5300 Call Report FAQs

Find answers below to frequently asked questions about the NCUA's 5300 Call Report.

For information about the March 2022 Call Report changes, view the following video:

 

General Questions

How long must I keep copies of the 5300 Call Report?

Part 749 of the NCUA regulations requires credit unions to keep either a hard copy or an electronic copy in their permanent records.

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Do I have to certify my Profile before I correct a 5300 Call Report?

Is NCUA waiving late filing fees for the March 2022 cycle?

The NCUA is not imposing civil money penalties for the March 2022 Call Report cycle.

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Statement of Financial Condition – Assets

Why won't the Call Report permit me to enter a negative (credit) balance for "Cash on Hand"? [Account 730A]

"Cash on Hand" means coin, currency, and cash items on hand. It is not possible to have negative cash on hand.

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Why do the Call Report instructions direct us to report multi-coupon instruments (step-ups) based on period remaining to maturity rather than the next step-up date?

This data feeds into the credit union's Risk Based Net Worth (RBNW) calculation. For PCA purposes, step-ups are risk-weighted at the period remaining to maturity. (The NCUA regulations part 702)

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Why do the Call Report instructions direct us to report FHLB stock in the “greater than 1 year, but less than or equal to 3 year” category? There is a 5-year notice requirement from the FHLB.

This data feeds into the credit union's Risk Based Net Worth (RBNW) calculation. For PCA purposes, FHLB stock is risk-weighted at 6% (>1 but < = 3 years). (The NCUA regulations part 702)

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Can I report loans, other than real estate loans, as "Loans Held for Sale"? [Account 003]

Where should credit unions report overdraft protection program advances (also referred to as bounced-check protection and courtesy pay)? [Account 397]

You should report these advances under "All Other Unsecured Loans/Lines of Credit." According to the Joint Guidance on Overdraft Protection Programs transmitted with Letter to Credit Unions 05-CU-03, when the credit union pays overdrafts, credit is extended. You should report overdraft balances as loans. Accordingly, you should charge off overdrafts against the allowance account.

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Why won't the call report software permit me to enter a debit balance for "Allowance for Loan & Lease Losses" or “Allowance for Credit Losses”? [Accounts 719 and AS0048]

A debit allowance balance does not comply with GAAP guidelines and is contrary to the concept of an allowance for losses.

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If a credit union repossessed collateral and has written it down to fair value (less cost to sell), is it reported as delinquent on the call report? [Account 798A]

No. The credit union should write down the repossessed collateral to fair value (less cost to sell) at the time of repossession. If the credit union intends to sell the repossessed collateral, you should move it out of loans and into "Foreclosed and Repossessed Assets." There should be no delinquency balance remaining on the books when moved out of loans because of the write down.

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In the instructions for "Foreclosed and Repossessed Assets," you refer to "long-lived assets." What is a "long-lived asset?” [Account 798A]. 

GAAP does not define "long-lived assets." Presumably, they are depreciable assets (automobiles, equipment, and real estate) with a useful life in excess of one year. An asset whose future benefit is expected for a number of years is also called long-term asset.

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I’d like to get some specificity about how to report 457F plan investments (used to fund employee benefits). Can you provide guidance with respect to what practical expedients can be utilized to determine if the various investments are part 703 compliant?

If they are securities, 457F investments are reported on the Statement of Financial Condition as either equity securities, trading debt securities, available-for-sale securities, or held-to-maturity securities. Additionally, 457F investments are reported in Schedule B by security type with additional valuation information included. 457F investments that are non-securities will be reported on other sections of the Statement of Financial Condition, consistent with generally accepted accounting principles. Lastly, 457F investments are also reported on Schedule B, Section 4, line 11 by type listed.

As for determining if investments are part 703 compliant, credit unions can refer the subpart A of part 703 and the FCU Act, specifically §§ 1757 (7), (8) and (15).

