Here is some helpful FAQ regarding the loan data file. This FAQ was originally published by the Louisiana Office of Financial Institutions addressing questions about the Interagency Loan File Format.
Are fields considered one row and terminated by 1 carriage-return line-feed sequence?
Yes.
Will all the fields on one line comprise one loan detail record?
Yes.
Should we include home equity loans in the file?
The file should contain all the bank’s loans regardless of type. This would include commercial as well as consumer loans.
Should we include zero-balance loans?
That depends upon the loan. We do want to see open lines of credit where the bank is obligated to advance funds in the future. These might show zero for an outstanding balance, but would show the full amount of the commitment in another field (undisbursed commitment availability). Examples of these types of loans that might be carrying a zero balance would credit card lines, commercial lines of credit, standby lines of credit and home equity lines. On the other hand, we do not want to see a zero-balance loan record that's simply an artifact from a loan that's been paid in full. If these were included in the file, they would show zero for both fields since there is no longer a legal obligation on the bank’s part to re-advance funds.
For the field called "charge off amount", do you want all old charged off loans in the interagency file?
If a loan has been charged off in full, it's a zero-balance loan as described in the answer above and it should not be in the file. We have seen some files where these loans show an outstanding balance and a like number in the charge-off amount. That creates a problem since at first glance these appear to be active
loans. It's important to understand that we will try to reconcile this trial balance to the amount shown for loans on the bank's general ledger using the total
from the outstanding balance field. Any loan that is listed in the file that isn't an active and current relationship that's properly carried as an asset of the bank should not be showing a current balance other than zero. In addition to inhibiting our ability to balance the ledger, these lines will distort the past due and summary reports built into our tools. If the bank has a note with a partial charge off, the current balance net of the charge off would show up in the outstanding balance since that portion of the note is still active. The charge off amount would be listed in the "charge off" column. If you have already mapped and distributed the format to your customers and you have old charge offs in the file, no change is needed as long as the amount in "balance outstanding" for these notes is zero.
In those instances where the bank sells a portion of a note, should we report the balance as balance outstanding net of the sold amount?
Since we’re interested in balancing "outstanding balance" to the bank’s call report RC-C, it should be net of any amount sold. For example, if a bank makes a loan for 100,000 and then sells 25,000 to another institution, the record for that note should reflect the following subsequent to the sale:
balance outstanding = 75000.00
participation indicator=S
amount sold=25000.00
original amount sold=25000.00
Please note the "amount sold" will decrease as payments are made to the participating bank(s). If your system is incapable of linking the participation to an individual note, then you could report the amount sold as a negative note. In the example above, the amount in outstanding balance for the original note would be 100000.00, and the amount in outstanding balance for the “participation” note would be –25000.00. In addition, you would need to populate the record for the negative note with some key information so that we could tie it to the underlying borrower. This would include:
Note number (this could be a dummy number, or a number tied to the participation) and Borrower ID. Please do not populate other fields if you use the negative-note option.
Our loan products can have up to 10 rates, indices and margins. How do you want to address this in the field for interest rate, index and margin?
We envision that this file will be presenting information on a loan-by-loan basis (i.e., one loan per line). That being the case, we would like to see the information/indices related to each loan. While we understand there could be many indices in use, we don’t expect that more than one will apply to an individual note.
Please give further definition of field "Amortizing/Non-Amortizing status"
We’re looking to see if amortization has been suspended. This would be most common on consumer loans where there has been an agreement by the bank to suspend principle payments for specified period of time.
Several fields in the file format document have been identified so far as unavailable or null for our system, and they are not identified as required fields for population. Do you have any tolerance for the number of fields that are not populated on the file?
A few of the fields are absolutely required (Note Number, Balance, Rate, Maturity Date). If other fields are unavailable, please leave those fields blank. Keep in mind though that missing data will impact your analysis (for example, not providing an index and spread for a variable rate loan)
Is the file to be sorted in any manner, i.e. branch, note type, officer, etc.?
Sort is not important to us since our tools will sort the data in the manner we need once we import the file.
Is there a particular method for transmission and data encryption that is expected?
Yes, you must upload this file via our secure (https://) server. DO NOT EMAIL THIS FILE TO US.
What should we report in "next payment due" when the loan is delinquent?
Show the due date of the next payment. This will be in the past if the loan is delinquent.
What should we report in "payment frequency" when the note has a mixed payment structure (for example, interest monthly with principle quarterly)?
This is a 10-character alpha field. Please describe the payment structure as "mixed" or "variable."
On a related note, what should we report in "payment amount" for loans with mixed payments?
Report the amount of the next expected payment if known.
How should we report negatively amortizing loans in the "amortizing/non-amortizing" field?
Answer "no.”
What should we report in "date of last payment" if the last payment wasn't a full payment?
Report the date of the last payment even if it wasn't a full payment. We are looking for activity on the line.
How should we report non-valid dates?
In some systems, non-valid dates are used to identify a specific event (i.e., 6-31 for quarter end). In those cases, please convert to a real date. Report all other non-valid dates as is, since they probably reflect a data integrity problem that we will want to investigate.
As we've mentioned in previous posts we understand that the detail loan file format #1 contains sensitive customer data. If you upload a file to us with customer sensitive data we delete this information right away, we don't want this information either. Part of our agreement with you is to keep information confidential.
