Board of Governors of the Federal Reserve System

FR Y-14M

General

Q (Y140001433, General):

Q&A Y140000981 response states that in the month of liquidation the foreclosure status should be "2" (Post Sale Foreclosure). The BHC is requesting additional guidance on this topic to confirm if that rule would also apply to other methods of liquidation. Specifically, if an account that is in foreclosure is paid off by the customer (voluntary liquidation) should the foreclosure status still reflect as post sale foreclosure, or some other value?

A: In this case, report this field as 0 ("Not in foreclosure"). (FRB Response: October 9, 2024)

Q (Y140001670, General):

We request clarification on how to report Interest Type at Origination (FR Y-14M A.1 Line Item 117/B.1 Line Item 20) and Original Interest Rate (FR Y-14M A.1 Line Item 44/B.1 Line Item 40) for First Lien and Home Equity loans with an introductory rate which is fixed during the promotional period of up to six months and then changes to a variable rate.

For the above scenario, what is the appropriate reporting treatment for Interest Type at Origination?

1) Variable
2) Fixed

For the above scenario, what is the appropriate reporting treatment for Original Interest Rate?

1) report the initial introductory rate offered as the original interest rate
2) report the rate that it would switch to once that promotional period is over

A: In the provided example, report "Interest Type at Origination" as "Variable" and report "Original Interest Rate" as the initial introductory rate.

Report the Interest Type at Origination fields as "Fixed" only if the interest rate is fixed for the entire term. Report "Variable" in these fields if the interest rate fluctuates based on a spread to an index, regardless of whether there is an initial fixed period.

Report the Original Interest Rate as the annual percentage rate specified on the mortgage note at the time of origination. (FRB Response: May 22, 2024)

Q (Y140001668, General):

The FR Y-14M instructions for Modification Type (A.1 field 74 & B.1 field 77) state "this line item should be populated for any loan that is currently operating under modified terms and identifies the specific terms that were altered through loss mitigation efforts." Should only loans that have been modified due to loss mitigation efforts be reported in these fields or should non loss mitigation modifications (e.g., rate reduction granted to a borrower who is not in default) also be reported?

A: Report in these fields any loan that is currently operating under modified terms. (FRB Response: March 13, 2024)

Q (Y140001573, General): Background:

The Financial Accounting Standards Board (FASB) issued the following new accounting guidance this year, for effect 1/1/2023 (ASU No. 2022-02 – Financial Instruments – Credit Losses (Topic 326): Troubled Debt Restructurings and Vintage Disclosures). With this new guidance, the TDR classification and TDR reserve balance will be eliminated and the TDR SEC disclosures will be replaced with enhanced disclosures for loan modifications granted to borrowers who experience financial difficulty. It is the firm's understanding that with the change, all modified loans will no longer be designated as TDRs, and that TDR accounting and all associated reporting will discontinue as of the effective date.

Question:

The firm would like to clarify how Field 96 (Troubled Debt Restructure Flag) in FR Y-14M Schedule A.1 and Field 55 (Troubled Debt Restructure Date) in FR Y-14M Schedule B.1 should be populated.

A: FASB Accounting Standards Update No. 2022-02 eliminates the troubled debt restructurings recognition and measurement guidance, and instead, requires firms to evaluate whether a modification represents a new loan or a continuation of an existing loan. Upon the adoption of this update, firms should no longer report existing/legacy TDRs under FR Y-14M Schedule A.1 Line Item 96 (Troubled Debt Restructure Flag) and Schedule B.1 Line Item 55 (Troubled Debt Restructure Date). Firms that have not adopted the new accounting guidance should continue to report those fields. (FRB Response: December 6, 2023)

Q (Y140001607, General): Questions:

1. Please clarify if FR Y-14M Schedule A.1 line item 143 (Workout Type Started) and FR Y-14M Schedule B.1 line item 120 (Workout Type Started), should be reported when the loss mitigation review process is started by the Firm, when the Firm approves the loss mitigation or when the customer decides and accepts which loss mitigation activity to pursue?

2. How should the allowed values be prioritized when reporting FR Y-14M Schedule A.1 line item 143 (Workout Type Started) and FR Y-14M Schedule B.1 line item 120 (Workout Type Started)? Should there be a priority given to any specific values (i.e. 1- Modification) in these scenarios?

Background:

For the new attribute added as part of the 2022 FRB instruction changes it is unclear at what point the loss mitigation activity should be reported as started.

As per the current instructions as drafted and based on business practice, the firm plans to report Workout Type Started at the time the loss mitigation review process is started by the Firm, prior to the Firm's approval of loss mitigation options for a customer and prior to the customer's acceptance of a specific action.

When loss mitigation review is approved, the customer may be approved for multiple options including forbearance, repayment plan, modification, partial claim, conditional short sale, and conditional deed in lieu. The decision is with the customer to determine which loss mitigation activity they want to pursue. At the time the Firm starts the loss mitigation review process it is not always clear which options a customer will be finally approved for or which loss mitigation option a customer will select to pursue. Prioritization will be given to report the value 1-Modification followed by the remaining options or allowed values based on the options considered by the Firm when starting the loss mitigation review process. That will be the Firm's practice until we hear otherwise from the regulator.

A: If a loss mitigation effort has started or is in progress for a loan by the firm but no workout plan has been accepted by the customer and is active, use code "0" for "No Active Workout Plan" under FR Y-14M Schedule A.1 Line Item 143 and Schedule B.1 Line Item 120. Once the customer accepts and enters the loss mitigation plan, code Y-14M Schedule A.1 Line Item 143 and Schedule B.1 Line Item 120 according to the type of workout plan that was pursued. (FRB Response: December 6, 2023)

Q (Y140001144, General): Topic: Last Modified Date

Question: The FR Y-14M asks for the Last Modified Date (fields #75 in Schedule A.1 and #78 in Schedule B.1) requiring "the date on which the loan terms were most recently modified." The date on which a loan is modified can be interpreted in a number of ways. Loan modification documentation includes a number of dates, including: the date of the agreement, date the agreement was signed, date the agreement was countersigned, date of the loan accrual change, and an effective date when the new payment is due. Additionally, loan accounting systems include the date that the modified terms have been processed and applied to the loan. Which date should be used for purposes of the Last Modified Date in the FR Y-14M schedules?

For example, which date should be used to populate the Last Modified Date in the Y-14M? - Loan modification agreement is dated on 10/11/2018 (executed on 10/11/2018), the modification was sent to the borrower for signature on that same date. The borrower signed the agreement on 10/22/2018, and the reporting firm countersigned on 10/29/2018. The agreement has a new effective payment date of 11/1/2018, and an accrual change date of 10/1/2018. The internal loan accounting system maintenance was initiated on 11/2/2018 and finalized on 11/6/2018.

A: For the FR Y-14M "Last Modified Date" items, report the effective date of the loan modification agreement. (FRB Response: September 15, 2021)

Q (Y140001142, General): Topic: Refreshed Property Values

Question: #1

Schedules A and B of the FR Y-14M collects data on refreshed property valuations. Instructions for Refreshed Property value line items state do not report where the refreshed property value was not obtained in the last year. Should refreshed property values only be reported if the valuation date was completed within the last year of the loan's modification date, or only if the valuation was completed within the last year of the reporting date?

• A loan is modified on 10/15/18 with an updated property value from 09/30/18. Should the new refreshed property value continue to be reported on the 10/31/19 report date?
• A loan is modified on 09/01/18 and an updated property value is obtained on 10/15/19. Should the new refreshed property value be reported on the 10/31/19 report date?

Question: #2

Schedules A and B of the FR Y-14M collect data on refreshed property valuations. Instructions for Refreshed Property Value line items state refreshed values are expected to be populated for modified loans only and the information to be collected at the time modification terms are being set. There may be loss mitigation modification types which do not require a refreshed property value. However, there is an edit check which requires this line item to be reported with a valid positive whole number for modified loans. Can you confirm that the refreshed property value, method, and date fields may be left blank for modified loans which have not received an updated property valuation?

A:

1. "Within the last year" means the refreshed property value (line item no. 69 CCFLM209, line item no. 79 CCHEM209) of the modified loans was obtained within the one year of the modification date.

   Example 1: If a loan is modified on 10/15/18 with an updated property value from 09/30/18, do not report the refreshed property value that was obtained in September 2018. Do not report where the refreshed property value was not obtained within the one year of the modification date.

   Example 2: If a loan is modified on 09/01/18 and an updated property value is obtained on 10/15/19, for 10/31/2019 report date, do not report the refreshed property value that was obtained on 10/15/19. Do not report where the refreshed property value was not obtained within the one year of the modification date.
2. Refreshed values are expected to be populated for all modified loans. For the modified loans which have not received an updated property valuation, the refreshed property value, method, and date fields may be left blank. (FRB Response: November 12, 2020)

Q (Y140001248, General):

We are looking for clarification – on field 55 FL/HE Next Payment Due Date (M196). The FRB communicated on 4/17 via Black Knight (BKI) new requirements around FR Y-14 – COVID-19 Forbearance Program reporting, which included a change to Next Payment Due Date field stating – "The Y-14M due dates should not be adjusted to report loans on forbearance plans as Current; the actual due dates should be reported". Clarification example – If the borrower was delinquent 30 days as of March ME and entered into a CARES Deferral Plan – should we report the ‘adjusted' due date to show the loan as current under the CARES Deferral Plan or continue to report the borrower as 30 days past due in this field?

