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                    for more details.
 National Credit Union Administration
 AGENCY: National Credit Union Administration (NCUA).
 ACTION: Request for Information (RFI)
 SUMMARY: The National Credit Union Administration is conducting a comprehensive review of the loan, deposit, and investment information collected electronically during examinations of federally insured credit unions from the core data processing and offline systems used by credit unions.
 DATES: Comments must be received on or before January 2, 2018.
 ADDRESSES: Comments may be submitted using 
                        *one*
                         of the methods below (Please do not send comments via multiple methods). Include [Your name and company name (if any)]—Electronic Data Collection Modernization in all correspondence. *Email:*
                         Address to 
                        *BIMail@NCUA.gov.*
                         Include “[Your name] Comments on Electronic Data Collection Modernization” in the email subject line. Any of the following formats is acceptable: HTML, ASCII, Word, RTF, or PDF.
                    *Mail:*
                         Please direct written comments to Amber Gravius, National Credit Union Administration, 1775 Duke Street, Alexandria, Virginia 22314. NCUA will post all comments received by the deadline on the agency Web site (
                        *www.ncua.gov*) without alteration or redaction, so commenters should not include information they do not wish public (
                        *e.g.,*
                         personal or confidential business information). SPAM or marketing materials will be discarded without publication.
 FOR FURTHER INFORMATION CONTACT: Kelly Lay, Business Innovation Director or Amber Gravius, Special Assistant for Business Innovation, Office of the Executive Director, at 1775 Duke Street, Alexandria, VA 22314 or telephone (703) 518-6313 (Ms. Lay) or (703) 548-2411 (Ms. Gravius). Media inquiries should be directed to the NCUA Office of Public and Congressional Affairs at (703) 518-6671 or 
                        *pacamail@ncua.gov.*


SUPPLEMENTARY INFORMATION: The National Credit Union Administration (NCUA) is conducting a comprehensive review of the loan, deposit, and investment information collected electronically during examinations of federally insured credit unions (FICUs). The overarching goal is to modernize, formalize, and standardize data formats collected during examinations from the core data processing and offline systems [1]
                    
                     used by credit unions. The purpose of this modernization effort is to: a. Achieve a more consistent examination process; b. Promote agency efficiencies and reduce burden on credit unions; c. Reduce onsite time by streamlining agency efforts to sort, organize, and format data; d. Improve data reliability and quality to enable more offsite work; e. Enhance the objectivity of examination conclusions with a more thorough and advanced portfolio analysis; and f. Support the Exam Flexibility Initiative's [2]
                    
                     longer examination cycle, consistency between examiners, better communication, more efficient examination planning process, and better offsite monitoring tools. This RFI is a major step in NCUA's internal modernization efforts. After considerable research and analysis, the agency is now at a point where it can outline the scope of its planned improvements. In turn, NCUA seeks the views of the public on this initiative and is eager to gain input from interested stakeholders on a number of aspects related to the future data collection by NCUA. Specifically, this RFI explains NCUA's objectives and seeks insights from stakeholders in identifying the interrelated considerations and challenges that could arise if NCUA adopts a new standardized data format for loan, deposit, and investment data.[3]
                    
                     NCUA will use information furnished by stakeholders to help further define data fields to collect electronically, develop a standard data format (including field names and definitions), and comprise an implementation strategy that reduces burden without compromising the agency's ability to safeguard the National Credit Union Share Insurance Fund (NCUSIF). Separate and apart from the normal examination data download process, FICUs with assets greater than $10B must comply with 12 CFR 702, subpart E which implements capital planning and stress testing.[4]
                    
                     The information collected as part of this process is not the focus of this RFI as it differs significantly in timing, purpose, and content. In addition to this RFI, the agency may seek clearance from the Office of Management and Budget to conduct stakeholder calls and form workgroups to gather additional information about barriers and benefits to this modernization initiative. NCUA invites interested parties to respond generally to this modernization initiative and specifically to the questions included in this RFI. 
 
 I. Background Examiners obtain electronic data at the beginning of every examination, during some supervision contacts, and on an ad hoc basis from credit unions. This raw data, sometimes from multiple sources and in multiple data files, provides examiners with essential information in evaluating credit and deposit risks in FICUs and is integral to risk supervision which is central to safeguarding the integrity of the NCUSIF. Before 1995, this data was in written format. In 1995, NCUA initiated the first electronic data collection [5]
                    
                     encouraging FICUs to provide member data to examiners through standard download routines made available by their information processing vendor or written in-house instead of paper listings and reports. In this letter, NCUA requested 12 member profile, 24 loan and 4 share fields electronically for each member record.[6] In November 2000, NCUA encouraged adherence to the share and loan data record layout specifications to facilitate the import functions into NCUA's examination software, Automated Integrated Regulatory Examination System (AIRES).[7]
                    
                     NCUA did not increase the electronic data fields or modify the data format with this communication. NCUA last changed the loan and share download in April 2003.[8]
                    
                     Beginning June 30, 2003, the member profile fields were consolidated and one new field was added for a total of eight fields.[9]
                    
                     The unique loan fields increased by eight and the unique share fields increased by nine to total 39 loan and 20 share data fields in the electronic download. Although NCUA did not make electronic data collection a requirement, NCUA did identify fields as “critical” and “optional.” NCUA requested FICUs provide all critical fields for successful import and use in the examination process. The letter identifies 15 critical fields in the share file and 25 critical fields in the loan file. In 2009, NCUA informed federal credit unions (FCUs) of the membership data collection and information extracted from the electronic loan and share download gathered during examinations.[10]
                    
