[Federal Register: December 20, 2004 (Volume 69, Number 243)]
[Notices]
[Page 76034-76041]
From the Federal Register Online via GPO Access [wais.access.gpo.gov]
[DOCID:fr20de04-162]
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DEPARTMENT OF THE TREASURY
Office of the Comptroller of the Currency
[Docket No. 04-25]
FEDERAL RESERVE SYSTEM
[Docket No. OP-1218]
FEDERAL DEPOSIT INSURANCE CORPORATION
DEPARTMENT OF THE TREASURY
Office of Thrift Supervision
[No. 2004-57]
Shared National Credit Data Collection Modernization
AGENCIES: Office of the Comptroller of the Currency, Treasury (OCC);
Board of Governors of the Federal Reserve System (Board), the Federal
Deposit Insurance Corporation (FDIC); and the Office of Thrift
Supervision (OTS) as an assisting agency.
ACTION: Notice for public comment.
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[[Page 76035]]
SUMMARY: The Federal Banking Agencies (Board, FDIC, OCC, and OTS,
collectively referred to as ``the Agencies'') are seeking comment on
proposed changes to the examination data collected in support of the
Shared National Credit Program (Program). The Agencies propose to
standardize and expand the data collection to improve the efficiency
and effectiveness of Shared National Credit (SNC) examinations. By
standardizing and expanding the collection of data, the Agencies will
be able to use advanced credit risk analytics that will be beneficial
to the reporting banks and the Agencies. The proposed changes are
warranted based on the increasing sophistication of banks' risk
management practices and the complexity of credit markets. Going
forward, the Program also plans to take advantage of current
information technologies. The Agencies plan to implement the changes
beginning with the 2007 SNC examinations, employing data as of December
31, 2006.
DATES: Comments must be submitted on or before February 15, 2005.
ADDRESSES: Because the Agencies will jointly review all of the comments
submitted, interested parties may send comments to any one of the
Agencies without the need to send comments (or copies) to all of the
Agencies. Postal service in the Washington, DC area and at the Agencies
is subject to delay, so please consider submitting your comments by e-
mail or fax. Commenters are encouraged to use the title ``SNC Program
Modernization'' to facilitate the organization and distribution of
comments among the Agencies. Interested parties may submit comments to:
OCC: You should include OCC and Docket Number 04-25 in your
comment. You may submit comments by any of the following methods:
Federal eRulemaking Portal: http://www.regulations.gov.
Follow the instructions for submitting comments.
OCC Web site: http://www.occ.treas.gov. Click on ``Contact
the OCC,'' scroll down and click on ``Comments on Proposed
Regulations.''
E-mail address: regs.comments@occ.treas.gov.
Fax: (202) 874-4448.
Mail: Office of the Comptroller of the Currency, 250 E
Street, SW., Mail Stop 1-5, Washington, DC 20219.
Hand Delivery/Courier: 250 E Street, SW., Attn: Public
Information Room, Mail Stop 1-5, Washington, DC 20219.
Instructions: All submissions received must include the agency name
(OCC) and docket number or Regulatory Information Number (RIN) for this
notice of proposed rulemaking. In general, OCC will enter all comments
received into the docket without change, including any business or
personal information that you provide. You may review comments and
other related materials by any of the following methods:
Viewing Comments Personally: You may personally inspect
and photocopy comments at the OCC's Public Information Room, 250 E
Street, SW., Washington, DC. You can make an appointment to inspect
comments by calling (202) 874-5043.
Viewing Comments Electronically: You may request e-mail or
CD-ROM copies of comments that the OCC has received by contacting the
OCC's Public Information Room at regs.comments@occ.treas.gov.
Docket: You may also request available background
documents and project summaries using the methods described above.
Board: You may submit comments, identified by Docket No. OP-1218 by
any of the following methods:
Agency Web site: http://www.federalreserve.gov Follow the instructions for submitting comments at http://www.federalreserve.gov/generalinfo/foia/ProposedRegs.cfm.
Federal eRulemaking Portal: http://www.regulations.gov.
Follow the instructions for submitting comments.
E-mail: regs.comments@federalreserve.gov. Include the
docket number in the subject line of the message.
Fax: (202) 452-3819 or (202) 452-3102.
Mail: Jennifer J. Johnson, Secretary, Board of Governors
of the Federal Reserve System, 20th Street and Constitution Avenue,
NW., Washington, DC 20551.
All public comments are available from the Board's Web site at
http://www.federalreserve.gov/generalinfo/foia/ProposedRegs.cfm as
submitted, except as necessary for technical reasons. Accordingly, your
comments will not be edited to remove any identifying or contact
information. Public comments may also be viewed in electronic or paper
form in Room MP-500 of the Board's Martin Building (20th and C Streets,
NW.) between 9 a.m. and 5 p.m. on weekdays.
