Emergency Capital Investment Program

Overview of Qualified Lending 

Reporting

1
Emergency Capital Investment Program

Steve Davidson

Investment Director

Emergency Capital Investment Program

U.S. Department of the Treasury

David Meyer

Operations Program Manager

Emergency Capital Investment Program

U.S. Department of the Treasury

Carol Rodrigues

Attorney-Adviser (Finance)

Office of the General Counsel 

U.S. Department of the Treasury

April 2023

2

Presenters
Topics

❖ Background on Reporting

❖ Quarterly Supplemental Report

❖Report Structure and Overview

❖Submission Schedule 

❖ Initial Supplemental Report – M&A

❖ Legal Certifications

❖ Impact Highlight Report 

❖ Submission of Comments

❖ Q&A 

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Emergency Capital Investment Program
Topics

❖ Background on Reporting

❖ Quarterly Supplemental Report

❖Report Structure and Overview

❖Submission Schedule

❖ Initial Supplemental Report – M&A

❖ Legal Certifications

❖ Impact Highlight Report 

❖ Submission of Comments

❖ Q&A 

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Emergency Capital Investment Program
• All Emergency Capital Investment Program (ECIP) participants must provide periodic reports 

to Treasury:

• See the relevant Securities Purchase Agreement for the full set of reporting requirements.

• Quarterly Supplemental Report (QSR)

• The QSR is used to:

• Calculate eligibility for rate reductions; and

• Collect data required for Treasury to assess and evaluate the program. 

• Initial Supplemental Report (ISR) for certain M&A transactions

• The ISR is used to adjust the baseline amount of Qualified Lending when an ECIP 

participant merges with or acquires a non-participant.

• Legal Certifications

• Voluntary: Impact Highlight Report

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Emergency Capital Investment Program

Background on Reporting
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Emergency Capital Investment Program

Timeline

QSR Release Timeline 

April 22, 

2022:

Treasury 

posted 

preview 

copies of the 

QSR forms 

and 

instructions.

June 30, 

2022: 

Treasury 

published 

Federal 

Register 

notice of 

proposed 

QSR forms 

and 

instructions. 

August 29, 

2022: 

Deadline to 

submit 

comments. 

September 

2022 - March 

2023: 

Treasury 

reviewed 

comments 

and made 

updates to 

forms and 

instructions 

based on 

comments.

March 27, 

2023: 

Treasury 

releases 

updated forms 

and 

instructions for 

30-day 

comment 

period.

April 26, 

2023: 

Comment 

period 

deadline.

May/June 

2023: Final 

comments 

considered; 

Treasury 

submits forms 

for OMB 

approval.

June 30, 

2023: QSR 

submission 

starts.
Topics

❖ Background on Reporting

❖ Quarterly Supplemental Report

❖Report Structure and Overview

❖Submission Schedule 

❖ Initial Supplemental Report – M&A

❖ Legal Certifications

❖ Impact Highlight Report 

❖ Submission of Comments

❖ Q&A 

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Emergency Capital Investment Program
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Emergency Capital Investment Program

Schedule A – Summary 

Qualified Lending

Schedule B – Disaggregated 

Qualified Lending

Schedule C –

Additional 

Demographic Data

Schedule D –

Additional Placebased Data

Quarterly Supplemental Report – Report Structure and Overview
• Purpose is to collect data on Qualified and Deep Impact Lending to: 

• Allow computation of qualification for rate reductions in dividend and interest payments to be 

made to Treasury; and 

• Enable Treasury to assess and evaluate the impact of the program.

• Separate sets of schedules and instructions for IDIs & holding companies and credit unions. 

• Submission is required for all Participants and the same report schedules are required regardless of 

institution size.

• Report is a single Excel-based spreadsheet and consists of four (4) primary schedules, containing 

twelve (12) individual tabs.

• Schedules A & B are due quarterly, and each schedule consists of one tab.

• Schedules C & D are due annually: Schedule C has two tabs and Schedule D has eight tabs.