                     NCUA did not increase the electronic data fields or modify the data format with this communication. II. Reason for Modernization Initiative The credit union industry is dynamic, with FICUs growing larger and more complex each year. NCUA must ensure its data collection vehicles evolve with industry practices and examination/supervision procedures so: a. All material FICU risk exposures are captured; b. data offering little insight into these exposures are no longer solicited; and c. the reporting burden on supervised institutions—particularly small or non-complex credit unions—is minimized. Increasing industry complexity, a desire for more effective offsite supervision, and evolving technologies necessitated a review of the current process in favor of opportunities to improve efficiencies and reduce the examination burden on credit unions. Table 1 illustrates the evolution of the FICU industry since NCUA last changed the electronic data collection in April 2003. Although the number of institutions has declined, FICUs continue to grow in assets, loans, shares, membership, and complexity. Table 1—FICU Trends Since the Last Change in Electronic Data Collection
12/31/2003
3/31/2017
Change (%)FICUs
9,369
5,737
(63.33)Total Assets
$610.16B
$1.34T
119.62Total Loans
$376.11B
$884.58B
135.20Consumer Loans 11
$187.53B
$390.07B
108.00Credit Card Loans
$21.84B
$51.59B
136.21Indirect Loans
12
                             Not collected
$172.56B
Not availableParticipation Loans
$4.5B
$29.97B
566.00Real Estate Loans 13
$168.26B
$438.93B
160.86Commercial/MBL
$9.32B
$68.89B
639.16Student Loans 14
Not collected
$3.99B
Not availableTotal Shares
$528.34B
$1.13T
113.88Average Assets
$65.10M
$233.0M
257.91Median Assets
$10.55M
$29.97M
184.08# Loans
40.92M
61.01M
49.10# Shares Accounts
142.34M
204.44M
43.63
 Today, examiners
                    
                     frequently request additional reports and data electronically during examinations above and beyond the loan and share download including, but not limited to: Investment data, credit cards, indirect loans, participation loans, and commercial/member business loans. These requests are compelled by increased complexity, more services, and extensive loan products offered to credit union members. These requests may be made before an examination begins or throughout the process. As NCUA has not defined a standard data 
                    ( print page 50449)
                    structure and fields for different loan types,[15]
                    
                     the characteristics of data presented in these files often differs from credit union to credit union and vendor to vendor. The unique formats can result in credit union resources to produce and explain their individual reports to examiners. This also creates examination inefficiencies for credit unions and examiners as the reports may not contain all information requested by the examiner and additional information requests may be made. Further, data limitations and inconsistency results in disparate evaluations of risk at different credit unions and across all FICUs. As part of the broader enterprise modernization effort, NCUA desires to improve loan and deposit portfolio analytics used during FICU examinations to provide for more consistent analysis of risk within and across institutions to mitigate losses to the NCUSIF. Data standardization is paramount to effectively use more robust analytic tools and will also benefit credit unions outside of the examination context, as credit unions have been known to use the download when two credit unions are merging to transfer records. It has also been used with some third party vendors for analytics, reporting, and data processing conversions. NCUA acknowledges there are challenges with a standard data format. Credit unions use dozens of data processing systems and third party vendors for originating, recording, and monitoring loans, deposits, and investments. Additionally, there are many variations and platforms, including credit union developed information technology systems, with varying data content and formats. Responses to the questions in this RFI will inform NCUA of the extent to which FICUs can provide data electronically in a standard format and identify data fields available for electronic collection. Additionally, NCUA welcomes suggested implementation strategies that reduce burden without compromising the agency's ability to safeguard the NCUSIF. III. Information Security NCUA exercises great care in protecting sensitive and personally identifiable information. As a federal agency, NCUA must comply with mandatory security standards for federal information and information systems [16]
                    
                     and must meet these minimum information security requirements by using security and privacy controls recommended by the National Institute of Standards and Technology (NIST).[17]
                    