FDIC: You may submit comments by any of the following methods:
Agency Web site: http://www.FDIC.gov/regulations/laws/federal/propose.html.Follow
the instructions for submitting comments. E-mail: comments@FDIC.gov.
Mail: Robert E. Feldman, Executive Secretary, Attention:
Comments/Legal ESS, Federal Deposit Insurance Corporation, 550 17th
Street, NW., Washington, DC 20429.
Hand Delivered/Courier: The guard station at the rear of
the 550 17th Street Building (located on F Street), on business days
between 7 a.m. and 5 p.m.
Public Inspection: Comments may be inspected and
photocopied in the FDIC Public Information Center, Room 100, 801 17th
Street, NW., Washington, DC, between 9 a.m. and 4:30 p.m. on business
days.
Instructions: Comments received will be posted without change to
http://www.FDIC.gov/regulations/laws/federal/propose.html, including
any personal information provided.
OTS: You may submit comments, identified by No. 2004-57, by any of
the following methods:
Federal eRulemaking Portal: http://www.regulations.gov.
Follow the instructions for submitting comments.
E-mail address: regs.comments@ots.treas.gov. Please
include No. 2004-57 in the subject line of the message and include your
name and telephone number in the message.
Fax: (202) 906-6518.
Mail: Regulation Comments, Chief Counsel's Office, Office
of Thrift Supervision, 1700 G Street, NW., Washington, DC 20552,
Attention: No. 2004-57.
Hand Delivery/Courier: Guard's Desk, East Lobby Entrance,
1700 G Street, NW., from 9 a.m. to 4 p.m. on business days, Attention:
Regulation Comments, Chief Counsel's Office, Attention: No. 2004-57.
Instructions: All submissions received must include the agency name
and No. 2004-57 for this request for comment. All comments received
will be posted without change to the OTS Internet Site at http://www.ots.treas.gov/pagehtml.cfm?catNumber=67&an=1
, including any
personal information provided.
Docket: For access to the docket to read background documents or
comments received, go to http://www.ots.treas.gov/pagehtml.cfm?catNumber=67&an=1
.
In addition, you may inspect comments at the Public Reading Room,
1700 G Street, NW., by appointment. To make an appointment for access,
call (202) 906-5922, send an e-mail to public.info@ots.treas.gov, or
send a facsimile transmission to (202) 906-7755. (Prior notice
identifying the materials you will be requesting will assist us in
serving you.) We schedule appointments on business days between 10 a.m.
and 4 p.m. In most cases,
[[Page 76036]]
appointments will be available the next business day following the date
we receive a request.
FOR FURTHER INFORMATION CONTACT:
OCC: MaryAnn Nash, Counsel, Legislative and Regulatory Affairs
Division (202) 874-5753; or Louise Francis, National Bank Examiner,
Large Bank Supervision, (202) 874-1306; or Kevin Satterfield, Public
Reference Room Assistant, Communications Division, 202-874-4700.
Board: Elaine Boutilier, Managing Senior Counsel, or Alye Foster,
Senior Counsel, (202) 452-5289; or John T. Colwell, Senior Project
Manager, Division of Bank Supervision and Regulation, (202) 728-5885.
For users of Telecommunications Device for the Deaf (``TDD'') only,
contact (202) 263-4869.
FDIC: William R. Baxter, Chief, Large Bank Section, Division of
Supervision and Consumer Protection, (202) 898-8514 or
wbaxter@fdic.gov; Cecilia L. Barry, Senior Financial Analyst, Large
Bank Section, Division of Supervision and Consumer Protection, (202)
898-3506 or cbarry@fdic.gov; Rodney D. Ray, Counsel, Legal Division,
(202) 898-3556 or rray@fdic.gov; or Leneta G. Gregorie, Counsel, Legal
Division, (202) 898-3719 or lgregorie@fdic.gov.
OTS: David W. Tate, Manager, Examination Quality Review, (202) 906-
5717.
SUPPLEMENTARY INFORMATION:
I. Introduction
The SNC Program is a cooperative initiative through which the
Agencies examine and supervise shared national credits. A shared
national credit is a lending commitment of $20 million or more that is
held by three or more regulated lenders.
For the reasons explained in the discussion that follows, the
Agencies have determined that their administration of the SNC Program
could be improved, and the quality of the feedback we provide to banks
in the SNC Program enhanced, by creating a single, shared SNC database
and by standardizing and expanding the set of data we collect from
certain banks that currently report data pursuant to the Program.
Accordingly, this notice describes the changes to the reporting system
that the Agencies contemplate and identifies the new data elements that
the Agencies propose to collect. The proposed data elements are
included in a chart appended to the notice. Immediately preceding the
chart, the Agencies present a series of questions designed to elicit
comment on the expanded program. Commenters' responses will help refine
our thinking about the ultimate design of the expanded data collection
process. Toward that end, the questions focus on the feasibility of
providing the expanded information and on the effects and consequences
of including particular new elements in the SNC reporting system.