• Schedules are prepared off-line and must be submitted through the ECIP Salesforce-based portal. 

• No format conversions required for submission.

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Emergency Capital Investment Program

Quarterly Supplemental Report – Report Structure and Overview
• See the Treasury ECIP webpage for instructions: ECIP Program webpage

• Located under the Reporting Resources section:

• Instructions by institution type

• Report templates

• FAQs

• Reference datasets

• See your specific set of legal documents for additional guidance on submission deadlines 

and requirements.

• Request technical assistance and ask Treasury questions via ECIP@treasury.gov.

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Emergency Capital Investment Program

Quarterly Supplemental Report – Report Structure and Overview
• All reports need to be completed in accordance with instructions and certified as complete and accurate. 

Participants are expected to collect all the data needed to complete all the schedules in the QSR accurately. 

• Use of proxy data to classify loans as Qualified or Deep Impact Lending is NOT permitted. 

• Carefully review the instructions on demographic data collection in Section I.G. of the instructions:

• Treasury expects that it will not be possible for Participants to accurately complete the QSR without processes 

in place to attempt to collect the data necessary to complete all the fields and all the schedules in the QSR 

accurately. 

• Participants are not expected to require their customers to provide demographic data.

• Participants may use the following methods for collecting demographic data from customers: (i) self-reporting 

by customers; (ii) methods that the Participant uses for the purposes of complying with the Home Mortgage 

Disclosure Act (HMDA); and (iii) methods that the Participant uses for the purposes of complying with CDFI 

Fund certification or reporting requirements. 

• Treasury believes self-identification is the best method of collecting demographic data. If a Participant is 

collecting data for the purposes of complying with HMDA or CDFI certification or reporting requirements, that 

data may be used for the QSRs. 

• However, geographic proxies may NOT be used, even if such proxies are accepted for the purposes of 

complying with HMDA or CDFI certification or reporting requirements. 

• If you have questions about how to apply these instructions to your institution or specific business lines or products, 

please contact ECIP@treasury.gov and we will provide technical assistance. 11

Emergency Capital Investment Program

Demographic Data Collection Demographic Data Collection
• Because Participants may require time to develop sufficient data-collection systems, for 

each QSR through the report for the quarter ending on June 30, 2024, Treasury will not 

consider the QSR to be inaccurate or incomplete solely on the basis of a lack of 

demographic data. 

• For each such QSR, the Participant must provide a narrative explanation of their plans to 

implement sufficient data-collection systems and their progress in implementing those plans.

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Emergency Capital Investment Program

Demographic Data Collection Demographic Data Collection
Schedule A

• Highest-level report of Qualified and Deep Impact Lending.

• Submitted quarterly.

• Uses Call Report Lending Activity Categories. The columns are the same for credit unions and IDIs and 

holding companies.

• Report the number of transactions and dollar amount of activity in the applicable quarter.

• Schedule A is used to determine qualification for rate reductions. 

• DO NOT DOUBLE COUNT TRANSACTIONS.

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Emergency Capital Investment Program

Schedule A Schedule A
Schedule B

• Used to present further detail on the composition of Qualified and Deep Impact Lending.

• Submitted quarterly.

• Double-counting of loans across categories is expected.

• Example: A loan to a Low-income Borrower in a Persistent Poverty County must be reported in both the 

Low-income Borrower and Persistent Poverty County columns. 

• Report the number of transactions and dollar amount of activity in the applicable quarter.

• Uses Call Report Lending Activity Categories. The columns are the same for credit unions and IDIs and 

holding companies.