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Where should regular reserves be reported: undivided earnings or other reserves?

Report regular reserves in Undivided Earnings (account 940).

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Statement of Income and Expense 

For financial reporting purposes, may credit unions net ATM fees and ATM expenses on the Call Report; or must they report gross ATM income and gross ATM expense in the corresponding income and expense lines of the Call Report?

A credit union must report gross ATM income in the income section of the income statement and ATM expenses in the expenses section of the income statement. You should not net the ATM income and expenses.

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Where do low-income designated federal credit unions report interest on deposits? It is not under "Interest on Deposits" because this only applies to SCUs. [Account 380]

You should report interest on deposits under "Dividends on Shares." The Federal Credit Union Act authorizes low income designated FCUs to receive shares, share drafts, and share certificates from nonmembers. The FCU Act refers to these as shares, not deposits. We maintain the same nomenclature in the Call Report. (FCU Act §107(6))

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PCA Net Worth Calculation Worksheet

How can the optional Total Assets Elections on lines 10-12 benefit a credit union?

By using one of the optional total assets elections as the denominator in the net worth calculation, a credit union may receive a higher net worth ratio. As a result, a credit union could improve its net worth position to above 7% and not be subject to PCA requirements if the standard net worth calculation is below 7%.

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Schedule A, Section 1 - Loans

How do we treat lines of credit when reporting loans granted year-to-date? [Accounts 031A, 031B]

Report 1 loan granted year-to-date for any line of credit (including credit card loans) that has an advance on it in that year. The credit union will either report "1" (one or more advances in that year) or "0" (no advances in that year). The amount reported would include all advances in that year.

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Schedule A, Section 2 - Delinquent Loans

How does a credit union with a commercial loan that has real estate as the collateral, report it on the delinquent loan schedule? Is there double counting?

Delinquent commercial loans are reported in Schedule A, Section 2 - Delinquent Loans & Leases. Look for the part of this section specific to Commercial Loans and report delinquent Commercial Loans based on the collateral securing the loan. Only those delinquent loans included in Account 041B will be included in the delinquent loan ratio.

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Schedule A, Section 3 - Charge-Offs/Recoveries

How does a credit union with a participation loan that has real estate as the collateral, report it on the Loan Charge offs and Recoveries schedule? Is there double counting?

The credit union would report the participation loan charge-off or recovery in Schedule A, Section 3 - Loan Charge Offs and Recoveries based on the collateral securing the participation loan. The same amount would need to be reported in Account 550F, if a charge off, or Account 551F, if a recovery. The amounts reported in Account 550F or 551F do not affect the net charge-off ratio.

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Schedule A, Section 4 - Other Loan Information

Schedule A, Section 5 - Indirect Loans

Schedule A, Section 6 - Loans Purchased and Sold Under 701.22 and 701.23

Should I report "table funded" loans as loans sold in the secondary market? [Account 736]

No. Loans that are not funded by the credit union and, at settlement, are assigned to the party advancing the funds should not be reported as loans sold. (See the NCUA rules and regulations Part 760 for a definition of table funded loan.)

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If a credit union participates out real estate loans, should I report the portion participated out as real estate loans sold with servicing retained by the credit union? [Accounts SL0028, SL0029, SL0030, and 779A]

Yes. You should report the real estate loans as sold with servicing retained as long as the credit union still services the loans.

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The instructions for "Loans Transferred with Limited Recourse Qualifying for Sales Accounting" tell us not to include participations transferred with substantial recourse. Why? [Account 819]

If you transfer a loan with "substantial recourse" per GAAP, the credit union is required to keep the loans on its books. You would record a loan, but no contingent liability.

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If a credit union uses an open-end loan form (such as LOANLINER®) for secured loans, is the difference between the approved limit and the outstanding balance reportable as an unfunded commitment? [Account 816B5]

Yes. Credit unions using open-end loan forms should report the difference between approved limits and outstanding balances under “Other Unfunded Commitments.”