                     In addition to NIST standards and guidelines, NCUA is subject to federal statutes such as the Federal Information Security Modernization Act (FISMA) of 2014, the E-Government Act of 2002, the Privacy Act of 1974 and various OMB policies and guidance concerning federal information management, FISMA reporting, and privacy. NCUA uses administrative, technical, and physical controls, including but not limited to: Periodic review and authorization of information systems; proactive threat assessment and continuous monitoring; and annual general and role-based security training for employees and contractors. We also leverage independent tests and evaluations from other government agencies and third-party assessors. The Office of the Inspector General (OIG) conducts independent audits, investigations and other activities to verify NCUA's compliance with applicable standards, laws and regulations related to privacy and information security and keeps the NCUA Board and U.S. Congress fully and currently informed of their work. The OIG conducts a FISMA and Federal Managers' Financial Integrity Act (FMFIA) audit annually to ensure NCUA has effectively implemented all appropriate security and privacy controls.[18] *Request for Comment:*
                     NCUA is providing questions about major aspects of this electronic data modernization to target issues the public would like addressed by the effort. The questions are not intended to limit discussion. Indeed, responders may explore an issue relevant to this initiative. Responses containing references to studies, research, or data not widely available to the public should include copies of referenced materials. A description of the commenter's organization and its interest in the electronic data will help NCUA use the input provided. a. Electronic Data Collection Modernization Questions 1. To the extent an FICU offers the loan and deposit services and has the investment instruments identified in the section b, are there any example data fields listed in this RFI that cannot be reasonably provided electronically? What other data fields could be provided that NCUA should consider collecting electronically? 2. For electronic data, what file formats (
                    *e.g.,*
                     Microsoft Excel, CSV, etc.) are available? 3. If a FICU cannot provide data electronically, to what extent is the limitation due to the IT systems (
                    *e.g.,*
                     the field is not available in the IT system to be captured electronically)? To what extent is the limitation because a credit union is not electronically collecting the data now (
                    *e.g.,*
                     loan underwriting information captured in the loan file, such as a calculated debt to income ratio, but is not stored in an IT system that can capture that data)? 4. What is the number of vendors, systems, or service providers the FICU uses for loans (all types), deposits, and investments you currently can or would extract data for examination purposes? Specifically, how many are used for each category (
                    *e.g.,*
                     loans, deposits, and investments)? 5. To what extent does the FICU rely on a third party vendor to create and produce raw data downloads? Does the vendor provide the credit union with the flexibility to self-customize reporting for data attributes? 6. What are the technological challenges NCUA should consider with a standardized data format (
                    *e.g.,*
                     specific file names, format, etc.)? 7. What additional initial and annual costs would you estimate a FICU could incur to generate and provide data electronically in a standard format (
                    *e.g.,*
                     pass through costs from vendors, in-house development resources, etc.)? 8. Does the credit union or vendor have the ability to retain and create the current loan and share download data format (with no changes) as well as new download data formats? [19] 9. Should NCUA eliminate the “critical” and “optional” data 
                    ( print page 50450)
                    categorizations discussed in NCUA Letter to Credit Unions 03-CU-05? If yes, what approaches would you propose NCUA use to collect standardized data for better analytics and examination efficiencies? 10. With the exception of the example data formats based on data type discussed in this RFI, what alternatives would you propose for NCUA to collect data in a standardized format that minimizes the credit union burden? 11. What implementation strategies and timeline should NCUA consider with this modernization? For example, what is the anticipated timeframe for a FICU or vendor to provide the sample data fields and the associated format? How should NCUA ensure FICUs use the standard data format? 12. What specific information security controls or assurances are expected from NCUA to reasonably safeguard the electronic loan, share, and investment data? Commenters are also encouraged to discuss any other relevant issues they believe NCUA should consider with respect to the electronic collection of loan, deposit, and investment data. b. Sample Loan, Deposit, and Investment Electronic Data Collection NCUA is requesting input and feedback on sample data fields and the associated format.[20]
                    
                     The information in tables 2-9 is preliminary and is presented for discussion and input purposes only. For sample purposes only, NCUA is presenting one data format for all deposit types, one for investment data,[21]
                    
                     and different data formats for loans based on the loan type.[22]
                    
                     To the extent the FICU offers these loan and deposit services and has these investment instruments, NCUA is asking stakeholders to identify if FICUs can provide these and other data fields electronically in their response to the RFI. Similar to the download process today, credit unions would be permitted to submit multiple data files electronically for loans, deposits, and investments. Table 2—Deposit Electronic Fields
Number
Applies to
Field
Description
Example
Data
                             format
Current NCUA
                             standard 
                             