Commenters also are invited to suggest alternatives where appropriate.
Concurrently with this notice, the Board is publishing a separate
Request for Information (RFI) to gather information from prospective
contractors pertaining to system integration services to develop a
common system solution for supporting the SNC Program.
Following our evaluation of the comments received in response to
this notice and the RFI, the Agencies expect to develop a more detailed
description of the new data collection process and to publish that
description for additional comment. At that time, the Agencies will
also solicit comment on burden estimates pursuant to the Paperwork
Reduction Act. We anticipate that final changes to the SNC data
collection process will be implemented through an interagency statement
or similar issuance.
II. Background
The SNC Program has been an effective supervisory tool for over
twenty-five years. In 2004, it covered approximately 7,500 facilities
\1\ to nearly 5,000 borrowers and represented committed exposure in
excess of $1.5 trillion. The current objectives are to:
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\1\ The borrower receives funds from the lender by initiating a
facility under the credit agreement. Essentially a loan, a facility
might consist of a revolving, term, or other type of loan.
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Provide uniformity in approach and credit rating
determinations,
Gain efficiencies in risk analysis,
Provide timely results to the reporting banks and
Agencies, and
Gather and analyze reporting bank and industry credit
data.
Advancements in credit risk management and information technology
have created an opportunity to improve the Agencies' ability to achieve
these objectives going forward. In that regard, the Agencies propose
to:
Standardize the SNC data collection system so that all
Agencies collect the same data using the same data definitions,
Expand SNC data collected from the banks that agent a
significant volume of SNCs,
Apply advanced credit risk analytics and benchmarking \2\
techniques to common SNC borrowers, facilities, and reporting bank
portfolios, and
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\2\ Benchmarking references a standardized problem or test that
serves as a basis for evaluation or comparison.
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Provide reporting banks with feedback on their commonly
held SNC portfolios across those metrics.
The creation of a shared SNC database will improve the efficiency
and accuracy of data submission by the reporting banks. Currently, the
Federal Reserve and the OCC maintain separate SNC databases with
slightly different data collection processes (the OCC also processes
SNC data for the FDIC and OTS). A shared database and a common set of
data definitions will allow for increased use of electronic data
collection and will make the collection, reconciliation, and
maintenance of SNC data more effective.
By expanding the data collected from the banks that agent a
significant volume of SNCs, the Agencies will be able to develop and
share useful credit risk information with them. Over time and as credit
risk management techniques continue to evolve, reporting banks will
want additional feedback from their primary Federal regulator on how
their SNC portfolios compare with their peers. SNC benchmarking
information will provide a unique reference point because comparable
peer ratios on the internal credit risk estimates are currently not
available.
III. Proposed Enhancements
The Agencies intend to standardize the SNC data collected from the
reporting banks that serve as agent for at least 100 SNC facilities and
have been identified as likely mandatory or opt-in Basel II banks \3\
(i.e., ``Expanded Reporters''). Banks that do not meet this criterion,
but are able to provide the credit risk management data outlined in
this proposal, could also voluntarily choose to participate as Expanded
Reporters. All other reporting banks (i.e., ``Basic Reporters'') would
continue to submit data similar to the existing SNC reporting
requirements. The Agencies also propose to clarify the data definitions
and standardize the submission format to reduce ambiguity and automate
the data collection process for those banks that are able to submit
data electronically.
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\3\ See Risk-Based Capital Guidelines; Implementation of New
Basel Capital Accord, 68 FR 45900 (Aug. 4, 2003).
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III.A. Basic Reporters
Basic Reporters should see few changes outside of improved
software and feedback reports from the Agencies.
Basic Reporters would continue to provide data annually
prior to the SNC
[[Page 76037]]
examination period only on SNC facilities they agent.
The data elements provided by Basic Reporters in the
existing SNC Program would remain substantially unchanged. However,
they would be subject to a common set of detailed definitions (e.g.,
five or six digit NAICS codes would be required rather than the four
(FRB) or five (OCC, FDIC, and OTS) that are currently requested).
The Agencies would provide user-friendly software to the
Basic Reporters to electronically transmit data.
The Agencies would distribute identifiers (IDs) for
borrowers and facilities agented by Basic Reporters (see the section on
Regulatory IDs).
A Basic Reporter would have the option to become an
Expanded Reporter and receive benchmark comparisons as well.
III.B. Expanded Reporters
The following points highlight the primary changes that would
affect Expanded Reporters.
Expanded Reporters would report data on a quarterly basis
instead of annually. Quarterly data submission will allow each Agency
to provide more frequent feedback on the risk characteristics of SNC
portfolios to the Expanded Reporters.
Data would be collected on all Program borrowers and
facilities (i.e., agented and participated facilities) held by the
Expanded Reporters.
Expanded Reporters would report additional data elements.
The tables in Appendix I and II list the set of data elements
required by the proposed changes to the Program.
