc.txt) be updated to identify the disposition of specific account codes (e.g., Retire & Replaced)?
Beginning with the March 2022 Call Report cycle, the account description text file (AcctDesc.txt) has been modified to identify the Active and Inactive accounts but the text file will not identify a replacement account. For March 2022, that information is available in the Account Catalog. In future quarters, replacement information will be available in the 5300 Changes document.Close and return to top
Is there a document that shows the account code changes that took place in March 2022? Also, sometimes an account code will change from a 3 digit number to something longer like six characters.
The Account Code Catalog, available from the 5300 Call Report - Changes link on the CUOnline page of NCUA.gov, shows account changes. All account codes assigned since March 2018 have had 6 alphanumeric characters.Close and return to top
Is the Commercial Loan definition the same across the entire Call Report?
The commercial loan definition is consistent for all Call Report Schedules EXCEPT Schedule I. For Schedule I see the definition in 702.2: Commercial loan means any loan, line of credit, or letter of credit (including any unfunded commitments) for commercial, industrial, and professional purposes, but not for investment or personal expenditure purposes. Commercial loan excludes loans to CUSOs, first- or junior-lien residential real estate loans, and consumer loans. For the remaining Call Report schedules, see the definition in 723.2.Close and return to top
Statement of Financial Condition
Why won't the Call Report permit me to enter a negative (credit) balance for "Cash on Hand"? [Account 730A]
"Cash on Hand" means coin, currency, and cash items on hand. It is not possible to have negative cash on hand.Close and return to top
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. (The NCUA regulations part 702)Close and return to top
Why do the 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 but < = 3 years). (The NCUA regulations part 702)Close and return to top
Can I report loans, other than real estate loans, as "Loans Held for Sale"? [Account 003]
Where should credit unions report overdraft protection program advances (also referred to as bounced-check protection and courtesy pay)? [Account 397]
You should report these advances under "All Other Unsecured Loans/Lines of Credit." According to the Joint Guidance on Overdraft Protection Programs transmitted with Letter to Credit Unions 05-CU-03, when the credit union pays overdrafts, credit is extended. You should report overdraft balances as loans. Accordingly, you should charge off overdrafts against the allowance account.Close and return to top
Why won't the call report software permit me to enter a debit balance for "Allowance for Loan & Lease Losses" or “Allowance for Credit Losses”? [Accounts 719 and AS0048]
A debit allowance balance does not comply with GAAP guidelines and is contrary to the concept of an allowance for losses.Close and return to top
If a credit union repossessed collateral and has written it down to fair value (less cost to sell), is it reported as delinquent on the call report? [Account 798A]
No. The credit union should write down the repossessed collateral to fair value (less cost to sell) at the time of repossession. If the credit union intends to sell the repossessed collateral, you should move it out of loans and into "Foreclosed and Repossessed Assets." There should be no delinquency balance remaining on the books when moved out of loans because of the write down.Close and return to top
In the instructions for "Foreclosed and Repossessed Assets," you refer to "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.Close and return to top
I’d like to get some specificity about how to report 457F plan investments (used to fund employee benefits). Can you provide guidance with respect to what practical expedients can be utilized to determine if the various investments are part 703 compliant?
If they are securities, 457F investments are reported on the Statement of Financial Condition as either equity securities, trading debt securities, available-for-sale securities, or held-to-maturity securities. Additionally, 457F investments are reported in Schedule B by security type with additional valuation information included. 457F investments that are non-securities will be reported on other sections of the Statement of Financial Condition, consistent with generally accepted accounting principles. Lastly, 457F investments are also reported on Schedule B, Section 4, line 11 by type listed.
As for determining if investments are part 703 compliant, credit unions can refer the subpart A of part 703 and the FCU Act, specifically §§ 1757 (7), (8) and (15).Close and return to top
Where should regular reserves be reported: undivided earnings or other reserves?
Report regular reserves in Undivided Earnings (account 940).Close and return to top
Do I have to report my non-negotiable certificates of deposit at fair value?
No. Non-negotiable certificates of deposit are reported in the Cash and Deposit section of the Call Report. They are not reported in the Investment Securities section of the Statement of Financial Condition. Non-negotiable certificates of deposit do not need to be reported on Schedule A, Section 1 or 2. Non-negotiable certificates of deposit are reported on Schedule A, Section 3, item 1 in the appropriate maturity category.Close and return to top
Was "Investments with original maturities of 3 months or less" removed from the Cash section?