Reporting the loan as delinquent appears to conflict with the April 7th Board of Governors of the Federal Reserve System Interagency Guidance on Past Due Reporting (page 4) and Modified GAAP reporting – "With regard to loans not otherwise reportable as past due, financial institutions are not expected to designate loans with deferrals granted due to COVID-19 as past due because of the deferral. A loan's payment date is governed by the due date stipulated in the legal agreement. If a financial institution agrees to a payment deferral, this may result in no contractual payments being past due, and these loans are not considered past due during the period of the deferral." Both Cares Act Guidance and Interagency Guidance – provide Modified GAAP reporting guidance that implies – Qualified CARES Deferral Plans will not be considered TDRs, Non-performing loans (delinquency not advanced) or FFIEC Charge-off eligible.

A: For Y-14M Schedule A and Schedule B reporting, do not change the Next Payment Due Date field (Schedule A line item 55, Schedule B line item 39) until the payment is made. In Schedule A, if the loan was active and performing prior to entering forbearance, use the Loss Mitigation Performance Status field (line item 85) "1 = active and performing," so we can account for this. However, if the loan was active and non-performing prior to entering forbearance, use the Loss Mitigation Performance Status field (line item 85) "2 = active and nonperforming." In addition, for Schedule B, for the Loan Status field (line item 47) and the Loss Mitigation Performance Status field (line item 89), record its status before the forbearance began, and retain the status through the duration of the forbearance period.
(FRB Response: June 10, 2020)

Schedule A—Domestic First Lien Closed-end 1-4 Family Residential Loan Data Dictionary

Q (Y140001699, A.1 – Loan Level Table):

The instructions for FR Y-14M Schedule A.1 line item 28 ("Recourse Flag") state that "recourse on a loan refers to terms in the mortgage contract that give the owner of the note the right to pursue additional claims against the borrower beyond possession of the property." If the reporting institution is reporting a loan post sale where only servicing is retained, should the recourse flag relate to the claims against the servicer/reporting institution rather than the borrower?

A: Report only terms that give the owner of the note the right to pursue additional claims against the borrower beyond possession of the property. Do not report any claims against parties other than the borrower. (FRB Response: October 30, 2024).

Q (Y140001434, A.1 – Loan Level Table):

Field 95 (Credit Enhanced Amount) on FR Y-14M Schedule A.1 reports the total amount of credit enhancement received to offset the loss on a given loan. Loans that are originated through FHA, VA, or USDA programs may receive claim fund proceeds upon default of the mortgage. Please confirm that the claim funds received from the Investor, FHA, VA, or USDA on a defaulted loan are not considered a credit enhancement and, thus, should not be reported in field 95.

A: In general, if funds received from federal government agencies or entities offset the credit loss resulting from an involuntary termination, then the amount received may be reportable in Field 95, Credit Enhanced Amount, depending on the circumstances. If a firm reports the amount received from federal government agencies or entities in public reports as the sales price of the property, then those amounts must be reported for Field 121, Sales Price of Property, consistent with the instructions for that field. If funds received from federal government agencies or entities are included in the sales price reported in Field 121, do not report such funds in Field 95 as part of the Credit Enhanced Amount. If funds received from federal government agencies or entities are not included in the sales price reported in Field 121, report such funds in Field 95. (FRB Response: September 18, 2024)

Q (Y140001547, A.1 – Loan Level Table):

14M ARM Periodic Rate Cap (field 35)

14M ARM Periodic Rate Floor (field 36)

As per the FR Y-14M Domestic First Lien closed 1-4 Family Residential template instructions, BHC must report the periodic interest rate floor for adjustable rate loans.

If the interest rate resets to 6.25% at the last reset period and the prior interest rate was 5.5%, for a loan with a periodic adjustment cap of 2%, a lifetime cap of 9.00% and lifetime floor of 2.25%, would the periodic cap and floor be reported as 8.25% and 4.25% or 7.5% and 3.5%?

A: In this example, the ARM Periodic Rate Cap would be 8.25 percent and the ARM Periodic Rate Floor would be 4.25 percent. The cap and floor are calculated by taking the current interest rate (in this example, 6.25 percent) and adding/subtracting the periodic adjustment cap (in this example, 2 percent), subject to the lifetime rate cap and floor. The periodic rate should not go above/below the lifetime cap/floor values. (FRB Response: March 13, 2024)

Q (Y140001546, A.1 – Loan Level Table):

14M ARM Periodic Rate Cap (field 35)

14M ARM Periodic Rate Floor (field 36)

As per the FR Y-14M Domestic First Lien closed 1-4 Family Residential template instructions, BHC must report the periodic interest rate floor for adjustable rate loans.

If there is no periodic adjustment cap stated in the note, would we report both the ARM periodic rate cap and the ARM periodic rate floor as 0% or NULL?

A: If there is no contractual periodic rate cap or floor, report fields 35 and 36 as NULL. (FRB Response: March 13, 2024)

Q (Y140001545, A.1 – Loan Level Table): 14M ARM Lifetime Rate Floor (field 38)

As per the FR Y-14M Domestic First Lien closed 1-4 Family Residential template instructions, firms must report the ARM Lifetime Rate Floor for adjustable rate loans.

If there is no stated lifetime floor on the note, would we report NULL or 0 or the margin?

A: If the credit agreement includes a floor on the base rate and there is a contractual margin, report the effective floor in these fields. If there is no contractual floor on the base rate, report the field as NULL. (FRB Response: December 20, 2023)

Q (Y140001574, A.1 – Loan Level Table): 14M Modification Type (field 74): Code 25-Recapitalization

Currently, Firms have loss mitigation modifications on fixed rate mortgages that only result in the capitalization of delinquent interest and advances and is the first modification for the loan. There is no change in maturity date or interest rate, nor any forgiveness, deferral or rate frozen.

Can you please advise if Firms should report the Modification Type (Field #74) as "25-Recapitalization" or "99-Other"?

A: In this example, firms should report the Modification Type (Field #74) as "25-Recapitalization." (FRB Response: December 6, 2023)

Q (Y140001608, A.1 – Loan Level Table):

When an adjustable-rate mortgage note reportable on FR Y-14M Schedule A.1 does not contain a payment floor in the contract but does have a contractual margin rate, how should FR Y-14M Schedule A.1 line item 36 (ARM Periodic Rate Floor) and FR Y-14M Schedule A.1 line item 38 (ARM Lifetime Rate Floor) be reported? For these adjustable-rate mortgages, the Firm currently reports the margin as the effective rate floor in for FR Y-14M Schedule A.1 line item 36 (ARM Periodic Rate Floor) and FR Y-14M Schedule A.1 line item 38 (ARM Lifetime Rate Floor). This is consistent with the guidance provided for effective rate floor in FAQ Y140000869 which is applicable to FR Y-14Q, Schedule H, Wholesale Risk.

A: If the credit agreement includes a floor on the base rate and there is a contractual margin, report the effective floor in these fields. If there is no contractual floor on the base rate, report the field as NULL. (FRB Response: December 6, 2023)

Q (Y140001219, A.1 – Loan Level Table):

Regarding "Workout Type Completed" on FRY14M (schedule A line 77 and schedule B line 61), the Fed's request is to report "9=Forbearance Plan" only if the loss mitigation effort has been "successfully completed" in the reporting month. The firm plans to report "9=Forbearance Plan" only for the first month of the forbearance plan even when the forbearance plan covers multiple months (i.e. The firm interprets "successfully completed" as implemented). Please confirm whether or not this approach is correct. If it is not, please clarify the timing when "9=Forbearance Plan" should be reported (every month of the plan, only after the end of the forbearance period).

In all of the firm's internal and external reporting, the firm is freezing the delinquency status of loans entering a COVID-related forbearance plan. Should 14M reflect the frozen delinquency status for these forbearance loans? If so, the firm plans to freeze the Home Equity loan status field, but First Mortgage does not report a delinquency status field. Should next payment due date be altered in any way (rolled forward artificially) for First Mortgage and Home Equity to "freeze" delinquency?