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Schedule A, Section 7 - 1- to 4-Family Residential Real Estate Loans

When reporting the number and amount of loans outstanding on the real estate loan schedule, do we report based on original maturity, remaining maturity, or period remaining until next adjustment?

Report fixed-rate loans based on original maturity. Report balloons/hybrids based on the period the original interest rate remains fixed. Report adjustable-rate loans based on the adjustment period.

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Account RL0050 captures the amount of real estate loans outstanding that contractually refinance, reprice or mature within the next five years. Do I also report real estate loan cash flows over the next five years on loans not refinancing, not repricing or not maturing in the next five years? [Account RL0050]

No. The NCUA uses account RL0050 in the net long-term assets calculation. Reporting cash flows on long-term real estate loans results in an underreporting of the credit union’s ratio of net long-term assets.

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Schedule A, Section 8 - Commercial Loans

A credit union has $35,000 in business purpose loans to a member and makes a $40,000 business purpose loan to the same member. How much does the credit union report as a member business loan -- $40,000, $35,000, or $75,000? [Account 400A]

The credit union would report $40,000, and would comply with all of the requirements of part 723 in making this loan because the loan caused the aggregate amount of business purpose loans to the member to exceed the $50,000 threshold in the NCUA rules and regulations §723.8.

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Where do we report loans that would be commercial loans except that the commercial purpose lending relationship has an outstanding aggregate balance below $50,000? [Various Accounts]

These loans are not Commercial Loans as defined in the NCUA regulations §723.2 and as such you will report them as you would any other Non-Commercial loan based on the loan characteristics in the various schedules.

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Can the same loan be both a Commercial Loan and a Member Business Loan? [Accounts 400A1, 400B1, 400A]

Yes. The definition of Commercial Loan and Member Business Loan are both distinct and not mutually exclusive. Attention must be paid to the specific definitions of each. Commercial Loans and Member Business Loans are defined in the NCUA rules and regulations §723.2 and §723.8 respectively. See the quick reference chart below:

Commercial Loans and Member Business Loans
Type of Loan Member Business Loan Commercial Loan
Loan secured by a single 1- to 4-family residential property (whether or not secured by a member’s primary residence) No No
Loan secured by more than one 1- to 4-family residential properties Yes Yes
Business loan secured by a vehicle manufactured for household use Yes No
Business loan secured by a vehicle used in a fleet or to carry fare-paying passengers Yes Yes
Business loan with aggregate net member business loan balance less than $50,000 No No
Business loan fully secured by shares in the credit union making the extension of credit or deposits in other financial institutions No No
Business loan in which a federal or state agency (or its political subdivision) fully insures repayment, fully guarantees repayment, or provides an advance commitment to purchase the loan in full No Yes
Non-member business loan or non-member participation interest in a commercial loan made by another lender No Yes
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Once a loan is classified as a Commercial Loan is it then always a Commercial Loan even if the balance falls below $50,000? [Account 400A1 or 400B1]

No. These loans are no longer Commercial Loans. Likewise, they are no longer Member Business Loans.

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Account CM0099 captures the amount of real estate loans outstanding that contractually refinance, reprice, or mature within the next five years. Do I also report the real estate loan cash flows over the next five years on loans not refinancing, not repricing, or not maturing in the next five years? [Account CM0099]

No. The NCUA uses account CM0099 in the net long-term assets calculation. Reporting cash flows on long-term real estate loans results in an underreporting of the credit union's ratio of net long-term assets.

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Schedule B, Section 1 and Section 2

On Schedule B of the March 2022 Call Report, Federal Agency Securities are divided between Guaranteed vs. Non-Guaranteed and again between Debt Instruments vs. Non-Debenture Instruments. These distinctions were not present on the historical Call Report. Can you provide examples of the types of securities you expect to be reported in each of these report lines?