III.C Regulatory IDs
Collecting and matching expanded data on the commonly held SNCs
from agent reporting banks and participant reporting banks presents
challenges. To ensure borrowers and facilities are uniformly
identified, common identifiers (i.e., Regulatory IDs) will need to be
assigned. The Agencies are requesting assistance in the design,
implementation, and administration of the Regulatory ID system.
The Agencies propose to create Regulatory IDs that the Expanded
Reporters would distribute to participant reporting banks. The
Regulatory IDs would accompany the data elements with each data
submission by all Expanded Reporters that participate in the facility.
Agencies would assign Regulatory IDs to current SNC borrowers and
credits and provide those IDs to Expanded Reporters as they transition
to the new system. Going forward, Expanded Reporters would request
Regulatory IDs, as needed, on a post-origination basis.
The Agencies intend to distribute Regulatory IDs to Basic Reporters
on an annual basis, following their annual data collection. The
Agencies have not determined how an Expanded Reporter would provide
data on facilities agented by Basic Reporters.
IV. Technology and Data Exchange
The Agencies propose to provide all reporting banks with a common
set of detailed data element definitions that specify data quality
standards as well as provide data validation and edit checks as part of
the collection process. In addition, the new technologies will support
seamless and secure electronic data exchanges between reporting banks
and the Agencies. The Agencies also plan to use technologies for
enhanced electronic reporting and feedback to reporting banks.
Technologies and techniques to collect and distribute SNC data and
reports are currently under investigation and include XML and XBRL
taxonomies. The Agencies intend to implement an efficient data
transmission process for each organization (i.e., holding company level
and all subsidiaries and affiliates) that prefers to submit and receive
data centrally. Results could be mailed to one location, and data would
be broken down by legal entity. These enhancements should improve the
quality of information and the efficiency of the program.
V. Benefits of the Proposed Enhancements
The benefits of the proposed enhancements discussed in this notice
would be significant to both reporting banks and the Agencies. The
ability to quantify and compare institutional risk across the same
syndicated exposure or portfolio of commonly held exposures (i.e.,
``benchmark'') is one important benefit of the proposed changes. With
improved data, the Agencies will be able to benchmark the quality of
broadly held credits in the banking industry and in individual
reporting bank portfolios, and assist in the evaluation of credit risk
metrics across commonly held portfolios of risk. Where appropriate,
supervisors will be able to provide peer information on such items as
capital intensity (i.e., capital per dollar of exposure), weighted
average Probability of Default (PD), weighted average Loss Given
Default (LGD), and many other metrics on a reporting bank's total SNC
portfolio (or by industry) versus peer basis. Analysis and benchmark
comparisons may prompt examinations by the Agencies, particularly when
reporting banks begin identifying emerging risks that other reporting
banks have not. This information could also alert both the Agencies and
reporting bank management to emerging trends or other pertinent
factors.
Feedback relating to the range of risk metrics (e.g., PDs, LGDs,
and Exposures at Default) assigned by peer reporting banks to various
industry sector exposures could help reporting banks evaluate and
improve their internal risk systems. Such information could also
improve the Agencies' understanding of internal risk assessment
methodologies. Examples of this feedback might include:
Feedback grouped by risk grade categories that would show
median PDs, LGDs, or EADs for various industry segments.
Borrower to borrower comparisons that would show a
reporting bank how its PDs compared to the range of scores assigned to
the same borrower by other banks.
Credit comparisons, possibly grouped by facility type,
size, industry, collateral, etc. that would help reporting banks
compare their EAD and LGD values to the range of scores assigned by
other banks to the same exposures.
Accumulated actual credit loss measured over time, which
could prove to be a valuable source of empirical information relating
to LGD estimates.
The Agencies realize that there are various methods used to
evaluate risk. Consequently, multiple conclusions could be drawn from
the same information, yet still arrive at a sound and consistent risk
assessment.
As supervisors and reporting banks gain experience with
benchmarking and other data, the Agencies anticipate that the SNC on-
site examination process will become more efficient. In the past, the
Program has relied heavily upon examination of individual credit
transactions. Going forward, examiners would continue to examine
credits; however, they could focus their on-site examination on credits
where portfolio analysis, market data and risk metrics indicate an
increased risk or concentration. Moreover, with the expanded
examination data, examiners should have a better understanding of a
reporting bank's credit portfolio and macro credit trends.
VI. Conclusion
The benefits of the proposed changes to the Program discussed in
this notice support the Agencies' goals to improve the data collection
system, the efficiency and effectiveness of SNC examinations, and to
provide the ability to perform and share advanced risk
[[Page 76038]]
analytics on the data. The effective implementation of a portfolio
approach to credit risk is dependent on a timely and reliable flow of
useful and relevant data in conjunction with benchmarking commonly held
exposures and risk-focused examinations. These changes call for the
reporting banks and Agencies to share more credit risk information than
in the past. The ultimate goal of the proposed changes is to create a
streamlined, risk-focused Program that recognizes and takes advantage
of the significant advances in bank risk management practices,
leverages current technology, and enables the production of meaningful
credit risk information for the Agencies and reporting banks.