Yes, with the retired account 730C, Cash Equivalents (Investments with Original Maturities of Three Months or Less), these items are likely reported in account AS0008, Other Deposits, because "Investments with Original Maturities of Three Months or Less" should be included in the Total Cash and Other Deposits, AS0009. Also, consider whether the amounts previously reported in 730C represented Time Deposits in commercial banks, S&Ls, savings banks, natural person credit unions, or corporate credit unions with maturities of three months or less. If so, these would be reported in Time Deposits in account AS0007 and also on the Maturity Distribution Schedule, Schedule B, Section 3.Close and return to top
CECL requires implementation for fiscal year ends starting after December 15 of 2022. For a credit union that has a fiscal year-end of September 30th when do we have to begin reporting on the Call Report?
Recently the NCUA's Office of General Counsel interpreted the term "fiscal year" as used in the NCUA Board's July 2021 final rule. OGC determined there is no statutory or regulatory requirement that the term "fiscal year" as used in the CECL Transition Rule be interpreted to mean "calendar year" (or vice versa). For FCUs, CECL is implemented at the start of the financial statement reporting year that begins after December 15, 2022. For example, for a financial statement reporting year ending on September 30, 2023, CECL will be implemented on October 1, 2023. For the NCUA's CECL Transition Rule, the phase-in of the day-one effects on the net worth ratio would also start on October 1, 2023.Close and return to top
Can credit unions get an exemption from complying with CECL?
Federal credit unions with $10,000,000 or less in assets do not have to comply with GAAP and, therefore, will not have to comply with CECL. State chartered credit unions will need to consult with their state regulatory authority.Close and return to top
Our credit union owns 70% of a CUSO and the other 30% investment is classified as non-controlling equity. Where is this reported on the Call Report?
In Account 996 on page 3.Close and return to top
Are repossessed mobile homes, where land is not included in the repossessed collateral, considered repossessed real estate or repossessed "other"?
It would be considered as "other" if the mobile home does not qualify as real estate by the laws in your state. Once the property type, personal or real estate, is determined, based on the specifics of the transaction and the laws, then report accordingly.Close and return to top
How should we report overdrawn share accounts?
You should report overdrawn non-commercial share accounts of all types, regardless of the existence of an overdraft protection program for share draft accounts, in Schedule A, Section 1, line 4 - All Other Unsecured Loans/Lines of Credit (Accounts 994 and 397).
Overdrawn commercial share accounts of all types that qualify as a commercial loan should be reported in Schedule A, Section 1, line 13. An overdrawn commercial share account is generally reported as an unsecured commercial loan unless the aggregate outstanding balances plus unfunded commitments less any portion secured by shares in the credit union to a borrower or an associated borrower, are equal to less than $50,000, in which case you would report it with all other overdrawn non-commercial share accounts.Close and return to top
Are there specific requirements needed to report member deposits in which the member is an agent, holding funds for another entity or entities? Or should they be reported as general member deposits?
Deposits where the member is an agent holding funds for another entity or entities are not distinguishable from other similar types of deposits. They should be reported as outlined in Call Report Instructions for Page 3, Shares/Deposits.Close and return to top
Statement of Income and Expense
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. You should not net the ATM income and expenses.Close and return to top
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]
You should report interest on deposits 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 FCU Act refers to these as shares, not deposits. We maintain the same nomenclature in the Call Report. (FCU Act §107(6)).Close and return to top
With adopting ASC 842 (Leases), where is an Operating Lease expense included on page 5 of the Call Report?
Operating Leases: Under ASC 842 (Leases), the idea of an Operating Lease remains, but the expense becomes a single amount representing the depreciation (amortization) of the Right-of-Use asset and the Interest component of the Lease liability. This single lease amount is generally recognized on a straight-line basis. If related to office occupancy, such as office space lease, the amount is usually recorded to OFFICE OCCUPANCY EXPENSE (ACCOUNT 250). If related to office operations, such as a copier, the amount is usually recorded to OFFICE OPERATIONS EXPENSE (ACCOUNT 260).Close and return to top
With adopting ASC 842 (Leases), where are the Financing Lease expenses included on the Call Report?