                                field 23D1
All Share Accounts
Effective date of the download
Effective date of the data
03312017
Date
No.D2
All Share Accounts
Record Code
Indicate D for Deposits, L for Loans, I for Investment
D
D/L/I
Yes  .*D3
All Share Accounts
Taxpayer ID
Nine digit code used by the U.S. Government (TIN). For individuals use Social Security number
123456789
Number
Yes .*D4
All Share Accounts
Member ID
Primary key identifier for the entity. This is the number used to uniquely identify the member/non-member such as an account number
ABC123456
Text
Yes .*D5
All Share Accounts
Member Name
Full legal name. Format: Last Name, Suffix (if applicable), First Name, Middle Initial for individuals. For business provide full legal name
Long Sr., John, S
Text
Yes .*D6
All Share Accounts
Address Line 1
Street address
7247 Circle Sun
Text
Yes .*D7
All Share Accounts
Address Line 2
Address line 2
P.O. Box 858
Text
YesD8
All Share Accounts
City
City where borrower resides. For business account, provide the city of the main or head office
Fairfax
Text
Yes .*D9
All Share Accounts
State
Post office state code where borrower resides. For business accounts, provide the state of the main or head office
NM
Text
Yes .*D10
All Share Accounts
Zip Code
Zip code where borrower resides. For business accounts, provide the zip code of the main or head office
80521
Number
Yes .*D11
All Share Accounts
Insiders and Employees
If data supports, report “D” for directors, supervisory committee, and credit committee members, “O” for executive officers, and “E” for employees who are not executive officers. If the CEO is also the Board Treasurer, report as an executive officer—“O”. If the credit union or vendor data does not support this scheme, simply identify insider status with Y/N
E
Text
Yes.( print page 50451)D12
All Share Accounts
Non-member
Indicator to identify non-member share accounts
Y
Y/N
No.D13
All Share Accounts
Share Balance
Current balance of the share account, signed with two decimal places
156.45
Number
Yes .*D14
All Share Accounts
Share Type Code
System code to identify certificates, regular, draft, IRA, money market and other share deposit accounts
R
Text
Yes .*D15
All Share Accounts
Dividend Rate
Current dividend rate for each share account
2
Number
Yes .*D16
All Share Accounts
Date of Last Activity
Date of last deposit or withdrawal
03312017
Date
Yes .*D17
All Share Accounts
Share Amount Frozen
Dollar amount of the account the member cannot access
5000.00
Number
Yes .*D18
All Share Accounts
Last Activity Code
Identifies the type of account activity that occurred last by code
FM
Text
Yes.D19
All Share Accounts
Accrued Dividend Interest
Dollar amount of accrued dividends
25.36
Number
Yes.D20
All Share Accounts
Last File Maintenance Date
Last date of any non-financial modification to the account (
                            *e.g.,*
                             dividend rate, member address, etc.)
03312017
Date
Yes.D21
All Share Accounts
Last File Maintenance User ID or Initials
Approving official or employee's transaction code or initials
AH
Text
Yes.D22
All Share Accounts
Date Negative Shares
The date the share account first went negative without cure
03312017
Date
No.D23
All Share Accounts
Joint Owner
Provide the name of the joint owner's full legal name. Format: Last Name, Suffix (if applicable), First Name, Middle Initial for individuals. For businesses, provide full legal name
Long Sr., John, S
Text
No.D24
All Share Accounts
Membership Type
Provide the membership type using the following identifiers: Single ownership, Joint ownership, Trustee, or Business
Business
Text
No.D25
All Share Accounts
Last Statement Date
Date the member statement was last generated
03312017
Date
No.D26
Share Certificate Accounts
Step/Bump Dividend Rate
Indicator if the share certificate product has a term that allows the member to “step-up” or “bump-up” the dividend rate
Y
Y/N
No.D27
Share Certificate Accounts
Certificate Date Granted
Date member opened the share certificate account
03312017
Date
Yes .*D28
Share Certificate Accounts
Certificate Maturity Date
Date the share certificate will mature
03312017
Date
Yes .*D29
Business Accounts
Name of Beneficiaries
Full legal name of individuals who are beneficiaries on business accounts. Format: Last Name, Suffix (if applicable), First Name, Middle Initial
Long Sr., John, S
Text
No.
  Table 3—Security and Non-Negotiable CD Investment Electronic Fields 24
Number
Field
Description
Example
Data
                             format
Current NCUA 
                             standard  
                             fieldI1
Download Cut-off date
Effective date of the data
03312017
Date
No.I2
Record Code
Report D for Deposits, L for Loans, I for Investment
L
D/L/I
No.I3
CUSIP Number
Committee on Uniform Securities Identification Procedures number. Security identifier
23345abcd
Text
No.( print page 50452)I4
Original Face Value
Original face value of the investment
100,000
Number
No.I5
Current Face Value
Current face value of the investment
100,000
Number
No.I6
Book Value
Current book value of the investment
102,000
Number
No.I7
Fair Value
Current fair value of the investments
102,000
Number
No.I8
Maturity Date
Maturity date of investment
12312017
Date
No.I9
Coupon/Rate
Stated coupon or rate of investment
5
Number
No.I10
Floating Rate
Indicator if the investment has floating rate
Y
Y/N
No.I11
Issuer
Name of issuer of the investment
Wells Fargo Bank
Text
No.I12
Settlement Date
Date funds are exchanged
10312015
Date
No.
  Table 4—Consumer and Credit Card Loan Electronic Fields
Number
Field
Description
Example
Data
                             format
Current NCUA 
                             