The questions in the next section address specific aspects of the
proposal as well as request feedback on obstacles that the Agencies may
not have anticipated.
The Agencies intend to use feedback from this preliminary proposal
to develop a more detailed notice for comment prior to any final
implementation of the proposed changes. This more detailed notice will,
to the extent necessary, formally propose a new data collection and
request comment on burden estimates.
VII. Questions
Feasibility of Reporting Banks Providing the Data and Establishing
Which Reporting Banks Would Provide That Data
1. To perform benchmark analysis and provide meaningful feedback to
the reporting banks, what data elements should the Agencies add,
delete, or change from the Expanded Reporter list?
2. What are the effects on Expanded Reporters of providing data on
credit participations?
a. Are there data elements that reporting banks would not be able
to compile electronically without manual intervention?
b. Are there equivalent data elements that would be easier to
provide?
3. For Basic Reporters, the Agencies anticipate that the effects of
the proposal will be minimal. What effects, if any, do reporting banks
see from the proposed changes?
a. The main change for Basic Reporters is improved data software.
Are there changes to the current software that would be particularly
helpful?
b. Which, if any, additional data items would be useful for the
Agencies to collect, either to improve their understanding of the
underlying transactions or to provide better feedback to the reporting
banks?
c. What, if any, effects would the use of a common set of detailed
definitions have on Basic Reporters? Are there other alternatives that
could achieve the goals of reducing ambiguity and automating the data
collection process?
4. Are the criteria ``agents 100 or more facilities and is a
mandatory or opt-in Basel II bank'' reasonable to separate Expanded
Reporters from Basic Reporters? If not, please provide an alternative.
5. Since more banks are using credit derivatives to manage their
exposures, should the Program begin to collect data on credit
derivatives in order to provide benchmarking feedback? Should the data
files include credit derivative positions used to manage portfolio
risk, along with the same risk metrics used for loans and other credit
exposures?
Assignment and Maintenance of Unique Facility and Borrower Identifiers
6. Are there obstacles to the Agencies' proposal to assign,
distribute, and maintain Regulatory IDs and, if so, what are they?
a. Should the Agencies distribute Regulatory IDs directly to
participants instead of relying on the Expanded Reporter Agent banks to
do so?
b. Should Basic Reporters also distribute Regulatory IDs to their
participants? Are credit participations held by Basic Reporters'
numerous enough to provide useful, relevant feedback?
c. Are there existing or planned commercial systems that might help
uniquely identify facilities and borrowers in place of the process
proposed here?
d. Would quarterly batch submission and Regulatory ID feedback for
Expanded Reporters be preferable or would those banks prefer to request
the Regulatory IDs throughout the year as deals are completed?
7. Which technologies would best support the reporting banks in
requesting Regulatory IDs?
Feasibility of Data Exchange, Data Definitions, and Selecting Data
Exchange Technologies
8. For both Basic and Expanded Reporters, the Agencies propose to
define standard data requirements to support the secure file exchanges,
and utilize web-based data exchanges, such as XML and XBRL taxonomies
and related secure technologies, to exchange SNC examination data.
a. Is there an alternative to XML and XBRL taxonomies and related
secure technologies to collect SNC examination data that would be
superior?
b. Would it be feasible to extend existing data exchange
technologies, conduits, and processes, such as those used for the FFIEC
Call Reporting, to collect SNC data?
9. Do reporting banks store sufficient information in their
databases to electronically identify a SNC according to the current
criteria--$20 million or more with three or more lenders regulated by
the Agencies?
a. Would reporting banks need a resource to determine if the
Agencies regulate a lender?
b. Would other criteria help reporting banks identify SNCs and
submit data electronically?
c. Would a larger data feed to the Agencies, which the Agencies
would then screen for SNC criteria and then extract SNC facilities, be
easier for reporting banks to administer?
Additional Issues Related to the Delivery of Reports and Data to
Reporting Banks
10. Assuming that the proposed list of data elements is adopted,
how could that data be best presented to provide value to Basic and
Expanded Reporters (i.e., what views would be most advantageous)?
a. Alternatively, should the Agencies simply provide raw data
tables to support bank-generated reports?
b. Will your reporting bank be able to receive the feedback data
and reports electronically by the proposed 2007 implementation date?
11. Are there any unintended consequences that might arise from the
use of this comparative information?