Yes, these are new to the Call Report. Here are some examples of what you might report on these lines:

  • Federal Agency Securities/Guaranteed - Debt - FNMA Debenture, TVA Debenture.
  • Federal Agency Securities/Guaranteed - Non-Debt - FNMA Pass Through.
  • Federal Agency Securities/Non-Guaranteed - Debt - We do not believe these exist. This field exists in case this type of non-guaranteed debt is ever issued.
  • Federal Agency Securities/Non-Guaranteed - Non- Debt - Non-guaranteed subordinated tranches issued by a GSE. For example Freddie-K subordinated tranche. Also, FNMA or FHLMC credit-risk transfer securities would be include in Federal Agency Securities/Non-Guaranteed - Non-Debt.
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How should ABS with guaranteed student loan collateral be reported? As Federal Agency Securities or Other ABS?

If a securitization, ABS with guaranteed student loan collateral should be reported in non-federal agency asset backed securities. If issued by a state corporation in a revenue bond structure, they should be reported as Securities Issued by States and Political Subdivisions in the U.S.

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Schedule B, Section 4 - Investments - Memoranda

Are CDs purchased through the SimpliCD program reported as brokered CDs on the Call Report? [Account 788]

Yes. SimpliCDs are not direct purchases and therefore should be reported as brokered CDs.

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Schedule C, Section 1 - Unfunded Commitments

We offer a courtesy pay program where we do not return a member's NSF check to the depositor but instead charge the member the NSF fee and give them a number of days to make it good. There is no specific amount committed to a member for which we will do this. How do we determine the amount of unfunded overdraft protection program commitments? [Account 822C]

The NCUA regulations §701.21(c)(3) requires credit unions to establish a cap on the total dollar amount of all overdrafts the credit union will honor. FFIEC guidance requires the establishment of well-defined and properly documented dollar limit decision criteria. Credit unions should report their cap amount minus any outstanding advances. (The NCUA RR §701.21(c)(3); FFIEC Joint Guidance on Overdraft Protection Programs).

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Schedule C, Section 1 through 5 - Liquidity

We have an available line of credit at the FHLB based on percentages of our stock ownership and real estate loan portfolio. How do we report this? [Accounts 883C, 881]

The FHLB has various borrowing programs. In the case of a line-of-credit, report outstanding balances on, the Statement of Financial Condition in Account 860C - Borrowings. The maturity distribution of the draws against the line-of-credit should be reported on Schedule C, Section 5 - Borrowing Maturity Distribution in Accounts 883A, 883B1, and 883B2 - Draws Against Lines of Credit. Also, report the total credit line on Schedule B, Section 4 - Borrowing Arrangements in Accounts LQ0040, 885A3, LQ0042 and LQ0043.

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Schedule D, Section 1 - Number of Members

If a credit union member has multiple accounts, should these additional accounts count towards the number of current members?

No. You should count each member only once, regardless of the number of accounts held by a particular member.

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Schedule D, Section 2 - Shares/Deposits

We implemented sweep programs involving share draft accounts and money market accounts. Funds are swept between two subaccounts, a share draft subaccount and a money market subaccount. Depending on the balances in the two subaccounts on a particular day, we shift funds from the share draft subaccount to the money market subaccount or vice versa. How should we report these sweep accounts on the Call Report?

You must report funds where they reside as of the cycle end date. Report share draft subaccount balances as share drafts. Report money market subaccount balances as money market shares.

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Schedule D, Section 3 - NCUA Insured Savings Computation

What do I report in the NCUA Insured Savings Computation section?

Report only the amount of uninsured shares and deposits. Do not include notes payable or other forms of borrowings.

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Schedule I - Risk Based Capital (RBC) Ratio Calculation

Per the instructions for Schedule A, Section 1 of the Call Report and §723.2, SBA Paycheck Protection Program (PPP) loans are excluded from the definition of commercial loans. The Schedule A, Section 1 instructions also clearly indicate that PPP loans should be reported in account 397 as other unsecured loans. However, the instructions for Schedule I, Part II, line 25 require PPP loans to be reported as commercial loans which is in direct contradiction to the Schedule A, Section 1 instructions and §723.2.