                                standard field 25
ILDR Field 26C1
Effective date of the download
Effective date of the data
03312017
Date
No
No.C2
Record Code
Indicate D for Deposits, L for Loans, I for Investment
L
D/L/I
Yes*
No.C3
Taxpayer ID
Nine digit code used by the US Government (TIN). For individuals use social security number
123456789
Number
Yes*
Yes.C4
Borrower ID
Primary key identifier for the entity. This is the number used to uniquely identify the member/non-member such as an account number
ABC123456
Text
Yes*
Yes.C5
Member Name
Full legal name. Format: Last Name, Suffix (if applicable), First Name, Middle Initial for individuals. For business provide full legal name
Long Sr., John, S
Text
Yes*
Yes.C6
Address Line 1
Street address
7247 Circle Sun
Text
Yes*
Yes.C7
Address Line 2
Address line 2
PO Box 858
Text
Yes
Yes.C8
City
City where borrower resides. For business accounts, provide the city of the main or head office
Fairfax
Text
Yes*
Yes.C9
State
Post office state code where borrower resides. For business accounts, provide the state of the main or head office
NM
Text
Yes*
Yes.C10
Zip Code
Zip code where borrower resides. For business accounts, provide the zip code of the main or head office
80521
Number
Yes*
Yes.C11
Insiders and Employees
If data supports, report “D” for directors, supervisory committee, and credit committee members, “O” for executive officers, and “E” for employees who are not executive officers. If the CEO is also the Board Treasurer, report as an executive officer—“O”. If the credit union or vendor data does not support this scheme, simply identify insider status with Y/N
E
Text
Yes
Yes.C12
Business Type
Provide the member's North American Industry Classification System (NAICS) code where majority of their revenue is generated from
54194
Text
No
Yes.C13
Branch ID
Identifies the originating service facility
01C
Text
Yes
Yes.C14
Loan ID
Unique identifier for each loan
A
Text
No
Yes.( print page 50453)C15
Loan Category
The type of loan. Provide “Commercial/MBL”, “Residential Real Estate”, or “Consumer”
Commercial
Text
No
No.C16
Loan Type
The type of loan product as defined by the vendor or credit union (e.g. New or Used Auto, Credit Card Fixed, Credit Card Variable, etc.)
Capital LOC
Text
Yes*
Yes.C17
Purpose Code
Description of what the proceeds will be used for; Reason for loan
Auto purchase
Text
Yes*
Yes.C18
Origination Date
The note date; date the loan was originated. Do not report the date of last advance
03312017
Date
Yes*
Yes.C19
Original Loan Amount
The original principal amount of the loan
1500.45
Number
Yes*
Yes.C20
Payment Amount
Amount of regularly scheduled payment
780.25
Number
Yes*
Yes.C21
Loan Term
The contractual number of payments required by the note or modification of the note
60
Number
Yes*
Yes.C22
Payment Frequency
The interval of time payments are contractually required (monthly, quarterly, annually, balloon/maturity, etc.)
M
Text
Yes*
Yes.C23
Balloon Flag
Indicator the loan is a balloon loan
Y
Y/N
No
No.C24
Balloon Term
Number of months from origination until balloon date
84
Number
No
No.C25
Interest Only Flag
Indicator the borrower pays only the interest on the principal balance for a set period of time, with the principal balance unchanged
Y
Y/N
No
No.C26
Interest Only Term
The length of time (in months) during which the borrower pays only interest on the principal balance
12
Number
No
No.C27
First Payment Date
Date the first payment was/is due
03312017
Date
No
No.C28
Maturity Date
Date when full payment on the loan is contractually due. For balloon loans, this should be the same as the balloon expiration date
03312017
Date
No
Yes.C29
Interest Rate
The contractual rate of interest currently applied to this loan at origination
5.000
Number
Yes*
Yes.C30
Loan Type
The type of loan product as defined by the vendor or credit union (e.g. New or Used Auto, Credit Card Fixed, Credit Card Variable, etc.)
Capital LOC
Text
Yes
Yes.C31
Current Interest Rate
The contractual rate of interest currently applied to this loan
5
Number
No
Yes.C32
First Rate Adjustment Date
Initial date the interest rate will/did adjust on variable rate loans
03312017
Date
No
No.C33
Next Rate Adjustment Date
Future date interest rate will adjust on variable rate loans
03312017
Date
No
No.C34
Lifetime Interest Rate Cap
The maximum rate the loan can reach over its contractual term
18.000
Number
No
Yes.C35
Interest Rate Floor
The minimum rate the loan can reach over its contractual term
4.000
Number
No
No.C36
Variable Rate Index
Interest rate base index used when the loan's rate varies with an index
Prime
Text
No
Yes.C37
Variable Rate Margin
The margin added or subtracted from the index to get the rate
2
Number
No
No.C38
Current Credit Limit
The maximum a borrower can currently incur
2500.00
Number
No
No.C39
Date Closed
Date a line of credit was closed
03312017
Date
No
No.C40
Credit Score at Origination
Credit score of the primary borrower (e.g. FICO or Beacon) obtained from a credit bureau that was used in the underwriting of the credit. If two bureau scores were used, provide the highest score. If the credit union obtains all three bureau scores, provide the middle score
825
Number
Yes*
Yes.C41
Original Credit Score Date
Date of the primary borrower's credit score at origination
03312017
Date
No
No.( print page 50454)C42
Current Credit Score
Most recent primary borrower credit score obtained by the credit union
745
Number
No
No.C43
Current Credit Score Date
Most recent date of updated credit score for the primary borrower
03312017
Date
No
No.C44
Guarantor
Name of entity/person that guarantees the loan. With multiple guarantors, give the primary one
Long Sr., John, S
Text
No
Yes.C45
Co-Maker/Co-Borrower/Guarantor
The name of the co-maker/co-borrower whose signature(s) appears on the promissory note or loan agreement. Provide the first one when there are multiple co-makers/co-borrowers
Long Sr., John, S
Text
No
Yes.C46
Co-Maker/Co-Borrower Credit Score at Origination
Credit score of the co-maker/co-borrower at the time of origination
680
Number
No
No.C47
Current Credit Score Date of Co-Borrower
Most recent date of updated credit score of the co-borrower/co-maker
03312017
Date
No
No.C48
Original Credit Score Date of Co-Borrower
Credit score of the co-borrower/co-maker (e.g. FICO or Beacon) obtained from a credit bureau that was used in the underwriting of the credit. If two bureau scores were used, provide the highest score. If the credit union obtains all three bureau scores, provide the middle score
800