Financing Leases: Under ASC 842 (Leases), a Financing Leases continues to have two expenses. The amount representing the depreciation (amortization) of the Right-of-Use asset is reported on the line item related to its propriety. If related to office occupancy, such as an office space lease, the amount is usually recorded to OFFICE OCCUPANCY EXPENSE (ACCOUNT 250). If related to office operations, such as a copier lease, the amount is usually recorded to OFFICE OPERATIONS EXPENSE (ACCOUNT 260). The amount representing the Interest component of the Lease liability is recorded to INTEREST ON BORROWED MONEY (ACCOUNT 340).Close and return to top
Under ASC 842 (Leases), does the Call Report distinguish where to report deprecation related to Financing Leases: 1) for a Building; and 2) for Operating Equipment (e.g., copier)?
Yes - The amount representing the depreciation (amortization) of the Right-of-Use asset is reported on the line item related to its propriety. If related to office occupancy, such as an office space lease, the amount is usually recorded to OFFICE OCCUPANCY EXPENSE (ACCOUNT 250). If related to office operations, such as a copier lease, the amount is usually recorded to OFFICE OPERATIONS EXPENSE (ACCOUNT 260).Close and return to top
Schedule A, Section 1 - Loans
How do we treat lines of credit when reporting loans granted year-to-date? [Accounts 031A, 031B]
Lines of credit and credit card loans should only be counted as a new loan in the period they are granted or renewed, not each subsequent draw on the open line of credit. Credit decisions to increase a line of credit should be treated as a new loan.Close and return to top
Do lines 9 through 12 on Schedule A section 1 still have to tie to the real estate section total which is Schedule A section 7?
Most sections of Schedule A have to tie back to the amounts reported on Schedule A, Section 1, page 6. Lines 9 – 11 of Section 1 of Schedule A and Section 7 of Schedule A have to tie.Close and return to top
If a loan was modified in Section 4013 of the CARES Act but the modification term has ended, is the loan still reported on Schedule A, Section 1, Line 18?
Section 4013 is applicable for the term of the loan modification. Loan modifications include forbearance, an interest rate modification, and any other similar arrangement that defers or delays the payment of principal or interest. Once the term of a loan modification ends, credit unions should no longer report the loan in Schedule A, Section 1, Line 18.Close and return to top
For Loans Granted Year-to-Date (Schedule A, Section 1, Line 15) should the first draw on the line of credit in the current year be reported as a new loan ONLY if the draws were NOT taken in the prior year? Or should every first draw in the year on a line of credit be considered a "Loan Granted Year-to-Date"?
The number and amount granted or purchased year-to-date should include the total number and amount plus unfunded commitments at the time of purchase or origination. Include all loan types granted, including real estate loans sold on the secondary market, loans held for sale, and participation loans in which you are participating. Lines of credit and credit card loans only count as a new loan in the period that they are granted or renewed. This does not include each subsequent draw on the open line of credit. Credit decisions to increase a line of credit should be treated as a new loan.Close and return to top
Schedule A, Section 1 uses the same outstanding balance accounts used in the prior Call Report (703A and 386B). We included loans in process in this total in the past. Are they still included?
The balances reported in Accounts 025A1 and 025B1 on Schedule A, Section 1 must agree to the amounts reported in Accounts 025A and 025B on the Statement of Financial Condition. The balances reported in Accounts 703A, 386A, and 386B on Schedule A, Section 1, must agree to the amounts reported in Accounts RL0016, RL0017, RL0030, RL0031, RL0044 and RL0045 on Schedule A, Section 7. If loans in process are appropriately reported in the Statement of Financial Condition then they should be included in Schedule A, Sections 1 and 7.
The instructions for Schedule A, Section 1 provide clarification. For each loan category, report only loans that have an outstanding balance. Loans should be reported net of loan origination fees/costs which shall be recognized over the life of the related loan as a yield adjustment. Additionally, loan fees, certain direct loan origination costs, and purchase premiums and discounts on loans should be recognized as an adjustment to yield based on the contractual terms of the loan.Close and return to top
Schedule A, Section 2 - Delinquent Loans
How does a credit union with a commercial loan that has real estate as the collateral, report it on the delinquent loan schedule? Is there double counting?
Delinquent commercial loans are reported in Schedule A, Section 2 - Delinquent Loans & Leases. Look for the part of this section specific to Commercial Loans and report delinquent Commercial Loans based on the collateral securing the loan. Only those delinquent loans included in Account 041B will be included in the delinquent loan ratio.Close and return to top
Would all outstanding loan balances affected by bankruptcy or only the bankruptcies that are outstanding AND that were filed in the current year be reported on Schedule A, Section 2, Item 25, Account 971 - Total Outstanding Balances of Loans Affected by Bankruptcy?