A: 1. The firm's proposed approach is not correct. Per the FR Y-14M instructions, firms should only report Schedule A.1 Line Item 77 and Schedule B.1 Line Item 61 in the reporting month when the loss mitigation effort is completed (rather than just implemented). Where loss mitigation efforts are implemented and ongoing, but not completely resolved, Schedule A.1 Line Item 77 and Schedule B.1 Line Item 61 should be left blank. Instead, to identify ongoing forbearance plans, report Schedule A.1 Line Item 85 and Schedule B.1 Line Item 89 as "1 = Active and Performing." According to the FR Y-14M instructions for Schedule A.1 Line Item 85 and Schedule B.1 Line Item 89, "active and performing" refers to any loan that is currently in loss mitigation and is performing to the terms of a selected plan. Firms should then report "9 = Forbearance Plan" in Schedule A.1 Line Item 77 and Schedule B.1 Line Item 61 in the month when the program is successfully completed.

2. No, the firm's FR Y-14M reporting should not reflect the "frozen" delinquency status of loans entering a COVID-related forbearance plan. For Schedule A.1 Line Item 55 and Schedule B.1 Line Item 39, do not change next payment due date until the payment is made. As noted in the instructions, for delinquent loans this date will be in the past. Additionally, do not change the way you report Schedule B.1 Line Item 47 (Loan Status (MBA method)). Use the Loss Mitigation Performance Status fields, as described above, to identify loans in forbearance. (FRB Response: March 15, 2023)

Q (Y140001533, A.1 – Loan Level Table):

Line Items Impacted: 28 (Recourse Flag) Report whether there is recourse on a loan. Recourse on a loan refers to terms in the mortgage contract that give the owner of the note the right to pursue additional claims against the borrower beyond possession of the property.

Question:

1. Recourse refers to the right to pursue additional claims against the borrower beyond possession of the property. As the firm does not pursue claims beyond possession of property, does a reporting of 'N' for all loans satisfy the spirit of these requirement?

A: If there are no additional claims beyond the possession of property in the terms of the loans, report the line item 28 (Recourse Flag) as “N.” If there are additional claims beyond the possession of property in the terms of the loan contract, even if the firm has a policy of not pursuing any additional claims beyond possession of the property, report the line item 28 (Recourse Flag) as “Y.” (FRB Response: December 7, 2022)

Q (Y140001535, A.1 – Loan Level Table):

Line Items Impacted:

* Line item 46 (Pre-Payment Penalty Flag) Report whether the loan carries a penalty if the borrower prepays the loan during a specified period of time.

* Line item 47 (Pre-Payment Penalty Term) Report the time period from loan origination that a prepayment penalty applies (if applicable).

This is an origination line item and should specify the time period from origination for which a prepayment penalty would have applied. It should not change with the reporting month.

Question:

1. While Pre-Payment Penalty may be applicable where a borrower prepays during a specified period, its enforcement must be a consideration. As the firm does not originate loans with a Pre-Payment Penalty nor does it enforce a Pre-Payment Penalty on acquired loans, does a reporting of 'N' for all loans satisfy the spirit of these requirement?

A: If the loan was originated with no pre-payment penalty, then report line item 46 as “N.” If the loan contract was originated with a pre-payment penalty, even if the firm has a policy of non-enforcement of prepayment penalties, line item 46 should be reported as “Y,” with line item 47 answered accordingly. (FRB Response: December 7, 2022)

Q (Y140000982, A.1 – Loan Level Table):

If a loan that was originated as an adjustable rate mortgage (ARM) loan and then modified to a fixed rate mortgage (FRM) loan through loss mitigation (no new loan record is opened -same account number), should the ARM Periodic Rate Cap and Floor fields (Sch. A.1 #35, #36 and Sch. B.1 #31, #32) be reported Null since the modified rate term is fixed OR should these fields be reported based on the rate term before modification?

The report instructions specify that info for these fields should be based on "origination values", however, we would like to request clarification on modified loans that have changed from ARM to FRM, should the "origination values" be considered the values as of the most recent modification and report null?

A: The ARM Periodic Rate Cap and Floor fields (Sch. A.1 #35, #36 and Sch. B.1 #31, #32) should only depend on data available at the time of loan origination and should not change over time. (FRB Response: November 3, 2022)

Q (Y140001564, A.1 – Loan Level Table):

The Fed definition for A1 Recourse Flag states "Report whether there is recourse on a loan. Recourse on a loan refers to terms in the mortgage contract that give the owner of the note the right to pursue additional claims against the borrower beyond possession of the property."

For the majority of our A1 loans, the definition is clear, as the mortgages are to individuals, secured by residential property, and do not have any guarantees or recourse above the value of the collateral.

However, there is a smaller portfolio of Commercial loans that are secured by residential property and are therefore reportable on Schedule A1. Of these, some are backed by guarantees. Examples are loans to non-Individuals (such as LLCs, S Corps, Corporations) that are guaranteed by the owners (Primary source of repayments) or third parties. Additionally, there are loans to Trusts that are guaranteed by the trust owners.

Would these guarantees fall under the definition of Recourse for A1? Since the guarantees are not specifically claims 'against the borrower' we ask your guidance on how should these be reported. Currently we have interpreted these as being non-Recourse for A1.

A: The firm should report Recourse Flag as “Y” in these examples. (FRB Response: October 12, 2022)

Q (Y140001499, A.1 – Loan Level Table): Q&A regarding Modifications:

We wanted to confirm that a short term extension is not considered a modification for purposes of populating the modification type field.

These would generally be loans that had a short term forbearance, in which the forbearance amount is repaid using an extension at the end of the loan.

These loans would have the following characteristics:

1. Unlikely a true term extension - The P&I amount would not change for the remainder of the loan
2. The customer is not signing a document to accept new terms like they would for a true modification.

A: For the loans in this example, a short-term extension is not considered a modification. (FRB Response: October 12, 2022)

Q (Y140001171, A.1 – Loan Level Table): Topic: Step Modification Flag

Question: FR Y-14M schedule A.1 line 84 reports whether a rate modification has a stepped or gradual return to the non-modified interest rate. Instructions state to report "N" if the loan immediately returns to the contract rate at expiration of the modification. The revised instructions effective 3/31/2020 state the field should be populated with a "Y" if the rate drop is gradual, even to a rate that is different from the contract rate, while an immediate rate drop, even to a rate that is different from the contract rate, should be populated with an "N." This addition to the instructions appears to be referring to the interest rate drop under the modified terms. However, the revised instructions obfuscate the scenarios in which we should report "Y." Please clarify if the intention is to capture any modification scenario that has either a gradual increase or decrease in rate. For example, scenarios arise where a modification will immediately adjust the rate with a gradual return, gradually adjust the rate with an immediate return, or gradually adjust the rate and gradually return.

To highlight the challenge, this addition (effective 3/31/2020) seems to contradict the existing language in the following scenario. A loan has a 6% interest rate at origination. A modification immediately drops the interest rate to 4% for a period of time, and the interest rate steps back up to 6% at 0.5% intervals. The immediate drop requires an "N" to be reported, while the stepped return requires a "Y." The opposite scenario could also apply where the interest rate decreases gradually under the modification, requiring a "Y," and immediately returns to the original interest rate at the expiration of the modification, requiring an "N." Please provide further guidance on the reporting expectations of the step modification flag field.

A: This field (Step Modification Flag) is intended to capture all rate modifications that are stepped. For the scenario example, report the step modification flag as "Y" if either the increasing or decreasing of the rate is gradual (stepped), otherwise this field should be populated with "N." (FRB Response: November 18, 2020)

Q (Y140001124, A.1 – Loan Level Table): Topic: Allowable Blank Fields

Question: Line item 57 on schedule A of the FR Y-14M reports the remaining term of the loan in months. If a loan is past maturity, a value of 0 should be assigned. However, the reporting instructions do not articulate how to report loans which have paid off early during the reporting month but are not past the original maturity of the loan. In cases of a loan that is paid off prior to the maturity of the loan, should the field be populated with 0 or left blank?

A: In cases of a loan that is paid off prior to the maturity of the loan, the line item 57 should be populated with 0. (FRB Response: November 18, 2020)

Q (Y140001123, A.1 – Loan Level Table): Topic: Original LTV/CLTV Calculation

Question: Most FHA mortgages require the payment of an upfront mortgage insurance premium (UFMIP) which can be financed or paid up-front. In instances where this amount is financed, FHA rules state that the statutory loan amounts and LTV limits for these FHA mortgages do not include the UFMIP. Therefore the LTV/CLTV calculated at origination would not include financed UFMIP. These requirements are articulated in Handbook 4000.1, FHA Single Family Housing Policy Handbook. When reporting line items 8 and 9 (Loan-to-Value and Combined Loan-to-Value) on the FR Y-14M Schedule A, should reporting institutions recalculate LTV/CLTV including UFMIP if it is included in the total amount financed?

A: As FHA Single Family Housing Policy Handbook states, the LTV or CLTV calculated at origination for FHA loans should not include financed upfront mortgage insurance premium. (FRB Response: November 18, 2020)

Q (Y140001152, A.1 – Loan Level Table):

We have several questions, which are set forth below, regarding blanket loans. These loans typically consist of one loan secured by two residential properties where the properties, for example, could consist of a primary residence and a guest home, or a primary residence and a vacation home or two vacation homes. These properties are not commercial (i.e., Commercial Loan Flag field (Field #124) is reported as "0" = No). In addition, the borrower typically executes one note, but the collateral consists of a mortgage on each property that is underwritten in accordance with standard guidelines, with the loan-to-value ratio based on the aggregate values of the properties.

