I need assistance filling out FFIEC Call Report Schedule RC-C – Loans and Leases. Specifically, when asked to list maturity and repricing data for closed-end loans secured by first liens on 1-4 family residential properties (in the Memoranda for Part I), should I include commercial purpose loans secured by residential property? Are there any OCC bulletins that offer guidance on this question?

Yes, in the section you have identified, you should include data on all loans secured by a 1–4 family residential property, regardless of the loan purpose.

You asked about Call Report Schedule RC-C (Loans and Leases). Specifically, you asked about question 2 on the Memoranda for Part I, which asks you to list the following:

“2. Maturity and repricing data for loans and leases (excluding those in nonaccrual status): a. Closed-end loans secured by first liens on 1–4 family residential properties (reported in Schedule RC-C, Part I, item 1.c.(2)(a), column B) with a remaining maturity or next repricing date of: . .[various timeframes]. . .”

This question requires you to use the data entered in RC-C Part 1, item 1.c(2)(a). The FFIEC Call Report Instructions for item 1 state that this item should include all loans secured by real estate, regardless of purpose (other than loans to states and political subdivisions in the U.S.).

In addition, the glossary for the FFIEC Call Report reiterates that when a loan is secured wholly or substantially by a lien on real property, the loan should be reported “as a loan secured by real estate” in Schedule RC-C, part I, item 1 and related items, regardless of the purpose of the financing (unless the real estate is taken as collateral through an abundance of caution or when the real estate only partially secures a loan).

Consequently, for the purpose of answering Memoranda Question 2, we believe you should include all loans secured by a 1–4 family residential property, regardless of the loan purpose.

For resources related to our guidance, please see:

FFIEC Call Report, RC-C, Part I, item 1.c.(2)(a), Memoranda, Question 2, page 25 (“2. Maturity and repricing data for loans and leases (excluding those in nonaccrual status): a. Closed-end loans secured by first liens on 1–4 family residential properties (reported in Schedule RC-C, Part I, item 1.c.(2)(a), column B) with a remaining maturity or next repricing date of: . .”)

FFIEC Call Report Instructions, Schedule RC-C, page 2, Instructions for Part I, Item 1, Loans secured by real estate (“Include all loans (other than those to states and political subdivisions in the U.S.), regardless of purpose . . . that are secured by real estate as evidenced by mortgages, deeds of trust, land contracts, or other instruments, whether first or junior liens (e.g., equity loans, second mortgages) on real estate.”)

FFIEC Call Report Glossary, Loan Secured by Real Estate, page 80 (“For purposes of these reports, a loan secured by real estate is a loan that, at origination, is secured wholly or substantially by a lien or liens on real property for which the lien or liens are central to the extension of the credit — that is, the borrower would not have been extended credit in the same amount or on terms as favorable without the lien or liens on real property.”)

FFIEC Call Report Glossary, Loan Secured by Real Estate, page 81 (“A loan satisfying the criteria above, except a loan to a state or political subdivision in the U.S., is to be reported as a loan secured by real estate in Schedule RC-C, part I, item 1, and related items in the Reports of Condition and Income . . . regardless of the purpose of the financing.”)

FFIEC Call Report Glossary – Loan Secured by Real Estate, page 81 (“Only in a transaction where a lien or liens on real property (with an estimated collateral value greater than 50 percent of the loan’s principal amount at origination) have been taken as collateral solely through an abundance of caution . . . would the loan not be considered a loan secured by real estate for purposes of the Reports of Condition and Income. In addition, when a loan is partially secured by a lien or liens on real property, but the estimated value of the real estate collateral at origination (after deducting any more senior liens held by others) is 50 percent or less of the principal amount of the loan at origination, the loan should not be categorized as a loan secured by real estate. Instead, the loan should be reported in one of the other loan categories used in these reports based on the purpose of the loan.”)