Outstanding loan balances of all borrowers affected by bankruptcy should be reported. Not just borrowers that filed for bankruptcy in the current year. This includes reaffirmations but excludes bankruptcies that have been dismissed by the court.Close and return to top
Are loan participation delinquencies and charge offs and eligible obligations delinquencies and charges offs reported on the Call Report?
Yes, delinquency, charge offs, and recoveries are reported for Participation Loans Purchased under 701.22 and Whole or Partial Loans Purchased under 701.23 (eligible obligations). For Participation Loans, report delinquency in Account DL0142. For whole or partial loans purchased under 701.23, report delinquency in Account DL0144. Participation loans and eligible obligation delinquencies should also be reported on Page 7, Lines 1-20 based on the underlying collateral. See FAQ Topic Schedule A, Section 3 - Loan Charge Offs and Recoveries for questions related to participation loan and eligible obligations charge offs and recoveries.Close and return to top
On the Delinquency schedule we are not seeing an item for reporting the Commercial 1- to 4-Family Loans (Multiple 1- to 4-Family Residential), where should we report these?
You're correct. There's no item for reporting 1- to 4-family residential loans in the commercial section. That is because we separated 1- to 4-family from commercial. The only time you could potentially have 1- to 4-family loan as a commercial loan would be if you had multiple 1- to 4-family residential properties securing one loan. In that case, these would generally be reported as multifamily (Schedule A, Section 2, Item 14).Close and return to top
Schedule A, Section 3 - Charge-Offs/Recoveries
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 report the participation loan charge-off or recovery in Schedule A, Section 3 - Loan Charge Offs and Recoveries based on the collateral securing the participation loan. The same amount would need to be reported in Account 550F, if a charge off, or Account 551F, if a recovery. The amounts reported in Account 550F or 551F do not affect the net charge-off ratio.Close and return to top
Are loan participation charge offs and eligible obligations charge offs reported on the Call Report?
Yes, delinquency, charge offs, and recoveries are reported for Participation Loans Purchased under 701.22 and Whole or Partial Loans Purchased under 701.23 (eligible obligations). For Participation Loans, report charge offs in Account 550F and recoveries in 551F. For whole or partial loans purchased under 701.23, report charge offs in Account CH0047 and recoveries in Accounts CH0048. Participation loans and eligible obligation charge offs and recoveries should also be reported on Page 8, Lines 1-20 based on the underlying collateral. See FAQ Topic Schedule A, Section 2 - Delinquency Loans & Leases for questions related to delinquent participation loans and eligible obligations.Close and return to top
Schedule A, Section 6 - Loans Purchased and Sold Under 701.22 and 701.23
Should I report "table funded" loans 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 the NCUA rules and regulations Part 760 for a definition of table funded loan.)Close and return to top
If a credit union participates out real estate loans, should I report the portion participated out as real estate loans sold with servicing retained by the credit union? [Accounts SL0028, SL0029, SL0030, and 779A]
Yes. You should report the real estate loans as sold with servicing retained as long as the credit union still services the loans.Close and return to top
The instructions for "Loans Transferred with Limited Recourse Qualifying for Sales Accounting" tell us not to include participations transferred with substantial recourse. Why? [Account 819]
If you transfer a loan with "substantial recourse" per GAAP, the credit union is required to keep the loans on its books. You would record a loan, but no contingent liability.Close and return to top
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 816B5]
Yes. Credit unions using open-end loan forms should report the difference between approved limits and outstanding balances under “Other Unfunded Commitments.”Close and return to top
Are the same numbers that are reported under year-to-date on Schedule A, Section 6, lines 6 and 7 copied to the outstanding part?
The number and amount sold year-to-date for real estate loans sold with servicing retained and all other loans sold with servicing retained would be for the loans sold in the current year. The number and amount sold outstanding would include loans sold in previous years that your credit union is still servicing. For amount outstanding report the outstanding balance as of the reporting date for loans the credit union sold but is still servicing.Close and return to top
Can you explain the definition and the differences between Participation Loans Purchased under 701.22 and Whole or Partial Loans Purchased Under 701.23? Can you provide examples of each?