Additional Questions
12. The Agencies currently ask reporting banks to provide the name,
city, and state for SNC borrowers. This has often not been enough
information to clearly identify borrowers in the SNC database. The
Agencies are looking for additional data that reporting banks might
provide to help identify their borrowers more clearly (e.g., stock
tickers, taxpayer identification numbers, CUSIP numbers, MKMV's PIDs,
etc).
a. Which of these additional data elements would be most useful for
this project?
b. What are the minimum data required to clearly identify borrowers
and facilities?
c. Which, if any, of these items do reporting banks store
electronically?
d. Is the proposal to require submission of at least one of these
items reasonable?
13. Over the past two decades, some of the industry's largest
losses involved credits extended to groups of related borrowers.
[[Page 76039]]
a. How are reporting banks identifying groups of related borrowers
in their own systems?
b. What data could participating reporting banks provide to help
identify related borrowers in SNC credits?
c. Could reporting banks electronically transmit data on guarantors
for credits, sponsors, or other related and relevant parties?
14. Could the reporting banks provide entries tracking the
resolution of credits over time, such as amounts charged off or sales
of assets since the last data submission?
15. The data submission software currently in use (OSCAR and SNC
Reporting Application) does not easily support aggregated reporting of
SNC information for all of a reporting bank's related entities. Should
the Agencies design software to permit aggregate, single-point,
reporting of SNC data for a reporting bank? Should electronic data file
submission also allow this type of reporting?
Appendix I
Data Elements for Expanded Reporters
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Data element (``N'' denotes data that
is not collected in the current Comments A / P* (Agent / participant)
program)
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Name and address of Borrower and Agent Full, legal name as it appears in the AP
Bank. corporate charter, and State, ZIP, and
country.
Name and address of the Review Bank, if A ``review'' bank is designated in two A
any. situations: by the agent when it wishes
to identify a location other than its
headquarters for examination of the
credit files by Agency supervisors, or
by the supervisors when the agent is a
non-regulated bank and the supervisors
wish to examine the transaction. In the
latter case, the supervisors will
designate one of the regulated
participant banks as the ``review'' bank.
RegIDs of the Borrower and Agent Bank.. The Regulatory IDs (``RegIDs'') of the AP
Borrower and the Agent bank are
currently referred to as the borrower's
and agent bank's ``RSSD''. This
document proposes to expand the use of
``RegIDs'' to facilitate linkage of
agent bank and participant bank
information, and the RSSD system may, or
may not, be used in the future for this
purpose.
RegID of the Review Bank, if any....... The ``RegID'' of the Review Bank is A
currently referred to as the review
bank's ``RSSD.'' The RSSD
system may, or may not, be used in the
future for this purpose.
Industry Code (NAICS).................. 2002 North American Industrial A
Classification System (NAICS) code
number reflecting the borrower's
business activity. Note that although
this data element is currently provided,
this document proposed to increase the
number of digits required to five or six
(from four required by the FRB and five
requested by the OCC/FDIC/OTS), which is
consistent with the industry code
requirements for filers of Form FR Y-10.
Parent Identification (N).............. Name, Address, and Industry information AP
for Parent Organization. If the
reporting bank does not store the legal
parent, or better yet the ultimate
parent company in a multi-tier
structure, then reporting banks would
provide the name that they use to
aggregate related exposures.
Reporting bank's internal Facility ID.. Reporting bank's internal facility AP
number. Helps examiners identify
facilities in bank records.
RegID of the Facility.................. The ``RegID'' of the facility is AP
currently referred to as the ``Credit
Number'' and is assigned by the
Agencies. The ``Credit Number''
identifier would be replaced by the
proposed ``RegID'' system, which would
facilitate linkage of agent bank and
participant bank information.
Facility Origination Date.............. Date the facility originated. Permits A
analysis of facilities by ``vintage'' to
identify underwriting trends.
Most Recent Renewal Date............... Currently provided by FRB reporting banks A
only. Date the facility was last renewed
or reviewed to confirm the risk rating.
Facility Maturity Date................. Date by which all utilizations must be A
repaid (i.e., not the latest drawdown
date, but the date by which all drawings
must be repaid).
Facility Committed Exposure............ Total facility availability legally A
committed to the borrower as of the date
of the data submission. Includes the
total facility amount, not just the
portion retained by the agent reporting
bank (if any)--the agent bank's portion
of the total exposure would be reported
in ``Participant bank Share of Committed
Exposure'' below.
Facility Utilized Exposure............. Total utilized amount, including off- A
balance sheet instruments (e.g., LCs),
as of the date of the data submission.
Includes the total facility utilization,
not just the portion retained by the
agent bank (if any)-- the agent bank's
portion of the total utilization is a
new data element that would be reported
in ``Participant bank Share of Utilized
Exposure'' below.
Borrower Risk Rating (N)............... Risk rating assigned to the borrower..... AP
Borrower PD--Probability of Default PD used for regulatory capital purposes AP
(Reg) (N). (after any guarantor effect).
Facility EAD--Exposure at Default (Reg) EAD used for regulatory capital purposes. AP
(N).