1. For loans that are collateralized by multiple properties, which can include a primary residence and guest house, a primary residence and vacation home or two vacation homes where the predominant property type is known, should the Property Type field (Field #23) be reported as "Z" = Other or should we report the predominant property type?
2. For loans that are collateralized by multiple properties, which includes a primary residence and guest house, a primary residence and vacation home or two vacation homes, where the predominant property type is unknown, should the Property Type field (Field #23) be reported as "U" = Unknown?
3. Should the Property State and Property Zip Code fields (Field #4 and 5 respectively) be left blank for loans collateralized by multiple properties or should this reporting be based on the predominant property?
4. For loans that are collateralized by multiple properties, which can include a primary residence and guest house or a primary residence and vacation home, should the Loan Purpose Coding field (Field #20) be reported as "Y" = Other?
5. For loans that are collateralized by multiple properties, which can include a primary residence and guest house or a primary residence and vacation home, should the Number of Units field (Field # 21) be reported as "Y" = Other?
6. How should the Occupancy field (Field #15) be reported for Blanket Loans? Should it be reported as "U" = Unknown or based on the predominant property?

Receiving guidance on the above questions would help clarify the responses received from the Federal Reserve Bank on prior questions.

A: Consistent with our prior response noted in the FAQ Y140000862:

1. For example #1, line Item No. 23 – Property Type – If the predominant property type is known, report the predominant property type.
2. For example #2, line Item No. 23 – Property Type – If the predominant property type is unknown, report the property type as "U" – Unknown.
3. For example #3, line Item No. 4 and 5 – Property State and Property Zip Code – report the fields based on the predominant property.
4. For example #4, line Item No. 20 – Loan Purpose Coding – this item should be coded as "Y" – Other.
5. For example #5, line Item No. 21 – Number of Units - this item should be coded as "Y" – Other.
6. For example #6, line Item No. 14 – Occupancy – If one of the properties is a primary residence, then code as "Primary"; if both are vacation homes, then code as "Second Home"; if one of the properties is investment and no primary residence is involved, then code as "Non Owner/Investment"; otherwise coded as "Unknown." (FRB Response: November 12, 2020)

Q (Y140000862, A.1 – Loan Level Table):

We have several Blanket Loans in our FR Y-14M population. Our typical blanket loan scenario consists of one loan secured by two residential properties. Our blanket loans are not commercial loans. The properties could be a primary residence and a vacation home or two vacation homes. The borrower executes one note, but our security consists of a mortgage on each property. Blanket loans are underwritten to our standard guidelines, with the loan-to-value ratio based on the aggregate values of the properties.

Can you advise on the treatment of the below fields related to Blanket Loans?

• Line Item No. 14 – Occupancy (How should this field be treated for Blanket Loans?)
• Line Item No. 20 – Loan Purpose Coding (Should this item be "Y" – Other?)
• Line Item No. 21 – Number of Units (Should this item be "Y" – Other?)

A: For blanket loans, report the following fields:

Line Item No. 14 – Occupancy – If one of the properties is a primary residence, then code as "Primary"; if both are vacation homes, then code as "Second Home"; if one of the properties is investment and no primary residence is involved, then code as "Non Owner/Investment"; otherwise coded as "Unknown."

Line Item No. 20 – Loan Purpose Coding – this item should be coded as "Y" – Other.

Line Item No. 21 – Number of Units – this item should be coded as "Y" – Other. (FRB Response: November 12, 2020)

Q (Y140000975, A.1 – Loan Level Table): Topic: Refreshed Property Value

Question: Y-14M Schedules A.1/B.1 Fields 68/79 instructions indicate that the "Refreshed Property Value" fields are expected to be populated for modified loans and the valuation information to be collected at the time modification terms are being set. The instructions also state "Do not report where the refreshed property value was not obtained within the last year."

 

1. Please clarify as to whether "within the last year" means the refreshed property value of the modified loans that was obtained within the last year of the report date OR within the last year of the modification date?

2. If we should only be reporting the refreshed property value of the modified loans that was obtained within the last year of the report date, then should we stop reporting the loans when the current report date is more than 1 year from the last valuation date?

   Example 1: A loan was modified in May 2017 and the refreshed property value was also obtained in May 2017. On the report date of June 30, 2018, should we continue to report the May 2017 refreshed property value for this loan since it was obtained within the last year of the modification date OR should we stop reporting the refreshed property value since it was obtained more than a year ago as of the report date?

   Example 2: A loan was modified in May 2018 and the refreshed property value was obtained in Apr 2017. On the report date of May 31, 2018, should we not report the refreshed property value for this modified loan since it was obtained in Apr 2017 which is more than 1 year prior to the modification date?

A:

1. "Within the last year" means the refreshed property value (line item no. 69 CCFLM209, line item no. 79 CCHEM209) of the modified loans was obtained within one year of the modification date.

2. No, this is not the case. You must continue reporting this field.

   Example 1: For the June 2019 reporting, continue to report the refreshed property value that was obtained in May 2018.

   Example 2: If modified loan terms were based on the refreshed property value obtained in April 2018, do not report the refreshed property value that was obtained in April 2018. Since the report date is within one year of modification date, you should obtain the updated refreshed property value. (FRB Response: April 22, 2020)

Q (Y140001016, General):

We are looking for clarification on First Lien field 58 – Scheduled Principal Balance. The instructions are to "report the scheduled principal balance amount for the borrower."

Ignoring delinquencies and curtailments, variable rate loans and fixed rate loans that have been modified could have different scheduled payments than what would have been generated in an amortization schedule when the loan was originated. Should the scheduled principal balance be based on origination terms or current terms?

A prior question from 2015 states "It would be typical for...loans to have Scheduled Principal Balance equal to Unpaid Principal Balance (field 60) since these fields will only differ in cases of delinquency or curtailment." Should this difference pertain only to missed payments or curtailments in the current month, or should historical delinquency and curtailments also be factored into the scheduled principal amount?

Should accounting-based write-downs be factored into this field?

Lastly, should the reported principle balance be the amount expected at the end of the reporting period, or after the next payment is made? For example, if the reporting period is September and the next payment due date is October 1st, should the scheduled principal balance reported be the balance expected as of the end of September, or what is expected at the end of October?

Any examples that can be provided will be appreciated.

A: The scheduled principal balance (line item no. 58, CCFLM199) should be based on current terms. The historical delinquency and curtailments should be factored into the scheduled principal amount. The scheduled principal balance amount should reflect the balance outstanding based on the scheduled payment which is due from the borrower.

In this example, the scheduled principal balance should be the balance expected as of the end of September. (FRB Response: December 11, 2019)

Q (Y140001032, General):

Fed Q&A – Y140000675 clarifies that a mortgage loan with a variable rate where interest rate resets on a monthly basis or changes anytime the loan's index value changes to be coded as "ARM Other" in Product Type Origination (Field #133) and Product Type Current (Field #19) in FR Y-14M Sch A.

How should ARM loan with initial rate reset of 1 month or 6 months be coded in Product Type Origination (Field #133) and Product Type Current (Field #19)? Please note that Index rate changes but the Index does not change for these loans.

A: For ARM loan with initial rate reset of 1 month or 6 months, code the fields Product Type Origination and Product Type Current (line item no. 133, CCFLM955 and line item no. 19, CCFLM160) as code 9 "ARM Other." (FRB Response: December 11, 2019)

Q (Y140000997, A.1 – Loan Level Table): FAQ (Treatment of Loss Mitigation Items in Pipeline):

The instructions for loss mitigation ask BHC's to report a loan that's being "actively handled" but do not give a value that can be assigned to loans in the loss mitigation pipeline (loans that are being handled by the loss mitigation team but no workout plan has been identified as of yet). Please provide clarification on how the FRB wants BHC's to interpret loans in the pipeline, for where they are being actively handled by the Loss Mitigation department, but have not yet been identified through a workout program.

FRB Instructions:

Loss Mitigation Performance Status – Report whether a loan is being actively handled by the servicer's loss mitigation department. Refers to all loans where the servicer has initiated loss mitigation procedures whether or not a particular course of action or workout type has been executed. Active loss mitigation refers to instances where the loan is currently in loss mitigation, and the servicer is actively pursuing loss mitigation.

Applies to all loans regardless of workout type (Line item 61 Workout Type Completed/Executed) The code values indicate:

Not in loss mitigation – If a loan is not in loss mitigation, then it should be coded as "0."

Active and performing – Refers to any loan that is currently in loss mitigation and is performing to the terms of a selected plan.

Active and non-performing – Refers to instances where a loan is under a workout plan, as identified in Line item 61 Workout Type Completed/Executed, but borrower has missed at least one payment under the terms of the agreement.