Not only does this impact the internal consistency of the Call Report, but it will also require CUs to perform the unnecessary step of adjusting the totals of consumer loans and commercial loans on Schedule I, Part II. It would be more consistent and logical to report PPP loans in account RB0063 because PPP loans are reported in account 397 which rolls up under consumer loans for RBC purposes. Please consider revising the Call Report instructions or provide an explanation for this inconsistency.

There are intentional classification differences between the RBC schedule and the rest of the Call Report schedules. This is because, by regulation, some items are categorized differently for Call Report purposes and for RBC purposes. PPP loans are a good example. PPP loans are not considered commercial loans on Schedule A (Loans) of the Call Report because the definition of commercial loan in part 723 specifically excludes PPP loans. However, PPP loans are considered commercial loans on Schedule I (RBC) of the Call Report. Please review the Call Report Instructions for Consumer and Commercial loans reported on Schedule I, Part II for the proper treatment.

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The Call Report Instructions state that, if not using the look-through approach, part 703 compliant investment funds (§702.104(c)(2)(v)(B)(3)) should be reported in both account RB0023 (Securities 100 percent risk weighted) and RB0032 (Other Investments 100 percent risk weighted). Which is correct?

They are both correct. One is for investment funds that are securities and the other is for investment funds that are non-securities (other investments).

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Can you explain in detail the “look-through approach”?

The look-through approach is an alternate way to risk-weight investment funds and separate account insurance. There are three options for the look-through approach and they are in Appendix A of part 702. All three options look-through the investment fund's actual or permissible assets to determine the risk-weight of the credit union's exposure. If using the look-through approach, a credit union should refer to Appendix A of part 702 to determine which approach to use and how to calculate the risk-weight for the investment fund.

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Can you explain in detail the “gross-up approach”? If using the look-through or gross-up approach, how should the approach used be documented, as there doesn’t appear to be any selective areas on the new Call Report?

The gross-up approach is used for senior or subordinated tranches, typically in a securitization. The gross-up approach risk-weights the underlying collateral and applies a multiplier to the risk-weighting for subordinated tranches. The multiplier is based on the ratio of the outstanding amount of the more senior tranches in the securitization versus the outstanding amount of the subordinated tranche that is owned. For example, if a credit union owns the most senior tranche of a securitization, the risk weighting for that asset would be the weighted-average risk-weighting of the underlying collateral. If a credit union owns a subordinated tranche, then the weighted-average risk-weighting of the underlying collateral is multiplied by the leverage the subordinated tranche creates versus the more senior tranches. Credit unions have the option of risk-weighting senior tranches at 100 percent or subordinated tranches at 1,250 percent. The credit union should maintain the documentation of the approach used (look-through versus gross-up) and the results obtained for review by their examiner.

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Schedule I, Part II. Risk-Based Capital Calculation, Line 19 - Securities: On line 19, the instructions indicate the "exposure amounts" of securities should be placed in the various risk weight columns. Section 702.2 defines exposure amounts as amortized cost on HTM and AFS securities. Therefore, it would appear the unrealized gain/loss on AFS securities should be reported in "Adjustments to Totals" (RB0018). However, the instructions for the "Adjustments to Totals" state "adjustments to this line should be offset in another line item on this form". Does this intend to indicate the amounts in the all the "Adjustments to Totals" on the lines 18 through 29 should net to zero? If so, what line should be used for the offset on the unrealized gain/loss on AFS securities? And what risk weight should be used for that amount on the other line?

Per the category 1 - zero percent risk weight section of the instructions for line 19, report available for sale gain/(loss) in Account RB0020 to receive a zero percent risk weight.

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Last modified on
02/25/22