No
No.C49
Loan Officer
Code or loan officer name responsible underwriting and/or borrower relationship
BB
Text
No
Yes.C50
Loan Approver
Code or name of approving official. Indicate if approved by the Credit Committee or Board of Directors
AG
Text
Yes
No.C51
Loan Risk Grade
Credit union internal risk rating at origination. The credit union's internal loan risk grade (e.g., A, B, C, or D paper)
A
Text
Yes
Yes.C52
Collateral Protection Insurance
Indicator loan has coverage for when insurance coverage lapses
Y
Y/N
No
No.C53
GAP Indicator
Indicator the member purchased gap insurance on the collateral
Y
Y/N
No
No.C54
Credit Life
Indicator loan has a life insurance policy designed to pay off the borrower's debt if they die
Y
Y/N
No
No.C55
Credit Disability
Indicator loan has disability insurance designed to pay the borrower's debt if they become disabled
N
Y/N
No
No.C56
Loan Collateral
The narrative description of the collateral (e.g., year, make and model; 38 unit apartment building, etc.)
1996 Ford Mustang
Text
No
Yes.C57
Collateral Code
The system code associated with the collateral type (e.g., residential real estate, etc.)
Residential real estate
Text
Yes*
Yes.C58
Origination Collateral Value
Total value of collateral at loan origination
50000.00
Number
No
Yes.C59
Collateral Valuation/Appraisal Date (Origination)
Date collateral was appraised or valued at loan origination
20170313
Date
No
Yes.C60
Current Collateral Value
Dollar value of collateral when last assessed by the credit union
45150.65
Number
No
No.C61
Most Recent Collateral Value/Appraisal Date
Date collateral was last appraised or valued
03312017
Date
No
Yes.C62
Lien Position
The credit union's lien position on the collateral (e.g., 1st, 2nd, 3rd, etc.). If more than one collateral, identify the primary collateral's lien position
1
Number
No
Yes.C63
VIN Number
Vehicle Identification Number/unique identifier for collateral
1GTV2TEH8EZ173011
Text
No
No.( print page 50455)C64
Current Loan Balance
Current outstanding principal balance of the loan. If the member has overpaid the note and the credit union is carrying a credit balance, provide the number as a negative balance with a minus sign as the first character (e.g., −33.56)
84500.01
Number
Yes*
Yes.C65
Date of Last Payment
Date the last payment was made
03312017
Date
No
Yes.C66
Number of Remaining Payments
The remaining contractual number of payments required by the loan
24
Number
Yes*
No.C67
Next Payment Due Date
The date the next payment, principal or interest, is due. For delinquent loans, this will be in the past
03312017
Date
Yes*
Yes.C68
Accrued Interest
Total amount of interest accrued and not yet received on a loan
180.32
Number
Yes*
Yes.C69
Late Charges
Late charges currently due and unpaid
95.06
Number
No
Yes.C70
Debt to Income Ratio
Debt payments divided by gross or net income calculated at time of loan origination
35.670
Number
No
No.C71
Days Past Due
Number of days the note is past due beyond the due date as of the effective date of the download. If loan is current or paid ahead, report as zero
75
Number
Yes*
Yes.C72
Delinquency Counter 30-59 Days
Number of times past due 30-59 days since origination date
2
Number
Yes
Yes.C73
Delinquency Counter 60-89 Days
Number of times past due 60-89 days since origination date
4
Number
Yes
Yes.C74
Delinquency Counter 90-119 Days
Number of times past due 90-119 days or more since the origination date
0
Number
Yes
Yes.C75
Delinquency Counter 120 Days +
Number of times past due 120+ days or more since the origination date
1
Number
Yes
Yes.C76
Last Renewal Date
The date the loan was last renewed
03312017
Date
No
Yes.C77
Loan Modification
Indicator if the loan has been modified. A loan modification permanently restructures the terms of an existing loan. A loan modification is not a new loan, but a renegotiation of an existing loan
Y
Y/N
No
No.C78
Date of Loan Modification
Date of last loan modification
20170313
Date
No
Yes.C79
Capitalized Interest Amount
Amount of interest added to the loan principal balance
259.63
Number
No
Yes.C80
Amount of last advance
Dollar amount of the last advance
55000.00
Number
No
No.C81
Interest rate reset interval
Time between periodic reset dates for variable or adjustable rate loans expressed in days.
30
Number
No
Yes.C82
Troubled Debt Restructure
Indicates if a loan is currently a troubled debt restructure as defined by GAAP
Y
Y/N
No
Yes.C83
Nonaccrual
Indicate if the loan is currently on nonaccrual
N
Y/N
No
Yes.C84
Charge-Off Flag
Indicator if entire loan has been charged off
Y
Y/N
No
No.C85
Charge Off Amount
Amount of principal charged off this loan
5000.00
Number
Yes
Yes.C86
Charge Off Date
Date the loan was charged off
03312017
Date
No
No.C87
Last File Maintenance Date
Date of last file maintenance change on this loan
03312017
Date
Yes
No.C88
Last File Maintenance User ID or Initials
User ID of person who made last file maintenance change
JB100
Text
Yes
No.C89
Last File Maintenance action Code
Description of what was last changed on the member loan (e.g., due date, name, loan status, etc.)
DD
Text
No
No.( print page 50456)C90
Interest Rate Spread
Interest rate variance from the index rate changed on the note. Express in terms of a percentage. For example, the premium of a note written at Prime +2.25% would be expressed as 2.25
2.25
Number
No
Yes.
 Table 5—Indirect Loan Electronic Data Fields
Number
Field
Description
Example
Data
                             format
Current NCUA field
ILDR fieldIncludes all fields from 
                            *Table 4: Consumer and Credit Card Loan Electronic Data Fields*
                             and the following:ID1
Dealer Code
Name of sales agent for indirect auto loans
Hanks Auto Sales
Text
No