Broken – Populated for situations where the borrower has defaulted on the terms of loss plan and the servicer has removed the loan from loss mitigation. The broken flag should remain with the account until the loan has been paid-in-full, re-modified, or charged off.

A: As noted in the Y-14M schedule instructions, the code value of "2" also includes all situations where loss mitigation efforts have been initiated but no plan has been executed as of month-end. For the loans referenced in the question that are in the pipeline, report the field Workout Type Completed (line item no. 61, CCHEM218) as "2."
(FRB Response: December 11, 2019)

Q (Y140000998, A.1 – Loan Level Table): FR Y-14M schedule A.1. Delinquent Amount Capitalized (Field #82), Principal Deferred Amount (Field #87), Principal Write-down Amount (Field #89), and Loss/Write-down Amount (Field #119):

Fields such as Delinquent Amount Capitalized: #82, Principal Deferred Amount: #87, Principal Write-down Amount: #89, and Loss/Write-down Amount: #119 are reportable if a loan has been modified (Y on Field 74: Modification Type). For loans that have gone through multiple modifications, should these fields be reported based on a cumulative amount (i.e., all modifications combined) or based on the amount of the last modification only?

For example, for field #82: A loan is modified in 2016 and the capitalization amount at the time of modification is $1,000. In 2018, the loan is modified again, and this time the new capitalization amount is $1,500. Should the Delinquent Amount Capitalized field be reported $1,500 (as of last modification) or $2,500 (the capitalization amount of $1,000 in 2016 and $1,500 in 2018)? Additionally, if Field #82 is reported based on last modification, should Principal Deferred Amount, Principal Write-down Amount, and Loss/Write-down Amount fields be reported based on the time of modification as well?

A: For loans that have gone through multiple modifications, the fields Delinquent Amount Capitalized (line item no. 82, CCFLM223), Principal Deferred Amount (line item no. 87, CCFLM228), Principal Write-down Amount (line item no. 89, CCFLM230), and Loss/Write down Amount (line item no. 119, CCFLM241) should be reported based on the last modification only. (FRB Response: December 11, 2019)

Q (Y140001029, A.1 – Loan Level Table):

The BHC is seeking guidance on FR Y-14M reporting requirements of debt to income ratios for streamlined products, such as those originated under government sponsored Home Affordable Refinancing Super Streamlines (HAR ss), for which there is no income/DTI requirement. We would like to confirm whether it is permissible to report Debt to Income as NULL for loans under these programs that do not require income validation to qualify for the loan, regardless of whether the information was provided by the borrower since it would not have been validated.

A: Report Debt to Income (DTI) Back-End at Origination (line item no. 11, CCFLM152) and Debt to Income (DTI) Front-End at Origination (line item no. 12, CCFLM153) as NULL for loans under those programs that do not require income validation.
(FRB Response: December 11, 2019)

Q (Y140001030, A.1 – Loan Level Table):

As the FRB instructions state to report the date on which the loan terms were most recently modified, the BHC is requesting clarification on how that date is defined. Since the BHC cannot effectively modify an account unless it has a modification agreement signed by the customer, this date is currently being reported as the date that the loan terms are actually modified in the system of record (product processor) rather than the effective date of the modification agreement. This will be a date later than that printed on the modification agreement sent to the customer, which reflects the date the agreement was generated from the system. Typically, we see differences in these dates of 7 to 20 days, depending on how long it takes the customer to return the signed documents. However, we have seen examples of customers taking two or more months to return the documents.

If directed we could also report the Last Modified Date as the payment effective date stated in signed modification agreements. This effective date would be binding even if the borrower signed and returned modification documents after that date.

If we were required to report the date the modification agreement was printed, and these documents are not returned in a timely manner, there could be downstream impacts to other data fields associated with the modification, such as Interest Rate After Modification (Field 104), Remaining Term After Modification (Field 106), etc. In this scenario, the modification date would show as being modified, but the product processor would not be updated until the signed agreement was received back from the borrower, as described above.

A: Report the effective date in the modification agreement as Last Modified Date (line item no. 75, CCFLM216). (FRB Response: December 11, 2019)

Q (Y140001031, A.1 – Loan Level Table):

The BHC currently reports this field consistently with the property type provided in the appraisal. The appraisals also indicate a Planned Unit Development (PUD), typically under the special characteristics section. Please provide further guidance how Property Type should be reported for loans secured by single family residential properties, condos, or 2-4 unit multi- family properties located within a PUD. Is it acceptable to report single family residential, condos or 2-4 unit multi-family properties as Property Types 1 or 2, or must they be reported as Property Type 6 if within a PUD?

A: If it is known that a property is in a planned unit development (PUD) and the underlying property type is also known, report the underlying property type. In this case, the underlying property types given in the instructions are: 1 = Single Family Residential; 2 = Condo; 3 = Co-Op; 4 = 2-4 Units; 5 = Townhouse; 7 = 5+ Units; E = Commercial; F = Mixed Use; or M = Manufactured Housing. If it is known that the property is a PUD, but there is no information on the underlying property type as defined above, use 6 = PUD.
(FRB Response: December 11, 2019)

Q (Y140000976, A.1 – Loan Level Table): Workout Type Complete—Schedule A.1 line #77 & B.1 line #61 (Workout Type Completed):

Line item #77 requires coding for loans where a loss mitigation effort has been completed in the current month. Instructions state that loans for which no modification has been completed or that have never been modified should be left blank. FAQs RTH0043 and RTH0100 state the value "0" should be used for no workout completed or unsuccessful resolution of a loss migration efforts. However, the instructions nor the FAQs do not address loans for which the workout program was completed prior to the current month. For completed workout programs that were completed earlier than the current reporting month, how should loans be coded?

Additional Support:

Prior Q&A:

Q: Y-14M First Lien and Home Equity schedules have a fields called "Workout Type Completed." The instructions state that this is only coded for loans that successfully completed the loss mitigation process in the current month. However, there is a value of "0," which is defined as "no workout completed or unsuccessful resolution of loss mitigation effort." Should a "0" be populated if loss mitigation efforts are ongoing but not completed/resolved? If a loan has never been in loss mitigation, should the value be blank?

A: The Field Workout Type Completed should only be coded for any loan where a loss mitigation effort has been successfully completed in the current month. Code value of "0" should be entered only in the case where no workout is completed or there is an unsuccessful resolution of a loss mitigation effort. Do not enter a code value of "0" if loss mitigation efforts are ongoing but not completely resolved. For the cases where loss mitigation efforts are ongoing but not completely resolved, this field should be left blank. Also, if a loan has never been in loss mitigation, the value should be left blank.

Prior Q&A:

Q: For the field workout type completed #77, in what cases do we use a value of "0" and in what cases do we leave it blank?

A: This code value of "blank" will be used in the following cases:

• If the loans has never been in loss mitigation; or
• Where loss mitigation efforts are ongoing but not completely resolved

A: As stated in the instruction, the line item should be coded in only the reporting month when the workout type was completed and not in subsequent months.
(FRB Response: July 10, 2019)

Q (Y140000978, A.1 – Loan Level Table): Null fields for REO:

Additional clarification is required on a FAQ related to the FR Y-14M Schedule A.1 and B.1. dated September 13, 2017 provided: ". . . fields that are no longer relevant to an REO property such as current interest rate, current P&I payment and monthly draw amount should be left NULL..."

In addition to the fields that should be left NULL as specified in the previous FAQ (i.e., current interest rate, current P&I payment and monthly draw amount), should we also report the following fields NULL?

All fields that ask for "current" information

All fields which the EditChecks specify to be reported NULL if reporting REO

If our understanding is incorrect, please provide a full list of the fields in Schedule A.1 and B.1 that should be reported NULL for REO.

Fields that ask for "current" info:

• Current Combined LTV
• Current Credit Bureau Score
• Current Credit Bureau Score Date
• Current Credit Bureau Score Vendor
• Current Credit Bureau Score Version
• Current Credit Limit
• Current Interest Rate
• Escrow Amount Current
• Interest Type - Current
• Principal and Interest
• (P&I) Amount Current

Fields to be left "NULL" if reporting REO as specified in the FRB EditChecks:

• Principal and Interest
• (P&I) Amount at Origination
• Current Interest Rate
• Principal and Interest
• (P&I) Amount Current
• Current Credit Bureau Score Date
• Current Interest Rate
• Principal and Interest
• (P&I) Amount Current
• Monthly Draw Amount

A: Yes, the following fields may be left NULL for REOs

• Current Combined LTV (B1. line item no. 76, CCHEM266)
• Current Credit Bureau Score (A1. line item no. 48, CCFLM189, B1. line item no. 14, CCHEM189)
• Current Credit Bureau Score Date (A1. line item no. 138, CCFLS382, B1. line item no. 113, CCHES382)
• Current Credit Bureau Score Vendor (A1. line item no. 136, CCFLR038, B1. line item no. 111, CCHER038)
• Current Credit Bureau Score Version (A1. line item no. 137, CCFLR039, B1. line item no. 112, CCHER039)
• Current Credit Limit (B1. line item no. 46, CCHEM250)
• Current Interest Rate (A1. line item no. 56, CCFLM197, B1. line item no. 41, CCHEM197)
• Current Monthly Draw Amount (B1. line item no. 45, CCHEM249)
• Escrow Amount Current (A1. line item no. 113, CCFLM268)
• Interest Type – Current (A1. line item no. 132, CCFLM248, B1. line item no. 42, CCHEM248)
• Principal and Interest (P&I) Amount Current (A1. line item no. 43, CCFLM200, B1. line item no. 59, CCHEM200). (FRB Response: July 10, 2019)

Q (Y140000981, A.1 – Loan Level Table): Foreclosure status for liquidated loan (3rd party sale):

The line item requires a response for loan status with allowable code values of ranging from 0 – not in foreclosure to 3 – REO. Existing FAQ provides guidance indicating that loans in a foreclosure process should remain classified as "1 – In foreclosure, presale" until liquidated. However, in the month that the loan liquidates, there does not appear to be appropriate category to reflect the status of the loan (the loan didn't become an REO on our books and is no longer in the foreclosure process). How should such loans be coded in the month of liquidation?