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Emergency Capital Investment Program

Schedule B Schedule B
Schedule B Categories by Qualified and Deep Impact Lending (columns)

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Emergency Capital Investment Program

Schedule B

Column # Categories Qualified Lending Deep Impact Lending

1 LMI Borrowers X

2 Other Targeted Populations X

3 Low-Income Borrowers X

4 Mortgage Lending to Other Targeted Populations X

5 Rural Communities X

6 Urban Low-Income Communities X

7 Underserved Communities X

8 Minority Communities X

9 Persistent Poverty Counties X

10 Indian Reservations and Native Hawaiian Homelands X

11 U.S. Territories X

12 Small Businesses or Farms X

13 Underserved Small Businesses X

14 Affordable Housing X

15 Qualified Public Welfare Investments (PWI) X

16 Community Service Facility X

17 Deeply Affordable Housing X

18 Deep Impact Public Welfare Investments (PWI) X

Schedule B
Schedule B Lending Activity Categories for IDIs/Holding Companies and Credit Unions (rows)

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Emergency Capital Investment Program

Schedule B

IDIs and Holding Companies Credit Unions

ID Lending Activity Categories

Col

um

n1

CU ID Credit Union Lending Activity Categories

1 Loans secured by construction, land development, and other land loans 1 Non-commercial loans / lines of credit (auto-calculated)

2 Loans secured by farmland 2 Unsecured credit card loans

3 Loans secured by 1-4 family residential properties 3 Payday alternative loans (PALs I and PALs II) (FCU only)

4 Loans secured by multifamily (5 or more) residential properties 4 Non-federally guaranteed student loans

5 Loans secured by nonfarm nonresidential properties 5 All other unsecured loans/lines of credit

6 Loans to finance agricultural production and other loans to farmers 6 New vehicle loans

7 Commercial and industrial loans 7 Used vehicle loans

8 Loans to individuals for household, family, and other personal expenditures 8 Leases receivable

9 Lease financing receivables 9 All other secured non-real estate loans / lines of credit

10 Direct and indirect investments in real estate ventures 10 Loans / lines of credit secured by first lien on single 1-4 family res property

11 Equity investments without readily determinable fair values 11 Loans / lines of credit secured by junior lien on single 1-4 family res property

12 All other real estate loans / lines of credit

13 Commercial loans / lines of credit (auto-calculated)

14 Commercial loans / lines of credit real estate secured

15 Commercial loans / lines of credit not real estate secured

Schedule B
Schedule C

• Schedule C–Additional Demographic Data on Qualified Lending collects additional demographic data on certain categories 

of Qualified Lending and Deep Impact Lending:

• Schedule C1–People is used for loans to:

• LMI Borrowers, disaggregated by income category;

• Other Targeted Populations, disaggregated by race or ethnicity; and

• Mortgage lending to Other Targeted Populations, disaggregated by race or ethnicity.

• Schedule C2–Businesses is used for loans to Underserved Small Businesses, disaggregated by business size, owner 

income, or owner race and ethnicity.

• See instructions for additional information on how to determine the demographic characteristics of business 

owners and how to report loans to businesses with owners of multiple races and ethnicities. 

• Due annually for the calendar year, concurrently with quarterly data for quarter ending March 31 of the following year (e.g.,

2024 calendar year report due concurrently with Call Report for the quarter ending March 31, 2025).

• Report the number of transactions and dollar amount of activity in the applicable year.

• Uses Call Report Lending Activity Categories. The columns are the same for credit unions and IDIs and holding companies. 

• Double-counting of loans across categories is expected.

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Emergency Capital Investment Program

Schedule C Schedule C
Schedule C Lending Activity Categories for IDIs/Holding Companies and Credit Unions (rows)

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Emergency Capital Investment Program

IDIs and Holding Companies Credit Unions

ID Lending Activity Categories

Col

um

n1

CU ID Credit Union Lending Activity Categories

1 Loans secured by construction, land development, and other land loans 1 Non-commercial loans / lines of credit (auto-calculated)