Yes, we have received a number of questions on loans purchased under section 701.22 and 701.23. There's additional nuance to this and I would refer you to the Call Report Instructions and the NCUA regulations.
In general, participations would only apply to the purchase of a loan from the originator where there's a continuing contractual obligation between the purchaser and seller. Section 701.22 of the NCUA regulations also outline some additional seller retention requirements and minimum requirements for a participation agreement. As an example, let's assume that your credit union purchased a 90% participation interest in a loan. The originating credit union would be maintaining a 10% interest in that loan through the loan's life and the originating credit union is going to be servicing that loan. In this case you would report this as a participation purchased.
Section 701.23, would generally apply when there is not a continuing contractual obligation between the purchaser and seller.Close and return to top
What would be reported on Schedule A, Section 6, Loans Sold? Would mortgage loans be included? Or other types of loans? What would go in the outstanding part?
It is possible for a single loan to be reported on multiple lines of the Loans Sold section. Loans sold must be reported on one or more lines based on the type of loan and terms of the agreement. For example, the sale of a first lien residential mortgage loan where the servicing is retained would be reported on Schedule A, Section 6, Line 6. Do not include participation loans sold. Report All Other Loans Sold with Servicing Retained, such as auto loans, on Schedule A, Section 6, Line 7. Do not include participation loans sold.Close and return to top
Schedule A, Section 7 - 1- to 4-Family Residential Real Estate Loans
When reporting the 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.Close and return to top
Account RL0050 captures the amount of real estate loans outstanding that contractually refinance, reprice or mature within the next five years. Do I also report real estate loan cash flows over the next five years on loans not refinancing, not repricing or not maturing in the next five years? [Account RL0050]
No. The NCUA uses account RL0050 in the net long-term assets calculation. Reporting cash flows on long-term real estate loans results in an underreporting of the credit union’s ratio of net long-term assets.Close and return to top
Page 11 states to report loans sold on the secondary market but this has to equal section 9 page 6. We deduct the sold loans from our balance sheet general ledger for mortgage loans, so how do leave these off page 11?
Page 11 says to report real estate loans sold on the secondary market as part of the dollar amount of loans/lines of credit granted year-to-date only. You should also report these loans on page 6, line 15, along with all other loans granted year-to-date. They do not have to be reported as part of Number or Amount of Loans Outstanding.
The parts of page 11 that have to agree to page 6 are:
Page 11, Item 4, Account RL0016, has to agree to Page 6, Item 9, Account 703A
Page 11, Item 7, Account RL0030, has to agree to Page 6, Item 10, Account 386A
Page 11, Item 10, Account RL0044, has to agree to Page 6, Item 11, Account 386B
Please define "1- to 4-family residential real estate". What if a commercial loan is collateralized by a 1- to 4-family residential property? Where would you report a single 1- to 4-family residential property that is being used for business purposes go? Is it different if it's over or under $50,000?
Residential property means a house, condominium unit, cooperative unit, manufactured home, or the construction thereof, and unimproved land zoned for a 1- to 4-family residential use. Residential property excludes boats or motor homes, even if used as a primary residence, or timeshares. To be considered a 1- to 4-family residential property loan, the property securing the loan must be considered real property within the jurisdiction of the collateral.
A loan secured by a single 1- to 4-family residential property (whether or not secured by a member’s primary residence) would not be reported as an MBL or a commercial loan. It would be reported in Schedule A, Section 7 as a 1- to 4-family residential property loan, part of the non-commercial loan reporting.
