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FAQs on Compliance Management 

How are CRA small business loans defined?

A small business loan is a loan that is reported in the call report as either commercial and industrial purposes or non-farm/non-residential real estate, AND has a loan amount less than $1,000,000.

What is a Community Development Financial Institution (CDFI)?

CDFI’s are mission-driven financial institutions that have been certified by the U.S. Department of the Treasury’s CDFI Fund. CDFIs include credit unions, banks, loan funds, and venture capital funds that operate with a primary mission of serving low-income communities.

View CDFI Cert List >

What do I need to do as I transition from a small-intermediate bank to a large bank?


If you've grown over the threshold, begin acting as if you are a large bank. You'll want to start looking more closely at community development. Make sure you're investing resources on this aspect of CRA. Next, start considering how you are going to collect and transmit data to the FFIEC at year end. Make sure you have a process for collecting revenues for your small business and small farm loans and determine whether your number of small business and small farm loans is something that you can handle using the free data collection software from the FFIEC, or if you need additional software.

What is a community development loan?

A community development loan has a primary purpose of community development and has not been reported or collected by the bank or an affiliate for consideration in the bank’s assessment.

Learn More >

What address should I use to geocode my loans?

Consumer loans use the borrower's address. Real estate loans should be geocoded to the location of the property. Business and farm loans should be geocoded to either the location of the borrower's main business facility or to the location where the funds will be used as indicated by the borrower. Be consistent.

Are construction-only loans or construction-permanent loans covered by the TRID Rule?

Yes, most closed-end consumer mortgage loans to finance home construction that are secured by real property are covered.

What revenue should I use for a start-up business?

A start up business, by definition, does not yet have any revenues. So, they would be coded as having revenues less than $1,000,000.

Are construction-only loans or construction-permanent loans covered by the TRID Rule?

Yes, most closed-end consumer mortgage loans to finance home construction that are secured by real property are covered by the TRID Rule.

What information should we be collecting from our vendors in regards to diversity and inclusion?


While the OCC does not provide guidance on specific information collected from vendors, you may want to outline this in your Vendor Management Policy. Critical vendors at a minimum are recommended, but you may want to take a different approach such as vendors who your FI spends a substantial amount of funds could be the ones you focus D&I efforts on. As long as your FI can confidently describe its reasoning for selection (through documentation), that is the goal.

Are UDAAP risk assessments required by regulators?

UDAAP risk assessments are not necessarily a “regulatory requirement”, but they are certainly a supervisory expectation of the CFPB, the OCC and other Federal regulators. In a recent CFPB enforcement action, the CFPB took the novel step of ordering a national bank to develop “a written, enterprise-wide UDAAP risk-management program for any consumer financial products or services” it offers.

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