Facility LGD--Loss Given Default (Reg) LGD used for regulatory capital purposes AP
(N). (after any guarantor effect).
Facility EL--Expected Loss (Reg) (N)... EL using the PD, EAD, and LGD for AP
regulatory capital purposes (after any
guarantor impact).
Facility Capital (Reg) (N)............. Regulatory capital applicable to the AP
facility (after any guarantor effect).
Guarantor Name and stand alone PD, and To be submitted only if the guarantor's AP
guaranty amount (N). attributes are modifying the standalone
characteristics of the borrower's PD or
facility LGD. The parameter that was
mitigated (i.e., PD or LGD) will also be
provided.
[[Page 76040]]
At least one of the following (N): A corroborating variable to identify the AP
Taxpayer ID (TIN), CUSIP borrower in the event of ambiguity in
(borrower), Stock Ticker, MKMV's the other data elements.
``PID'', LPC's Loan ID (LIN).
Participant bank Share of Utilized In the current Program, the agent bank AP
Exposure. submits the committed exposure for each
participant bank. As a new data element,
the Agent bank would also be asked to
provide the utilized exposure for each
participant bank. Additionally, each
participant bank would be asked to
submit its utilized exposure, which
would be linked to the data provided by
the agent bank using the proposed
RegID system.
Cumulative Facility Charge offs (N).... Supports reconciliation and analysis of AP
risk exposures over time.
Facility collateral type (e.g., A/R, Supports LGD analysis.................... A
Equip) (N).
Days Principal or Interest Distress indicator/nonaccrual trigger.... A
Past Due (N).
Reportable SNC Flag (N)................ Identifies the current quarter as that in A
which a borrower no longer qualifies as
a SNC, and notifies users that the
facility will not appear in future data
submissions.
Participant bank names and addresses... In the current Program, the agent AP
reporting bank submits the full, legal
name of each participant bank, and its
State, Zip, and country, and would
continue to do so under this proposal.
Each participant bank would also provide
its name and address (in addition to
other data elements as noted), which
would be used to supplement linkage of
agent bank and participant bank
information through the new RegID system.
RegID of each Participant bank......... The ``RegID'' of a participant bank is AP
currently referred to as the participant
bank's ``RSSD''. Currently the
agent bank submits the RegID (RSSD< greek-
i>) of each participant bank, and would
continue to do so under this proposal.
Each participant bank would also provide
its RegID (in addition to other
data elements as noted), which would be
used to link agent bank and participant
bank information. If the agent bank is
also a participant bank, it would use
the same RegID to report both its agency
and its participation.
Participant bank Share of Committed In the current Program, the agent bank AP
Exposure. submits the committed exposure for each
participant bank. Additionally, each
participant bank would be asked to
submit its committed exposure, which
would be linked to the data provided by
the agent bank using the proposed RegID
system.
Facility Type.......................... Generic description of the facility A
(e.g., revolver, term).
Facility Purpose....................... Generic description of purpose (e.g., A
purchase equipment, provide operating
funds).
Facility Risk Rating................... Facility rating using the reporting AP
bank's risk rating system.
% Pass................................. % of committed exposure rated Pass (i.e., AP
translation of the reporting bank's risk
rating into the regulatory risk rating
system). Under the current Program, this
is reported by the agent bank and covers
the entire facility amount (``Facility
Committed Exposure'') using the agent
bank's credit evaluation. Under this
proposal, each participant bank
(including the agent bank) would report
the ``% Pass'' but only for their
``Participant bank Share of Committed
Exposure'' (see above).
% Special Mention...................... % of committed exposure rated Special AP
Mention--see ``% Pass'' above for a more
detailed explanation of expected
reporting.
% Substandard.......................... % of committed exposure rated AP
Substandard--see ``% Pass'' above for a
more detailed explanation of expected
reporting.
% Doubtful............................. % of committed exposure rated Doubtful-- AP
see ``% Pass'' above for a more detailed
explanation of expected reporting.
% Loss................................. % of committed exposure rated Loss--see AP
``% Pass'' above for a more detailed
explanation of expected reporting.
Nonaccrual Indicator................... Yes / No................................. AP
Nonaccrual Date........................ First day for which interest was no AP
longer accrued as income.
Internal Watch Indicator............... Currently provided only by FRB reporting AP
banks. On the bank's watch list--Yes /
No.
Name of Responsible Account Officer.... Account officer that examiners could A
contact to discuss the credit.
Phone Number of Responsible Account Account officer's external phone number.. A
Officer.
Department Handling Account............ Currently provided only by OCC reporting A
banks. Name of the business unit that is
responsible for monitoring the
borrower's performance and credit
quality.
----------------------------------------------------------------------------------------------------------------
\*\ Data to be provided for Agented (A) and/or Participated (P) facilities. Readers should also note that, for
purposes of this document, an agent reporting bank is also a participant reporting bank if the agent reporting
bank retains credit exposure.