However, a single loan that is secured by more than one 1- to 4-family residential properties where the outstanding balances plus unfunded commitments is equal to or greater than $50,000 should generally be reported as a member business loan AND commercial loan. (Note that loans to non-members should only be reported as commercial loans.)Close and return to top
Schedule A, Section 8 - Commercial Loans
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, $35,000, or $75,000? [Account 400A]
The credit union would report $40,000, and 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 the NCUA rules and regulations §723.8.Close and return to top
Where do we report loans that would be commercial loans except that the commercial purpose lending relationship has an outstanding aggregate balance below $50,000? [Various Accounts]
These loans are not Commercial Loans as defined in the NCUA regulations §723.2 and as such you will report them as you would any other Non-Commercial loan based on the loan characteristics in the various schedules.Close and return to top
Can the same loan be both a Commercial Loan and a Member Business Loan? [Accounts 400A1, 400B1, 400A]
Yes. The definition of Commercial Loan and Member Business Loan are both distinct and not mutually exclusive. Attention must be paid to the specific definitions of each. Commercial Loans and Member Business Loans are defined in the NCUA rules and regulations §723.2 and §723.8 respectively. See the quick reference chart below:
|Type of Loan||Member Business Loan||Commercial Loan|
|Loan secured by a single 1- to 4-family residential property (whether or not secured by a member’s primary residence)||No||No|
|Loan secured by more than one 1- to 4-family residential properties||Yes||Yes|
|Business loan secured by a vehicle manufactured for household use||Yes||No|
|Business loan secured by a vehicle used in a fleet or to carry fare-paying passengers||Yes||Yes|
|Business loan with aggregate net member business loan balance less than $50,000||No||No|
|Business loan fully secured by shares in the credit union making the extension of credit or deposits in other financial institutions||No||No|
|Business loan in which a federal or state agency (or its political subdivision) fully insures repayment, fully guarantees repayment, or provides an advance commitment to purchase the loan in full||No||Yes|
|Non-member business loan or non-member participation interest in a commercial loan made by another lender||No||Yes|
Once a loan is classified as a Commercial Loan is it then always a Commercial Loan even if the balance falls below $50,000? [Account 400A1 or 400B1]
No. These loans are no longer Commercial Loans. Likewise, they are no longer Member Business Loans.Close and return to top
Account CM0099 captures the amount of real estate loans outstanding that contractually refinance, reprice, or mature within the next five years. Do I also report the real estate loan cash flows over the next five years on loans not refinancing, not repricing, or not maturing in the next five years? [Account CM0099]
No. The NCUA uses account CM0099 in the net long-term assets calculation. Reporting cash flows on long-term real estate loans results in an underreporting of the credit union's ratio of net long-term assets.Close and return to top
What if a commercial loan is collateralized by a 1- to 4-family residential property? Do we still reclassify those to 1- to 4-family residential loans in the consumer section?
"A loan to a member secured by a SINGLE 1- to 4-family residential property used for business purposes would NOT be reported as a commercial loan. It would be reported as a 1- to 4-family residential property loan; part of the non-commercial loan reporting.
A loan to a member secured by more than one 1- to 4-family residential properties where the outstanding balance plus unfunded commitments is equal to or greater than $50,000 would be reported as a member business loan AND commercial loan whether or not the properties are used for business purposes. There is no crossover reporting for real estate loans. A loan to a non-member would NOT be reported as a member business loan and would only be reported as a commercial loan."Close and return to top
Schedule B, Section 1 and Section 2
On Schedule B of the March 2022 Call Report, Federal Agency Securities are divided between Guaranteed vs. Non-Guaranteed and again between Debt Instruments vs. Non-Debenture Instruments. These distinctions were not present on the historical Call Report. Can you provide examples of the types of securities you expect to be reported in each of these report lines?
Yes, these are new to the Call Report. Here are some examples of what you might report on these lines:
- Federal Agency Securities/Guaranteed - Debt - FNMA Debenture, TVA Debenture.
- Federal Agency Securities/Guaranteed - Non-Debt - FNMA Pass Through.
- Federal Agency Securities/Non-Guaranteed - Debt - We do not believe these exist. This field exists in case this type of non-guaranteed debt is ever issued.
- Federal Agency Securities/Non-Guaranteed - Non- Debt - Non-guaranteed subordinated tranches issued by a GSE. For example Freddie-K subordinated tranche. Also, FNMA or FHLMC credit-risk transfer securities would be include in Federal Agency Securities/Non-Guaranteed - Non-Debt.
How should ABS with guaranteed student loan collateral be reported? As Federal Agency Securities or Other ABS?