2 Loans secured by farmland 2 Unsecured credit card loans

3 Loans secured by 1-4 family residential properties 3 Payday alternative loans (PALs I and PALs II) (FCU only)

4 Loans secured by multifamily (5 or more) residential properties 4 Non-federally guaranteed student loans

5 Loans secured by nonfarm nonresidential properties 5 All other unsecured loans/lines of credit

6 Loans to finance agricultural production and other loans to farmers 6 New vehicle loans

7 Commercial and industrial loans 7 Used vehicle loans

8 Loans to individuals for household, family, and other personal expenditures 8 Leases receivable

9 Lease financing receivables 9 All other secured non-real estate loans / lines of credit

10 Direct and indirect investments in real estate ventures 10 Loans / lines of credit secured by first lien on single 1-4 family res property

11 Equity investments without readily determinable fair values 11 Loans / lines of credit secured by junior lien on single 1-4 family res property

12 All other real estate loans / lines of credit

13 Commercial loans / lines of credit (auto-calculated)

14 Commercial loans / lines of credit real estate secured

15 Commercial loans / lines of credit not real estate secured

Schedule C
Schedule C1 Categories by Qualified and Deep Impact Lending (columns)

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Emergency Capital Investment Program

Lending Type Borrower Category/Type Population

50% or Below of AMI

51 - 80% of AMI

81 - 100% of AMI

101 - 120% of AMI

Black American

Native American

Asian American

Native Alaskan

Native Hawaiian

Pacific Islander

Hispanic American

(of any race)

Black American

Native American

Asian American

Native Alaskan

Native Hawaiian

Pacific Islander

Hispanic American 

(of any race)

Deep Impact Lending Mortgage Lending to Other 

Targeted Populations

Qualified Lending

LMI Borrowers

Other Targeted Populations 

Schedule C
Schedule C2 Categories (columns)

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Emergency Capital Investment Program

Borrower Category/Type

Gross annual revenues that do not exceed $100,000

Majority owned by Low-Income Borrowers

Majority owned by Black Americans

Majority owned by Native Americans

Majority owned by Asian Americans

Majority owned by Native Alaskans

Majority owned by Native Hawaiians

Majority owned by Pacific Islanders

Majority Owned by Minority Individuals of Multiple Races

Majority owned by Hispanic Americans (of any race)

Underserved Small Businesses

Schedule C
Schedule D1 to D8 – Additional Place-based Data

• Schedule D collects additional geographic data on place-based lending.

• Some schedules require aggregation to the county level and others aggregate at the census tract level.

• Due annually for the calendar year, concurrently with quarterly data for quarter ending March 31 of the following 

year (e.g., 2024 calendar year report due concurrently with the Call Report for the quarter ending March 31, 2025)

• Report the number of transactions and dollar amount of activity in the applicable year, along with applicable 

geographic fields.

• See instructions for place-based definitions. 

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Emergency Capital Investment Program

Schedule D
• Categories of Place-based Lending

• Rural Communities (county level)

• Urban Low-Income Communities (census tract level)

• Underserved Communities (census tract level)

• Minority Communities (census tract level)

• Persistent Poverty Counties (county level)

• Indian Reservations & Native Hawaiian Homelands (American Indian Area Code and 

census tract)

• U.S. Territories (census tract)

• Projects Benefiting LMI Communities or Other Targeted Populations (county)

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Emergency Capital Investment Program

Schedule D
• Each report must have a narrative explaining the procedures used to produce the report data. 

• Narrative may be used in case there is a need to replicate the data after submission.

• The narrative should describe which methodology, or combination of methodologies, 

Participants used to identify their Qualified Lending. 

• As part of the submission process, each report must be certified by the Participant’s CEO or 

CFO as being prepared in conformance with the instructions, true and correct.