Appendix II
[[Page 76041]]
Data Elements for Basic Reporters
------------------------------------------------------------------------
Data element (``N'' denotes
data that is not collected in Comments
the current program)
------------------------------------------------------------------------
Name and address of Borrower Full, legal name as it appears in the
and Agent reporting bank. corporate charter, and State, ZIP, and
country.
Name and address of the Normally the same as the agent bank, a
Review Bank, if any. ``review'' bank differs from the agent
bank in two situations: when the agent
bank wishes to identify a location other
than its headquarters for examination of
the credit files by Agencies, or by the
Agencies when the agent bank is a non-
regulated bank and the Agencies wish to
examine the transaction. In the latter
case, the Agencies will designate one of
the regulated participant banks as the
``review'' bank.
RegID of the Borrower and the The ``RegIDs'' of the Borrower and the
Agent Bank. Agent bank are currently referred to as
the borrower's and the agent bank's
``RSSD.'' This document
proposed to expand the use of ``RegIDs''
to facilitate linkage of agent bank and
participant bank information, and the
RSSD system may, or may not, be used in
the future for this purpose.
RegID of the Review Bank, if The ``RegID'' of the Review Bank is
any. currently referred to as the review
bank's ``RSSD.'' The RSSD
system may, or may not, be used in the
future for this purpose.
Industry Code................ 2002 North American Industrial
Classification System (NAICS) code
number reflecting the borrower's
business activity. Note that although
this data element is currently provided,
this document proposed to increase the
number of digits required to five or six
(from four required by the FRB and five
requested by the OCC/FDIC/OTS), which is
consistent with the industry code
requirements for filers of Form FR Y-10.
Bank's internal Facility ID.. Bank's internal facility number. Helps
examiners identify facilities in bank
records.
Facility Origination Date.... Date the facility originated. Permits
analysis of facilities by ``vintage'' to
identify underwriting trends.
Most Recent Renewal Date..... Currently provided by FRB banks only.
Date the facility was last renewed or
reviewed to confirm the risk rating.
Facility Maturity Date....... Date by which all utilizations must be
repaid (i.e., not the latest drawdown
date, but the date by which all drawings
must be repaid).
Facility Committed Exposure.. Total facility availability legally
committed to the borrower as of the date
of the data submission. Includes the
total facility amount, not just the
portion retained by the agent bank (if
any).
Facility Utilized Exposure... Total utilized amount, including off-
balance sheet instruments (e.g., LCs),
as of the date of the data submission.
Includes the total facility utilization,
not just the portion retained by the
agent bank (if any).
Days Principal or Distress indicator/nonaccrual trigger.
Interest Past Due (N).
Participant bank Names and The agent bank submits the full, legal
Addresses. name of each participant bank, and its
State, Zip, and Country.
Participant Bank's Share of The agent bank submits the committed
Committed Exposure. exposure for each participant bank.
Facility Type................ Generic description of the facility
(e.g., revolver, term).
Facility Purpose............. Generic description of purpose (e.g.,
purchase equipment, provide operating
funds).
Facility Risk Rating......... Facility rating using the reporting
bank's risk rating system.
% Pass....................... % of committed exposure rated Pass (i.e.,
translation of the bank's risk rating
into the regulatory risk rating system).
% Special Mention............ % of committed exposure rated Special
Mention (i.e., translation of the bank's
risk rating into the regulatory risk
rating system).
% Substandard................ % of committed exposure rated Substandard
(i.e., translation of the bank's risk
rating into the regulatory risk rating
system).
% Doubtful................... % of committed exposure rated Doubtful
(i.e., translation of the bank's risk
rating into the regulatory risk rating
system).
% Loss....................... % of committed exposure rated Loss (i.e.,
translation of the bank's risk rating
into the regulatory risk rating system).
Nonaccrual Indicator......... Yes / No
Nonaccrual Date.............. First day for which interest was no
longer accrued as income.
Internal Watch Indicator..... Currently provided only by FRB reporting
banks. On the reporting bank's watch
list--Yes / No.
Name of Responsible Account Account officer name.
Officer.
Phone Number of Responsible Account officer's external phone number.
Account Officer.
Department Handling Account.. Currently provided only by OCC reporting
banks. Name of the business unit that is
responsible for monitoring the
borrower's performance and credit
quality.
------------------------------------------------------------------------
Dated: December 14, 2004.
Julie L. Williams,
Acting Comptroller of the Currency.
By order of the Board of Governors of the Federal Reserve
System, December 14, 2004.
Jennifer J. Johnson,
Secretary of the Board.
Dated at Washington, DC, the 7th day of December, 2004.
By order of the Federal Deposit Insurance Corporation.
Robert E. Feldman,
Executive Secretary.
Dated: December 9, 2004.
By the Office of Thrift Supervision.
James E. Gilleran,
Director.
[FR Doc. 04-27752 Filed 12-17-04; 8:45 am]