This is a set of scripts to download (if CloudFlare allows it) and parse flat
files from the FFIEC Community Reinvestment Act's public data disclosures. The
files match the pattern src/cra\d_.+?\.py and should be executed in
alphanumeric sort order.
This data is kept in fixed-width .dat files, making it annoying to work with.
The files are hosted at https://www.ffiec.gov/cra/craflatfiles.htm. Because
the file specifications are not easily machine-readable, defined in PDFs, a
substantial of manual work is needed to parse them properly. This not helped by
changes in the file specifications over time (column widths).
Aggregates are pre-calculated at the county level.
As with other data products such as pre-2017 HMDA (Home Mortgage Disclosure
Act), the respondents are identified by AGENCY_CODE and RESPONDENT_ID. The
agency codes are as follows.
AGENCY_CODE |
Agency |
|---|---|
| 1 | Office of the Comptroller of the Currency |
| 2 | Federal Reserve |
| 3 | Federal Deposit Insurance Corporation |
| 4 | Office of Thrift Supervision (abolished 2011) |
Mapping from CRA respondents to standard bank identifiers such as FDIC CERT
and Fed RSSD is via the transmittal table.
CRA reporter eligibility can be found on the FFIEC website. In 2023, the reporters were all banks regulated by the OCC, Federal Reserve, or FDIC that also had assets in excess of 1.503 billion $ as of 31 December for the previous two calendar years. The reports are filed on or shortly after 1 March of every year.
The banks which are not required to report are called "small banks" for the purposes of the regulation. This was set by 70 FR 44256 (2005) at 1 billion $, adjusting for inflation (CPI). Prior to 2005, reporting was uneven: a "small bank" was an independent bank with less than 250 million $ in assets or otherwise affiliated with a holding company that had less than 1 billion $ in assets. (Both thresholds applying only if they were met for the two preceding calendar years.) 60 FR 22156, 22180 (1995); 66 FR 37602, 37606 (2001).
A final CRA rule in 2024, superseding the 1995 rules, substantially kept the inflation-adjusted 2005 threshold. See 89 FR 6574, 7212 (2024). A new reporting requirement was imposed, 12 CFR 25.42(a)(7), requiring banks with more than 10 billion $ in assets with the same two year filter to report "the dollar amount of... deposits at the county level based on deposit location". "Deposit location" is the depositor address for purposes of the Consumer Identification Program (31 CFR 1020.220). 12 CFR 25.12 "Deposit location".
The main identifier in aggregates is the county FIPS code. FIPS codes can change over time as counties expand, contract, split, merge, and rename. They should be treated as valid only at the same CRA reporting year.
Bryce Bangerter and Kevin Wong
We are indebted to the work of AC Forrester.
The views expressed (if there is any such expression at all) herein do not necessarily represent the views of the Office of the Comptroller of the Currency, the Department of the Treasury, or the United States.