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Emergency Capital Investment Program

Additional Requirements
Topics

❖ Background on Reporting

❖ Quarterly Supplemental Report

❖Report Structure and Overview

❖Submission Schedule 

❖ Initial Supplemental Report – M&A

❖ Impact Highlight Report 

❖ Submission of Comments

❖ Q&A 

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Emergency Capital Investment Program
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Emergency Capital Investment Program

Period of Activity Schedules Required Report Due Date

Closing Date - June 30, 2022* A & B Friday, June 30, 2023

July 1, 2022 - September 30, 2022** A & B Friday, June 30, 2023

October 1, 2022 - December 31, 2022** A & B Friday, June 30, 2023

Closing Date - December 31, 2022 

Annual Reporting

C &D (for 2022 

lending) Friday, June 30, 2023

January 1, 2023 - March 31, 2023 A & B Friday, June 30, 2023

April 1, 2023 - June 30, 2023 A & B

Concurrent with applicable 

federal regulator report 

filing deadline (Call Report 

or FR Y-9C)

* For institutions that closed before June 30, 2022

** For institutions that closed within the quarter, report on all 

activity from the Participant’s closing date to quarter end.

QSR Submission Schedule
• Use applicable templates and guidance on Treasury website to begin 

preparation of the reports.

• 2022 reports can be submitted in any order but Treasury suggests that 

Recipients submit reports in chronological order.

• Treasury will only accept reports after the Office of Management and 

Budget assigns a Paperwork Reduction Act number and expiration date. 

• Treasury will provide technical guidance and demonstrations on how to 

submit reports through the ECIP portal prior to the submission deadlines.

• For any questions, contact Treasury at ECIP@treasury.gov.

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Emergency Capital Investment Program

QSR Submission Schedule
Topics

❖ Background on Reporting

❖ Quarterly Supplemental Report

❖Report Structure and Overview

❖ Submission Schedule 

❖ Initial Supplemental Report – M&A

❖ Legal Certifications

❖ Impact Highlight Report 

❖ Submission of Comments

❖ Q&A 

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Emergency Capital Investment Program
• When a Participant merges with or acquires another institution, the Participant’s baseline is 

adjusted. 

• If the acquired institution is an ECIP participant, Treasury will use the Initial Supplemental 

Report (ISR) submitted by the acquired institution. 

• If the acquired institution is not an ECIP participant, the Participant must submit an ISR for 

the acquired institution covering the annual period ending on the last day of the last 

completed quarter before the merger, acquisition or other business combination was 

completed. 

• The ISR for the acquired institution is due concurrently with the Participant’s first QSR that 

includes the lending of the acquired institution.

• Please see the instructions regarding M&A activity in section I.F. of the QSR instructions for 

more details on when the Participant should include the lending of the acquired institution in 

its QSR. 

• Notify Treasury of plans for M&A early in the process, whenever possible.

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Emergency Capital Investment Program

Initial Supplemental Report – Mergers and Acquisitions
Topics

❖ Background on Reporting

❖ Quarterly Supplemental Report

❖Report Structure and Overview

❖Submission Schedule 

❖ Initial Supplemental Report – M&A

❖ Legal Certifications

❖ Impact Highlight Report 

❖ Submission of Comments

❖ Q&A 

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Emergency Capital Investment Program
• Up to three certifications must be made annually. Forms of the certifications are on the ECIP 

website. 

• Process and Controls Certification.

• Due within 120 days after Participant’s fiscal year end.

• Currently submitted in response to “Additional Information Request” sent through 

Salesforce.

• Attestation of Independent Auditor, if applicable. 

• Due within 120 days after Participant’s fiscal year end.

• Currently submitted in response to “Additional Information Request” sent through 

Salesforce.

• Interim Final Rule Certification.

• Due by December 31 each year.

• Currently submitted in response to “Additional Information Request” sent through 

Salesforce. 30

Emergency Capital Investment Program

Legal Certifications
Topics

❖ Background on Reporting

❖ Quarterly Supplemental Report

❖Report Structure and Overview

❖Submission Schedule 

❖ Initial Supplemental Report – M&A

❖ Legal Certifications

❖ Impact Highlight Report 

❖ Submission of Comments

❖ Q&A 

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Emergency Capital Investment Program
• Treasury has proposed a form to collect impact stories submitted on a voluntary basis 

through the new Impact Highlight Report.

• Reports can be sent at any time.