Yes.ID2
Indirect Loan Flag
Indicator if the loan was originated through an indirect loan program
Y
Y/N
No
No.ID3
Dealer Reserve Balance
Current dealer reserve against the note
3,000
Number
No
Yes.
 Table 6—Participation Loan Electronic Data Fields
Number
Field
Description
Example
Data
                             format
Current NCUA field
ILDR fieldIncludes all fields from 
                            *Table 4: Consumer and Credit Card Loan Electronic Data Fields*
                             and the following:P1
Participation Sold (Original Amount)
The original amount of this note that was sold
9,000,000
Number
No
Yes.P2
Participation Sold (Current Balance)
The current balance of the amount sold
8,750,000
Number
No
Yes.P3
Participation Purchases (Original Amount)
The original amount of this note that was purchased
9,000,000
Number
No
No.P4
Participation Purchases (Current Balance)
The current balance of the amount purchased
8,750,000
Number
No
No.P5
Purchase percentage
Shows the percentage of the total participation loan owned by the credit union for individual loan purchases
20.000
Number
No
No.P6
Originating/Lead Lender
Shows the name of the originating/lead lender in the participation
ABC FCU
Text
No
No.P7
Sold Percentage
Identify the percentage of total participation loan the credit union sold
90.999
Number
No
No.
 Table 7—Residential Real Estate Loan Electronic Data Fields
Number
Field
Description
Example
Data
                             format
Current NCUA field
ILDR fieldIncludes all fields from 
                            *Table 4: Consumer and Credit Card Loan Electronic Data Fields*
                             and the following:R1
Property Type
Indicate the property type (
                            *e.g.,*
                             Single, Multi, Condominium, etc.)
Condo
Text
No
No.R2
Collateral State
Post office state code where collateral property is located
AZ
Text
No
No.R3
Collateral City
City where collateral property is located
Phoenix
Text
No
No.R4
Collateral County
County where collateral property is located
Maricopa
Text
No
No.R5
Collateral Zip Code
Zip code where collateral property is located
85255
Number
No
No.R6
Property in Flood Zone
Indicator if the collateral securing the loan is in a designated flood zone
Y
Y/N
No
No.R7
Draw Period
Remaining period of time (in months) a borrower can withdraw funds from a credit account
120
Number
No
No.( print page 50457)R8
Current Escrow Balance
Amount currently in escrow for payment to third parties such as insurance and real estate taxes. In the case of a negative escrow balance, report the data in this field with a minus sign in the first character position (
                            *e.g.,*
                             −350)
2,585
Number
No
Yes.R9
Number of Renewals
Indicate the number of times the loan has been renewed
2
Number
No
Yes.
 Table 8—Commercial/Member Business Loan Electronic Data Fields
Number
Field
Description
Example
Data
                             format
Current NCUA field
ILDR fieldIncludes all fields from 
                            *Table 4: Consumer and Credit Card Loan Electronic Data Fields*
                             and the following:CL1
Current Loan Risk Grade Commercial/MBL
Credit union internal risk rating at recent review/evaluation of commercial/MBL; Number or letter grade determined based on the level of risk
1
Text
No
Yes.CL2
Date of Current Loan Risk Grade Commercial/MBL
Date the most recent internal risk rating at recent review/evaluation of commercial/MBLs
03312017
Date
No
Yes.CL3
Debt Service Coverage Ratio (DSCR)
Debt service coverage ratio calculated for the loan at origination
1.05
Number
No
No.CL4
Personal guaranty status
Identify the level of personal guaranty of the principals (
                            *e.g.,*
                             full, limited, or none)
Full
Text
No
No.CL5
Environmental Review Level at origination
Identify the level of environmental review at origination (
                            *e.g.,*
                             borrower questionnaire, record search, phase 1, or phase 2)
Phase 1
Text
No
No.CL6
Environmental Review Date
Date of environmental review at origination
03312017
Date
No
No.CL7
Last Periodic Review
Date of last periodic/annual file review
03312017
Date
No
No.CL8
Property Type
Indicate the property type (
                            *e.g.,*
                             Single, Multi, Condominium, etc.)
Condo
Text
No
No.CL9
Collateral State
Post office state code where collateral property is located
AZ
Text
No
No.CL10
Collateral City
City where collateral property is located
Phoenix
Text
No
No.CL11
Collateral County
County where collateral property is located
Maricopa
Text
No
No.CL12
Collateral Zip Code
Zip code where collateral property is located
85255
Number
No
No.CL13
Property in Flood Zone
Indicator if the collateral securing the loan is in a designated flood zone
Y
Y/N
No
No.CL14
Draw Period
Remaining period of time (in months) a borrower can withdraw funds from a credit account
120
Number
No
No.CL15
Current Escrow Balance
Amount currently in escrow for payment to third parties such as insurance and real estate taxes. In the case of a negative escrow balance, report the data in this field with a minus sign in the first character position (
                            *e.g.,*
                             −350)
2,585
Number
No
Yes.CL16
Policy Exception
Indicator if the loan is an exception to policy
Y
Y/N
No
No.CL17
Number of Renewals
Indicate the number of times the loan has been renewed
2
Number
No
Yes.CL18
Specific Reserve
Amount of specific reserve for loan losses on this note which is not available to offset losses on any other loan
50,000
Number
No
Yes.
 