If a securitization, ABS with guaranteed student loan collateral should be reported in non-federal agency asset backed securities. If issued by a state corporation in a revenue bond structure, they should be reported as Securities Issued by States and Political Subdivisions in the U.S.Close and return to top
Schedule B, Section 4 - Investments - Memoranda
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.Close and return to top
Schedule C, Section 1 - Unfunded Commitments
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 822C]
The NCUA regulations §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. (The NCUA RR §701.21(c)(3); FFIEC Joint Guidance on Overdraft Protection Programs).Close and return to top
Schedule C, Section 1 through 5 - Liquidity
We have an available line of credit at the FHLB based on percentages of our stock ownership and real estate loan portfolio. How do we report this? [Accounts 883C, 881]
The FHLB has various borrowing programs. In the case of a line-of-credit, report outstanding balances on, the Statement of Financial Condition in Account 860C - Borrowings. The maturity distribution of the draws against the line-of-credit should be reported on Schedule C, Section 5 - Borrowing Maturity Distribution in Accounts 883A, 883B1, and 883B2 - Draws Against Lines of Credit. Also, report the total credit line on Schedule B, Section 4 - Borrowing Arrangements in Accounts LQ0040, 885A3, LQ0042 and LQ0043.Close and return to top
Securities Borrowing or Lending Transactions reported in Schedule C, Section 2, item 9. Is this referring to securities owned by the credit union that have been pledged to secure credit union borrowings or available credit sources? Or is this referring to securities pledged as collateral for loans the credit union has granted to members?
"This line is not referring to securities owned by the credit union that have been pledged to secure credit union borrowings or available credit sources, nor is it referring to securities pledged as collateral for loans the credit union has granted to members.
Securities lending and borrowing activities are done for a fee and not to pledge as collateral for a loan. Securities Lending means lending a security to a counterparty, either directly or through an agent, and accepting collateral in return. Securities Borrowing means borrowing a security from a counterparty, either directly or through an agent."Close and return to top
My credit union has $50 million in securities pledged to the Federal Reserve Bank to secure borrowing capacity of $45 million. Where do we report the $50 million and the $45 million?
If you do not have an outstanding balance at the FRB, then report the borrowing capacity of $45M in Account LQ0059 (Schedule C, Section 4, Item 3). If you have an outstanding balance at the FRB, report the outstanding balance in Account LQ0046 and the assets pledged to secure the outstanding balance in Account LQ0047. If the amount borrowed is not the full borrowing capacity, report the difference in LQ0059. The instructions would be the same if the assets are pledged to the Federal Home Loan Bank, except the outstanding balance would be reported in Account LQ0042 and the assets pledged would be reported in Account LQ0043.Close and return to top
We have borrowing capacity with the FHLB. We've taken advances against the borrowing capacity and those borrowings have final due dates, interest only payments, and could have pre-payment penalties. Where should this be reported?
The advances against your borrowing capacity with the FHLB sound like term advances. The Line of Credit column is for advances against a revolving line of credit so these advances would not be reported in this column. On Schedule C, Section 4, Borrowing Arrangements (page 18), report advances under Outstanding Term and Other Borrowings, Account LQ0042. On Schedule C, Section 5, Borrowing Maturity Distribution (page 18), report under Promissory and Other Notes (Item 2) in the appropriate maturity range for the note.Close and return to top
Schedule D, Section 1 - Number of Members
If a credit union member has multiple accounts, should these additional accounts count towards the number of current members?
No. You should count each member only once, regardless of the number of accounts held by a particular member.Close and return to top
Schedule D, Section 2 - Shares/Deposits
We 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 we report these sweep accounts on the Call Report?
You must report funds where they reside as of the cycle end date. Report share draft subaccount balances as share drafts. Report money market subaccount balances as money market shares.Close and return to top
Schedule D, Section 3 - NCUA Insured Savings Computation
What do I report in the NCUA Insured Savings Computation section?
Report only the amount of uninsured shares and deposits. Do not include notes payable or other forms of borrowings.Close and return to top
Schedule G - PCA Net Worth Calculation Worksheet
How can the optional Total Assets Elections on lines 10-12 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 is below 7%.Close and return to top
Where do I report Subordinated Debt included in Net Worth that used to be reported in Account 925A?
Report Subordinated Debt included in Net Worth in Account 925A on Schedule G. All subordinated debt, regardless of whether it is included in net worth, should also be reported on Schedule C, Section 5, Line 4, and on the Borrowings line in Account 860C on page 3.Close and return to top
Schedule H - Complex Credit Union Leverage Ratio (CCULR) Calculation
Does the qualification criteria for CCULR auto populate or do these have to be input?
