Although the Bank has an established process for compiling and reporting CRA data, which includes an industry-known system (CRAWiz), the spreadsheet used for collecting loan data does not always contain accurate information.
Review of 25 CRA loans identified two loans with the following exceptions:
(a) One loan was reported in the CRA data collection spreadsheet that the borrower's gross annual revenue ("GAR") was $76,865; however, the loan file indicated that it should be $74,865.
(b) Another loan was reported in the CRA data collection spreadsheet that the business address is located in Chattanooga, TN; however, the loan file indicated that the address where the majority of loan proceeds are used is located in Rossville (Walker County), GA. …show more content…
Alternatively, the CRA data collection team prints screenshots for each and every loan and checks to ensure the CRAWiz loan data is correct. However, the screenshots do not provide GAR $(USD) amount; it only indicates GAR code. Therefore, CRA management can only confirm that the GAR code is correct.
According to CRA management, they were able to confirm that the GAR code was correct; however, could not see (or confirm) the GAR amount. While in this case it did not result in the population of an incorrect revenue code, this error has the potential to result in this situation.
(b) Management indicated that this was due to lack of oversight in the process and that they will re-train their team.
Criteria: Federal Financial Institutions Examination Council ("FFIEC") CRA Getting It Right
Review of 25 CRA loans identified two loans with the following exceptions:
(a) One loan was reported in the CRA data collection spreadsheet that the borrower's gross annual revenue ("GAR") was $76,865; however, the loan file indicated that it should be $74,865.
(b) Another loan was reported in the CRA data collection spreadsheet that the business address is located in Chattanooga, TN; however, the loan file indicated that the address where the majority of loan proceeds are used is located in Rossville (Walker County), GA. …show more content…
Alternatively, the CRA data collection team prints screenshots for each and every loan and checks to ensure the CRAWiz loan data is correct. However, the screenshots do not provide GAR $(USD) amount; it only indicates GAR code. Therefore, CRA management can only confirm that the GAR code is correct.
According to CRA management, they were able to confirm that the GAR code was correct; however, could not see (or confirm) the GAR amount. While in this case it did not result in the population of an incorrect revenue code, this error has the potential to result in this situation.
(b) Management indicated that this was due to lack of oversight in the process and that they will re-train their team.
Criteria: Federal Financial Institutions Examination Council ("FFIEC") CRA Getting It Right