 
 Table 9—Student Loan Electronic Data Fields
Number
Name
Description
Example
Data
                             format
Current NCUA field
ILDR fieldIncludes all fields from 
                            *Table 4: Consumer and Credit Card Loan Electronic Data Fields*
                             and the following:S1
Time to Repayment
For deferred loans: Amount of time, in months, until repayment period begins
65
Number
No
No.S2
Deferred Status
Indicator if student loan is in deferred status
Y
Y/N
No
No.
 By the National Credit Union Administration Board on October 19, 2017. Gerard Poliquin, Secretary of the Board.


# Footnotes

1.
    
                         Offline systems is defined as other IT systems not connected or linked to the core data processing system or third party vendors with loan, deposit, and investment data. These may include, but are not limited to, credit cards, mortgage loans, student loans, indirect loans, etc. Back to Citation
 2.
    
                         
                        *https://www.ncua.gov/​About/​Documents/​exam-flexibility/​exam-flexibility-initiative-report-2016-oct.pdf* Back to Citation
 3.
    
                         A standard data format will not replace or eliminate all examiner data requests occurring during an examination. NCUA encourages responders to recommend other data sources that NCUA could standardize to improve exam efficiency. Back to Citation
 4.
    
                         Implemented in 2014, NCUA's Office of National Examination and Supervision (ONES) collects detailed loan level data and select share data to run stress test scenarios and loan portfolio analytics for supervisory purpose. Currently, these credit unions send monthly data to NCUA on a quarterly basis using standard templates with 191 unique data fields relevant to each data type including automobile, credit cards, student, real estate, member business loans, and other consumer loans. The sample formats in this RFI include 53 similar fields to those collected by ONES. Back to Citation
 5.
    
                         NCUA Letter to Credit Unions Number 179, (September 1995). Back to Citation
 6.
    
                         The download file for both loans and shares include the 12 member profile fields. Back to Citation
 7.
    
                         NCUA Letter to Credit Unions 00-CU-09 (November 2000). Back to Citation
 8.
    
                         NCUA Letter to Credit Unions 03-CU-05 (April 2003). Back to Citation
 9.
    
                         NCUA combined the member name, first name, last name, and middle initial into one field. Additionally, the zip code fields were consolidated and social security number was added to the share download resulting in the number of unique member profile fields to decline from 12 to 8. The member profile fields are currently included in each loan and each share download. Back to Citation
 10.
    
                         NCUA Letter to Federal Credit Unions 09-FCU-03 (January 2009). Back to Citation
 11.
    
                         Includes unsecured loans, lines of credit, vehicle loans, short-term, small dollar amount loans, and leases receivable. This number may include some overlap with indirect, participation, and commercial/MBLs based on categories of reporting on the 5300 Call Report. 12.
    
                         The December 31, 2003 5300 Call Report only collected Indirect Loans Granted Year-To-Date. NCUA first started collecting total outstanding indirect loans with the March 31, 2014 Call Report. Credit unions reported a total of $97.35B indirect loans as of March 31, 2014. Since that initial reporting, indirect loans have increased 77.3%. 13.
    
                         Total real estate loans includes commercial/MBLs secured by real estate. 14.
    
                         Non-federally guaranteed student loans as reported on the 5300 Call Report. NCUA first started collecting this information with the March 31, 2014 Call Report. Credit unions reported a total of $2.84B non-federally guaranteed student loans as of March 31, 2014. Since that initial reporting, these loans have increased 40.49%. Back to Citation
 15.
    
                         Most credit unions must obtain reports from other systems and third party vendors for real estate, commercial/member business loans, student loans, credit cards, participation, and indirect loans. Examiners primarily receive consumer and real estate loan information in the current loan and share download limited to the data fields defined in NCUA Letter to Credit Unions 03-CU-05. Back to Citation
 16.
    
                         FIPS Publication 199, 
                        *Standards for Security Categorization of Federal Information and Information Systems;*
                         FIPS Publication 200, 
                        *Minimum Security Requirements for Federal Information and Information Systems.* Back to Citation
 17.
    
                         NIST Special Publication 800-53 (Rev. 4), 
                        *Security and Privacy Controls for Federal Information Systems and Organizations.* Back to Citation
 18.
    
                         The results of these audits are reported both internally and externally to ensure completion of all remedial findings. Credit Unions and their members can review OIG Audit Reports, Semiannual Reports and Letter to Congress at 
                        *https://www.ncua.gov/​About/​Pages/​inspector-general/​reports.aspx.* Back to Citation
 19.
    
                         NCUA is modernizing our examination platform and analytics. The new data format will be used with these technological advancements. Until the current systems that use the existing download are retired, examiners will need the current download file as existing tools may not be able to accommodate a new download data format. Back to Citation
 20.
    
                         These data formats include 9 member profile, 18 deposit, 120 loan, and 12 investment unique data files. They include all data fields listed in Letter to Credit Unions 03-CU-05, except three data fields that would be overlapping with new data fields—Date of Last Activity, Last Activity Code, and Credit Limit at origination. Back to Citation
 21.
    
                         As of March 31, 2017, FICUs reported the following investments: Securities: 40.9% of all FICUs; Non-negotiable CDs: 83.7%. Back to Citation
 22.
    
                         Loan types include consumer, indirect, participations, residential real estate, student loans, and commercial/member business loans. As of March 31, 2017, FICUs reported the following loan services: Consumer: 100% of FICUs; Indirect: 33.1%; Participation: 27.2%; Real estate: 75.6%; Non-guaranteed federal student Loans: 12.1%; Commercial/MBL: 37.9%. Back to Citation
 23.
    
                         Identifies fields requested in NCUA Letter to Credit Unions 03-CU-05 (April 2003). Fields identified with an asterisk (*) are categorized as “critical” fields by NCUA in Letter to Credit Unions 03-CU-05. Back to Citation
 24.
    
                         NCUA has not previously published a standard structure for investment data. This will facilitate robust analytics with a dynamic, quantitative third-party service platform for interest rate risk assessment of individual securities and portfolios without requiring the examiner to reformat data files or request additional data from the credit union. Back to Citation
 25.
    
                         Identifies fields requested in NCUA Letter to Credit Unions 03-CU-05 (April 2003). Fields identified with an asterisk (*) are categorized as “critical” fields by NCUA in Letter to Credit Unions 03-CU-05. 26.
    
                         NCUA reviewed the Interagency Loan Data Request (ILDR) issued in March 2013. The ILDR provides a standard format for banks to electronically provide loan data. In comparison to the 82 data fields in the ILDR, the sample loan formats include 61 similar loan fields. 
                        *https://www.fdic.gov/​news/​news/​financial/​2013/​fil13012.html*. Back to Citation


[FR Doc. 2017-23219 Filed 10-30-17; 8:45 am] BILLING CODE 7535-01-P