For example, a foreclosure process on a loan began in May 2018. The loan was eventually sold to a third party in June 2018. For Field 65, the loan was coded as "1=In foreclosure, pre-sale" on the 5/31/18 report. We would like clarify how we should code the loan for the 6/30/18 report in Field 65? Should it remain as "1=In foreclosure, pre-sale" or should the code value change since it was liquidated during the month?

A: In the month the loan liquidates, code the field Foreclosure Status (line item no. 65, CCFML206) as "2." (FRB Response: July 10, 2019)

Q (Y140000779, A.1– Loan Level Table):

Line 78 – Repayment Plan Performance Status (MDRM: CCFLM219): Per the instructions, "This line item is only to be populated for repayment plans that were active as of the end of the month or broken during the month." As stated in the instructions we have been reporting this field as empty strings for loans that do not have a repayment plan (and never have). However, these will fail and edit as the edit failure description reads: "Repayment Plan Performance Status Must Be 0 through 10." If we do not have a repayment plan on a loan and never have, what should be reported?

A: The line item 78 should be coded only for line item 76 – Active Repayment Plan Flag = "Y." For those loans that do not have a repayment plan, report null for line 78 – Repayment Plan Performance Status. (FRB Response: April 11, 2018)

Q (Y140000675, General) 14M Product Type – Origination (field 133) and Product Type – Current (field 19):

As per the FR Y-14M Domestic First Lien closed 1-4 Family Residential template instructions, BHC must report the "Product Type – Origination" and "Product Type – Current."

How should we reflect the response for "Product Type – Origination" (field 133) and "Product Type – Current" (field19) for a 1 month ARM loan, where the interest rate resets on a monthly basis for the entire term of the loan? Should this product type be reflected as "ARM 1" (Adjustable rate mortgage where the initial rate reset is less than or equal to 1 year) or "ARM Other"?

A: For a mortgage loan with a variable rate where the interest rate changes on a monthly basis, or changes anytime the loan's index value changes, code the fields Product Type Origination and Product Type Current (first lien fields #133 and 19) as "ARM Other."
(FRB Response: March 14, 2018)

Q (Y140000676, A.1 – Loan Level Table):

14M HFI FVO/HFS Flag (field 130): As per the FR Y-14M Domestic First Lien Closed-end 1-4 Family Residential template instructions, BHCs must report whether all portfolio loans are held for investment (HFI), measured at fair value under a fair value option (FVO) or held for sale (HFS).

Are REO assets included in the definition of Portfolio loans for purposes of reporting on the FR Y-14M Domestic First Lien Closed-end 1-4 Family Residential loans template, if yes, how should the field 130 "HFI FVO/HFS Flag" be populated for REOs (i.e., "Foreclosure Status" =3)? Should field 130 be reported as "N" (No) or left "blank" as these REO assets are no longer in a loan form?

A: Yes, REO assets are included in the definition of portfolio loans for the purposes of reporting on the Y-14M schedule. If the field HFI FVO/HFS Flag (field 130) is coded as "Y" (or "N") before the REO, retain that designation through REO disposition. Do not change the designation because of the loan transitioning to REO. (FRB Response: March 14, 2018)

Q (Y140000689, A.1 – Loan Level Table):

How should we code fields 74 (Modification Type) and 77 (Workout Type Completed) when we have a modification that includes a partial claim?

A: Code the field Modification Type (first lien, field 74) with the applicable code other than "0" (zero) to indicate that the loan has been modified.

Code the field Workout Type Completed (first lien, field 77) as "12" (Other) unless other codes listed in the Y-14M instructions apply for a specific scenario. For instance, if the workout involves FHA partial claim, use code "5" as specified in the instructions.
(FRB Response: March 14, 2018)

Q (Y140000690, A.1 – Loan Level Table):

FNMA introduced in 2017 a revised singular Flex modification program as described in Lender Letter LL-2016-06. The new program is intended to replace the Fannie Mae Home Affordable Modification Program which expired end of 2016 and the Streamlined Modification Program which is set to expire in Oct 2017. Servicers are expected to adopt the revised standard no later than October 1, 2017. Under certain criteria a borrower response package (i.e., borrower financials) is not expected to be required. Has the FRB assessed the potential impact of the reduced borrower documentation requirements to the Industry's ability to report on 14M loan modification related data fields? (For example line 72 "Refreshed DTI Ratio (Back end)" and line 73 "Refreshed DTI Ratio (Front end).")

A: The Federal Reserve staff is aware of various modification programs and continues to evaluate the impact of any changes.

All fields, including the fields indicated in this question must be reported for the Y-14M reporting purposes. However, if a specific Y-14M edit check fails because the data is reported NULL or has a value outside the parameters of an established edit check, we require that the BHC provide details confirming the reporting is correct. Work with the data aggregator to document the reasons for missing data, or any edit check fails, if so.
(FRB Response: March 14, 2018)

Q (Y140000691, A.1 – Loan Level Table):

Is the intention of FR Y-14M, Schedule A: Domestic First Lien Closed-end 1-4 Family Residential Loan Data Dictionary, A.1 Loan Level Table, line item 84, Step Modification flag, to capture all rate modifications that are "stepped" or only those that are stepped and ultimately return to the non-modified rate?

Background: The instructions to line item 84, Step Modification flag, read: Step Modification Flag – Report whether a rate modification has a "stepped" or gradual return to non-modified rate.

This line item should be reported as "N" if the loan immediately returns to the contract rate at expiration of the modification.

A: This field is intended to capture all rate modifications that are stepped and ultimately return to the non-modified rate. (FRB Response: March 14, 2018)

Q (Y140000748, A.1 – Loan Level Table):

Line Item No 23 – Property Type: Which property type should be used to report a loan on a single family residence within a planned unit development? If the underlying property type takes precedence, i.e., the loan is reported as a 1 – SFR, what situation would result in a loan being reported as a 6 – PUD?

A: If it is known that a property is in a planned unit development (PUD) and the underlying property type is also known, report the underlying property type. In this case, the underlying property types given in the instructions are: 1 = Single Family Residential; 2 = Condo; 3 = Co-Op; 4 = 2-4 Units; 5 = Townhouse; 7 = 5+ Units; E = Commercial; F = Mixed Use; or M = Manufactured Housing. If it is known that the property is a PUD, but there is no information on the underlying property type as defined above, use 6=PUD.
(FRB Response: March 14, 2018)

Q (Y140000759, A.1 – Loan Level Table):

Should we include all non 1-4 family REO loans in the 14M RE submission?

A: Non 1-4 family REO loans should not be included in the Y-14M Schedule A and Schedule B submission. (FRB Response: February 14, 2018)

Q (Y140000760, A.1 – Loan Level Table):

We have a population of accounts that have been modified more than once. The first time with capitalization, the second without. Is the Capitalization Flag apply to only the current modification, or should it be populated with a Y the entire life of the loan if it has had at least one modification with capitalization?

A: The Capitalization Flag should only apply to the current modification.
(FRB Response: February 14, 2018)

Q (Y140000752, A.1 – Loan Level Table):

With regards to MSR reporting requirements, BHC would further like to clarify some key points and reconfirm if loan population related to MSR is required to be reported.

1. Separate portfolio: From a materially point of view—the UPB of the loans is at less than 1% of average Tier 1 capital, and MSR valuation itself is immaterial and therefore BHC's view is to consider this a separate portfolio.
2. Sub-servicer: While BHC have an immaterial portfolio of mortgage servicing rights retained on first-lien whole loans, servicing is actually outsourced to a sub-servicer.

3. Ceased Business Activity: These MSRs retained represent the on first lien whole loans portfolio, which were originated and sold to FNMA prior to 2012, since than the business activity ceased.