• Will be implemented online through the ECIP portal.

• Content incudes narrative of up to 250 words and dropdown menus to help Treasury 

catalog reports.

• Information submitted may be used for program evaluation and as a source of qualitative 

information on the impact of ECIP and any innovations by Participants in serving targeted 

communities. 

• May be shared with the public, Congress, or oversight bodies, in various forms.

• Do not include personal details of borrowers.

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Emergency Capital Investment Program

Impact Highlight Report
Topics

❖ Background on Reporting

❖ Quarterly Supplemental Report

❖Report Structure and Overview

❖Submission Schedule 

❖ Initial Supplemental Report – M&A

❖ Legal Certifications 

❖ Impact Highlight Report 

❖ Submission of Comments

❖ Q&A 

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Emergency Capital Investment Program
• The public may submit comments on any of the forms and instructions:

• ISR – M&A versions

• QSR

• Legal Certifications

• Impact Highlight Report

• To submit a comment, please email your comment to pra@treasury.gov. 

• Please reference 1505-0275 in the subject line.

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Emergency Capital Investment Program

Comment Submission
• After the comment period closes:

• Treasury will review comments; 

• Request the Office of Management and Budget to approve use of forms 

by assigning a Paperwork Reduction Act number;

• Open the Salesforce-based portal for submission of QSR reports; and

• Conduct demonstration(s) of how to submit reports.

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Emergency Capital Investment Program

Comment Submission
Topics

❖ Background on Reporting

❖ Quarterly Supplemental Report

❖Report Structure and Overview

❖Submission Schedule

❖ Initial Supplemental Report – M&A

❖ Legal Certifications

❖ Impact Highlight Report 

❖ Submission of Comments

❖ Q&A 

36

Emergency Capital Investment Program
37

Emergency Capital Investment Program

Q & A

Report Period of Activity Reports or Schedules 

Required Report Due Date How to Submit

Legal Certification Recipient's most recently completed 

fiscal year

Process and Controls 

Certification

120 days after the end of the fiscal 

year (e.g., FYE December 31, 2022

report due by April 30, 2023)

Treasury sent out an Additional 

Information Request (AIR) in Q1 of the 

calendar year. Please respond to the 

AIR to submit this certification. 

Legal Certification Recipient's most recently completed 

fiscal year

Process and Controls 

Attestation of Internal Auditor, 

if applicable

120 days after the end of the fiscal 

year (e.g., FYE December 31, 2022

report due by April 30, 2023)

Treasury will send out an Additional 

Information Request (AIR) in Q1 of the 

calendar year. Please respond to the 

AIR to submit this certification. 

Financial Statements Recipient's most recently completed 

fiscal year

Balance sheet and statements 

of income, retained earnings 

and cash flows

120 days after the end of the fiscal 

year (e.g., FYE December 31, 2022

report due by April 30, 2023)

By email to ECIP@treasury.gov. Please 

label email subject header: '[ECIP #], 

[Participant Name] – FY Financials'

QSR Closing Date - June 30, 2022* A & B Friday, June 30, 2023 ECIP (Salesforce) Portal

QSR July 1, 2022 - September 30, 2022** A & B Friday, June 30, 2023 ECIP (Salesforce) Portal

QSR October 1, 2022 - December 31, 

2022** A & B Friday, June 30, 2023 ECIP (Salesforce) Portal

QSR Closing Date - December 31, 2022

Annual Reporting C & D (for 2022 lending) Friday, June 30, 2023 ECIP (Salesforce) Portal

QSR January 1, 2023 - March 31, 2023 A & B Friday, June 30, 2023 ECIP (Salesforce) Portal

QSR April 1, 2023 - June 30, 2023 A & B

Concurrent with applicable federal 

regulator report filing deadline (Call 

Report or FR Y-9C)

ECIP (Salesforce) Portal

* For institutions that closed before June 30, 2022

** For institutions that closed within the quarter, report on all activity from the Participant’s closing date to quarter end.