There are four qualifying criteria. The first one is the CCULR ratio which is equal to the net worth ratio. In order to opt in to CCULR the net worth ratio must be 9% or greater. The net worth ratio will auto populate. The second criteria is the total Off-Balance Sheet Exposures. Off-Balance Sheet Exposures will be auto populated and the percentage, the ratio of those to total assets, will be auto calculated. The third criteria is the sum of Trading Assets and Trading Liabilities. That is a manual entry and the ratio of that sum to total assets is auto calculated. Finally, the fourth criteria, the sum of goodwill and other intangible assets is also a manual entry, the ratio of that sum to the total assets will be auto calculated.Close and return to top
Schedule I - Risk Based Capital (RBC) Ratio Calculation
Per the instructions for Schedule A, Section 1 of the Call Report and §723.2, SBA Paycheck Protection Program (PPP) loans are excluded from the definition of commercial loans. The Schedule A, Section 1 instructions also clearly indicate that PPP loans should be reported in account 397 as other unsecured loans. However, the instructions for Schedule I, Part II, line 25 require PPP loans to be reported as commercial loans which is in direct contradiction to the Schedule A, Section 1 instructions and §723.2.
Not only does this impact the internal consistency of the Call Report, but it will also require CUs to perform the unnecessary step of adjusting the totals of consumer loans and commercial loans on Schedule I, Part II. It would be more consistent and logical to report PPP loans in account RB0063 because PPP loans are reported in account 397 which rolls up under consumer loans for RBC purposes. Please consider revising the Call Report instructions or provide an explanation for this inconsistency.
There are intentional classification differences between the RBC schedule and the rest of the Call Report schedules. This is because, by regulation, some items are categorized differently for Call Report purposes and for RBC purposes. PPP loans are a good example. PPP loans are not considered commercial loans on Schedule A (Loans) of the Call Report because the definition of commercial loan in part 723 specifically excludes PPP loans. However, PPP loans are considered commercial loans on Schedule I (RBC) of the Call Report. Please review the Call Report Instructions for Consumer and Commercial loans reported on Schedule I, Part II for the proper treatment.Close and return to top
The Call Report Instructions state that, if not using the look-through approach, part 703 compliant investment funds (§702.104(c)(2)(v)(B)(3)) should be reported in both account RB0023 (Securities 100 percent risk weighted) and RB0032 (Other Investments 100 percent risk weighted). Which is correct?
They are both correct. One is for investment funds that are securities and the other is for investment funds that are non-securities (other investments).Close and return to top
Can you explain in detail the “look-through approach”?
The look-through approach is an alternate way to risk-weight investment funds and separate account insurance. There are three options for the look-through approach and they are in Appendix A of part 702. All three options look-through the investment fund's actual or permissible assets to determine the risk-weight of the credit union's exposure. If using the look-through approach, a credit union should refer to Appendix A of part 702 to determine which approach to use and how to calculate the risk-weight for the investment fund.Close and return to top
Can you explain in detail the “gross-up approach”? If using the look-through or gross-up approach, how should the approach used be documented, as there doesn’t appear to be any selective areas on the new Call Report?
The gross-up approach is used for senior or subordinated tranches, typically in a securitization. The gross-up approach risk-weights the underlying collateral and applies a multiplier to the risk-weighting for subordinated tranches. The multiplier is based on the ratio of the outstanding amount of the more senior tranches in the securitization versus the outstanding amount of the subordinated tranche that is owned. For example, if a credit union owns the most senior tranche of a securitization, the risk weighting for that asset would be the weighted-average risk-weighting of the underlying collateral. If a credit union owns a subordinated tranche, then the weighted-average risk-weighting of the underlying collateral is multiplied by the leverage the subordinated tranche creates versus the more senior tranches. Credit unions have the option of risk-weighting senior tranches at 100 percent or subordinated tranches at 1,250 percent. The credit union should maintain the documentation of the approach used (look-through versus gross-up) and the results obtained for review by their examiner.Close and return to top
Schedule I, Part II. Risk-Based Capital Calculation, Line 19 - Securities: On line 19, the instructions indicate the "exposure amounts" of securities should be placed in the various risk weight columns. Section 702.2 defines exposure amounts as amortized cost on HTM and AFS securities. Therefore, it would appear the unrealized gain/loss on AFS securities should be reported in "Adjustments to Totals" (RB0018). However, the instructions for the "Adjustments to Totals" state "adjustments to this line should be offset in another line item on this form". Does this intend to indicate the amounts in the all the "Adjustments to Totals" on the lines 18 through 29 should net to zero? If so, what line should be used for the offset on the unrealized gain/loss on AFS securities? And what risk weight should be used for that amount on the other line?
Per the category 1 - zero percent risk weight section of the instructions for line 19, report available for sale gain/(loss) in Account RB0020 to receive a zero percent risk weight.Close and return to top