   In light of these clarifications, can you please advise if the first-lien mortgage loans that relate to MSRs should be reported on Schedule A of the FR Y-14M?

A: The FR Y-14 applies materiality threshold limits to the overall portfolio of first-lien mortgages. If a BHC's overall first lien portfolio meets this materiality criterion, each exposure in the portfolio is subject to FR Y-14M reporting for first lien. The relevant loan population includes all loans directly held on the BHC's portfolio and all loans serviced by the BHC in that period. For schedules that require the institutions to report information on serviced loans, the materiality threshold is based on the asset balances associated with the BHC's owned portfolio. All loans that meet these criteria must be reported, irrespective of whether the BHC services its portfolio loans, or it is subserviced by other BHCs on the firm's behalf.

As noted in the loan populated criteria listed on the FR Y-14M schedule instructions for first-lien schedule, "Portfolio loans are defined as all loans meeting the definition of FR Y-9C, Schedule HC-C, item 1.c.(2)(a). Serviced loans include those meeting the definition of first-lien loans reported in FR Y-9C, Schedule HC-S, item 1 column A, Schedule HC-S item M.2.a, Schedule HC-S, item M.2.b, Schedule HC-S, item M.2.c, and Schedule HC-S, item M.2.d."

If the set of loans where the BHC has mortgage servicing rights as noted in the question as a), b), and c) meets any of these criteria, these loans should be reported.
(FRB Response: December 20, 2017)

Q (Y140000669, General) 14M Paid-in-Full Coding (field 64):

As per the FR Y-14M Domestic First-lien closed-end 1-4 Family Residential template instructions, BHC must report the liquidation method for any loan that was liquidated during the reported month. For portfolio loans that are sold to a third party, should field 64 "Paid-in-full Coding" be reported as "Service Transfer" (3)?

A: Yes. (FRB Response: September 13, 2017)

Q (Y140000670, General) 14M Real Estate Owned assets:

As per the FR Y-14M Domestic First-lien Closed-end 1-4 Family Residential template instructions, BHCs are required to continue reporting data on loans which become Real Estate Assets (REOs) until the loan terminates as a REO sale or otherwise. For loans that become REOs (i.e., "Foreclosure Status" = 3 in the reporting instructions), should loan related fields (e.g., "Current Interest Rate," "Principal and Interest Amount Current") be reported with the data submitted on the FR Y-14M prior to the loan becoming REO? Alternatively, should these fields be left blank once the asset becomes REO?

A: As noted in a prior Q&A, once a loan enters REO, it is essential to keep reporting key attributes of the loan originated on the property so that a loan can be tracked from a performing or delinquent status up until the time the property collateralizing the loan is disposed. Continue reporting through REO all of the loan's origination attributes (e.g., original LTV, property state, property zip, etc.). Also continue to report the outstanding principal on the loan and the date on which the next payment was due so that time in REO can be tracked. Fields that are no longer relevant to an REO property such as current interest rate, current P&I payment and monthly draw amount should be left NULL. Do not populate a field with a "0" or other value unless explicitly indicated in the instructions for that field. To code the paid-in-full-type and foreclosure-type fields correctly report a loan that is currently in the REO process with a paid-in-full-type of "0" and a foreclosure-type of "3." Once the REO property has been liquidated, the paid-in-full-type and foreclosure-type should be coded as "2" and "3" respectively. (FRB Response: September 13, 2017)

Q (Y140000671, General) 14M Origination Credit Score (field 13) and Current Credit Score (field 48):

As per the FR Y-14M Domestic First Lien Closed-end 1-4 Family Residential template instructions, BHC must report the credit score of the borrower using a commercially available credit bureau score. For loans where the legal borrower is in the form of an Entity (e.g., LLC), and where the Entity is the sole borrower/obligor, a commercially available credit bureau score is not available. In certain cases, an individual may be present in the initial lending decision—where this individual is added as a co-borrower alongside the Entity, the credit score of the individual is available and will be reported. However, in cases where the individual is not required to join the loan from a credit risk perspective, and the Entity is the only legal borrower/obligor on the transaction, a representative credit score of the Entity legal borrower would not be available. Where the Entity is the sole borrower/obligor, is it expected that fields "Origination Current Credit Score" (field 13) and "Current Credit Bureau Score" (field 48) are reported as blank?

A: In such cases where the credit bureau score is not available or was not used for the underwriting decision, report these fields as NULL. Loans marked as commercial loans (i.e., Field #124 "Commercial Loan Flag"=1) where the legal borrower is an Entity such as an LLC is one such case. (FRB Response: September 13, 2017)

Q (Y140000672, General) 14M ARM Periodic Rate Floor (field 36):

As per the FR Y-14M Domestic First Lien closed 1-4 Family Residential template instructions, BHC must report the periodic interest rate floor for adjustable rate loans. For loans that do not have a periodic rate floor, how should the field 36 "ARM Periodic Rate Floor" be reported? Should it be populated with the same response as required under the field 38 "ARM Lifetime Rate Floor" since the lifetime rate floor would apply on a periodic basis or should field be reported as "blank"?

A: For loans that do not have a periodic rate floor, report the field as NULL. Work with the data aggregator to document the reasons for any edit checks fails that result from such missing data. (FRB Response: September 13, 2017)

Q (Y140000674, General) 14M Foreclosure Status (field 65):

As per the FR Y-14M Domestic First Lien Closed-end 1-4 Family Residential template instructions, BHCs are required to continue reporting data on loans which become Real Estate Assets (REOs) until the time the loan terminates as a REO sale or otherwise. BHCs must report the current foreclosure status as of the end of the reporting month. Where the REO has been liquidated as of the end of the reporting month (i.e., where "Paid in Full Coding (field 64)" is now other than "0") should the response for field 65 "Foreclosure Status" continue to remain as "3" (REO) as it was reported in the previous month? Alternatively, for the month in which the REO asset has sold should the Foreclosure Status field 65 now revert to "0" (Not in foreclosure) given the asset has been liquidated as of the end of the reporting month?

A: Report Paid in Full Coding (first lien, field #64) as "0" while the loan is in active REO. Report Paid in Full Coding as "2" in the month the loan liquidates, and then the loan will be removed from the file in the following month. The Foreclosure Status (first lien, field #65) will be coded as "3" (REO) in the month the loan liquidates. (FRB Response: September 13, 2017)

Schedule B—Domestic Home Equity Loan and Home Equity Line Data Dictionary

Q (Y140001667, B.1 – Loan/Line Level Table):

The general instructions for FR Y-14M Schedule B.1 state to identify HELOC renewals "using the applicable code value for the field Modification Type (B.1 field #77) and indicate the line renewal date in the field Last Modified Date (B.1 field #78)." Would modification type 13 - "HELOC line renewal (regular)" be reported for renewals that did not undergo any loss mitigation efforts?

A: If a HELOC has been renewed and the contract terms have changed, report such a renewal using code value 13—"HELOC Line Renewal (Regular)"—if the borrower meets the reporting entity's current credit standards, and report using code value 14—"HELOC Line Renewal (Loss Mitigation)"—if the borrower does not meet the reporting entity's current credit standards. (FRB Response: April 24, 2024)

Q (Y140001140, General):

The instruction of field #37 Original Loan Term states, "For a line of credit, the original loan term should be the combined draw period and the amortized repayment period." We have HELOC accounts originated with a known Draw term, but either unknown Repay Term or a balloon payment required one month after end of draw. For the unknown repayment period, the contract normally states the draw period can be renewed or the line can be refinanced at the lender's discretion providing the borrower continue to meet certain criteria. It can also be determined by remaining outstanding balance at the end of the draw period. For example, depending on if the balance exceeds $5k or not, the repayment period can be either 120 or 60 months, or it is determined by the a fixed monthly payment amount calculated as a fixed percentage of the balance at end of draw. For these situations, should we report the Original Draw Term as the Original Loan Term?

If the answer is yes, how should we handle those failing edit 37.3 once these accounts pass the 3 months after the Original Draw period?

For those with balloon payment at the end of draw, Original Loan Term would be Draw term plus 1 month, which would fail the edit 37.2 since it would be the values other than those listed in the edit rule, i.e., draw term 60 months, total loan term would be 61. Please provide guidance on these.

A: Report FR Y-14M Schedule B.1 line item 37, Original Loan/Line Term, based on the information known at loan origination. If the loan term subsequently becomes known after the expiration of the draw period, update the line item with the known loan term. For loans with an unknown repayment period, report the original draw term as the original loan term. For those with balloon payment at the end of draw, Original Loan Term would be the draw term plus one month. (FRB Response: September 15, 2021)

Q (Y140001143, General): Topic: HELOC Credit Limit – Expired Draw Period

Question:
Field 46 on schedule B of the FR Y-14M reports the total credit line currently available to the borrower for lines of credit. Instructions note to leave blank for home equity loans. Based on FAQ RTH0092, a HELOC that reaches the end of its draw period should continue to be reported as a HELOC even once the loan starts to amortize. For a HELOC where the draw period has concluded, should the current credit limit field reflect the line's original credit limit or the amount outstanding as of the report date? For example, the bank originates a $100,000 HELOC on 1/1/18 with a 12 month draw period. On 1/1/19, the borrower has an outstanding balance of $60,000 and cannot draw on the line anymore. Should the current credit limit field reflect:

1. the $100,000 original credit limit,
2. the $60,000 currently outstanding on the line,
3. the $0 additionally available to the borrower, or
4. be left blank?

A: Current Credit Line Amount – For lines of credit, report the total credit line currently available to the borrower. Lines that can permanently no longer be drawn upon should be reported as closed. Follow normal reporting practices for the current credit limit. Report the current credit limit as $0 if the borrower cannot draw on the line anymore. (FRB Response: September 15, 2021)

Q (Y140001197, B.2 – Portfolio Level Table): Topic: Modification Type (Field #77)

Question: The instructions for FR Y-14M Schedule B Field 77 ‘Modification Type' include the following definition of value 14 – ‘HELOC Line Renewal (loss mitigation strategy)':

HELOC Line Renewal (loss mitigation strategy) – Report any lines that have been renewed and contract terms have changed and the borrower does not meet the current BHC or IHC credit standards. This code value applies when the borrower has entered into a new contractual obligation with the lender and the HELOC terms have changed.

For situations where the borrower does not meet the current BHC or IHC credit standards but the modification results in a product type change from a HELOC to a loan, should a value of 14 – ‘HELOC Line Renewal (loss mitigation strategy)' be used or should another value be reported?

A: Yes, report code value 14 – "HELOC Line Renewal (loss mitigation strategy)" in this case. (FRB Response: November 12, 2020)

Q (Y140001033, General):

1. The instructions for Schedule B.1 Line Item 61, "Workout Type Completed" is silent on the definition of "7 = Settlement." What does the FRB expect to be reported as "Settlement" and can examples please be provided?
2. The instructions for Schedule B.1 Line Item 61, "Workout Type Completed" is silent on the definition of "8 = Other." What does the FRB expect to be reported as "Other" and can examples please be provided?
3. Apart from "Settlement" Workout Type, does the FRB expect values to be populated in Schedule B.1 Line Item 63, "Settlement Negotiated Amount" for other workout types? For example
   • if Schedule B.1, Line Item 61 equals to "1 = Modification," what value should be reported in B.1, Line Item 63?
   • if Schedule B.1, Line Item 61 equals to "1 = Payment Plans," what value should be reported in B.1, Line Item 63?
4. Should Schedule B.1 Line Item 63, "Settlement Negotiated Amount" follow the same timing as Schedule B.1 Line Item 61, "Workout Type Completed (i.e., only be populated in the month where the workout type was completed and not in subsequent months)?

 

A:

1. A Settlement is an agreement to accept as payment in full of the debt an amount that is less than what is contractually owed. Institutions sometimes negotiate settlement agreements with borrowers who are unable to service their unsecured open-end credit. In a settlement arrangement, the institution forgives a portion of the amount owed. In exchange, the borrower agrees to pay the remaining balance either in a lump-sum payment or by amortizing the balance over a several month period.
   Settlement programs are another type of workout program in which the bank agrees to accept less than the full balance due from a borrower in full satisfaction of the debt. As with any other workout program, collectors should determine the borrower's ability to repay under the settlement terms.
2. Use Workout Type = 8 (Other) if a workout was completed that is not included in any other option (modification, repayment plan, deeds-in-lieu/short sales, stipulated repayment, and settlement). This is meant to capture any loss mitigation activity that does not fit into the prior categories. Examples may include strategic refinances or changes to scheduled balloon-payments that do not operate under modification agreements.
3. Line Item 63 "Settlement Negotiated Amount" should only be populated when Line Item 61 Workout Type = 7 (Settlement).
4. Yes. Line Item 63 "Settlement Negotiated Amount" should only be populated the month the settlement was completed, that is, the month Line Item 61 Workout Type = 7 (Settlement). (FRB Response: December 11, 2019)

 

Q (Y140001034, General):

How should a Home Equity Line of Credit (HELOC) be reported if certain segments of the funded line are interest only while certain other segments are loans with payments which include both principal and interest?

Background: Certain home equity lines of credit when drawn upon allow the customer to modify their drawdowns into segments so that the payment for certain segments are interest only and the payment for certain other segments include both principal and interest. However, all these segments are associated with one loan number, which is assigned to a HELOC and are aggregated for reporting at that loan/line of credit number in Schedule B.1.

Our current practice is that if the payment received for the loan is interest only for the primary segment then we flag that loan as "Y=Was I/O in the reporting month." Primary segment is the main segment linked to the Revolving Credit Line as defined in the borrower's HELOC agreement document. We will continue to report this way until we receive further clarification.

A: Report Interest Only in Reporting Month (line item no. 22, CCHEM190) as "Y" if the primary segment is Interest Only. (FRB Response: December 11, 2019)

Q (Y140000781, B.1 – Loan/Line Level Table):

Line 7 – Original Loan/Line Commitment (MDRM: CCHEM242): As per the FR Y-14M Domestic Home Equity Loan and Home Equity Line template instructions, BHCs should report the total credit line available at origination (i.e., the total commitment), not the actual amount drawn (amount drawn is reported in Line Item 6). For lines with a zero balance and no draws, report "0" for this item. Note: For HELOANSs, Line items 6 and 7 will be the same value. However, edits for this field have recently increased to include lines with an original loan/line amount of "0." What is the correct way to report lines with a zero balance and no draw?

A: For lines with a zero balance and no draws, report the total credit line available at origination (i.e., the total commitment), not the actual amount drawn (amount drawn is reported in Line Item 6). (FRB Response: April 11, 2018)

Q (Y140000754, B.1 – Loan/Line Level Table):

The instructions for field 7 – Original Loan / Line Commitment field on the Home Equity schedule state: "For lines with a zero balance and no draws, report ‘0' for this item." Should we report "0" for lines that meet this condition at origination, and then update this field to report the total credit line commitment amount once the line has been drawn upon? Since this is an origination field, we want to ensure it is expected that values for this field could change for lines.

A: For lines with a zero balance and no draws, report the total credit line available at origination (i.e. the total commitment), not the actual amount drawn (amount drawn is reported in Line Item 6). Do not update this field to report the total credit line commitment amount once the line has been drawn upon. (FRB Response: February 14, 2018)

Q (Y140000738, General):

Need guidance on a Home Equity modification program that does not fit the FRB definition for Modification Type (HE Field 77 M215) "altered through loss mitigation efforts." How should these modifications be reported in schedule? Modification program is a Home Equity repayment extension program that extends repay terms on HELOC for non-delinquent borrowers (in good standing, not in default/loss mitigation), does not fit FRB modification definition "in Loss Mitigation," and would not classify as a renewal of the Line.

A: Report these modifications with Modification Type (HE Field 77) as "9 – Proprietary Other." Also make sure that the remaining term (HE Field 84) is updated accordingly.
(FRB Response: December 20, 2017)

Q (Y140000673, General) 14M HELOCs:

As per the FR Y-14M Domestic Home Equity Loan and Home Equity Line template instructions, BHCs should continue reporting the HELOCs in the FR Y-14M Home Equity schedule even after they have entered into a pay down status and are no longer revolving credits, and that the loan type at origination determines where the exposure should be reported. This explicit guidance is absent in the FR Y-9C instructions, and may yield a reporting difference amongst regulatory filings. Is this reporting difference expected and if not, which reporting should be adjusted?

A: For the Y-14M reporting, continue reporting the loans as per the specifications outlined in the Y-14M instructions. Reporting differences of this type are expected between reporting schedules. (FRB Response: September 13, 2017)

Schedule C—Address Matching Loan Level Data Collection

No questions for publication.

Schedule D—Domestic Credit Card Data Collection Data Dictionary

Q (Y140001062, General):

Question:

Please clarify what should be reported as Option "1 - Yes" in FR Y-14M Schedule D.1 Line Item 108, "Fraud in the Current Month":

1. Should the firm report option 1 if the account has fraud but is not frozen?
2. If Yes to question 1 above then,
   1. Should the firm report Option 1 if the fraud identification and conclusion of investigation all happened within the same month?
   2. Should the firm report Option 1 if the fraud was identified within the reporting month, but the investigation is still ongoing as of the last day of the current reporting month?
   3. Should the firm report Option 1 if the fraud was identified in previous months but the investigation was concluded in the current reporting month?
   4. Should the firm report Option 1 if the fraud was identified in a previous month but the investigation is still ongoing as of the last day of the current reporting month?

Background:

The Line Item Name for Schedule D.1 "Fraud in the Current Month", suggests that firms should report Option 1 in the following two scenarios:

1. When the account is currently frozen due to a potential fraud or
2. When the account has been closed for cause at the conclusion of a fraud investigation month

However, it's not clear how to report when there is a fraud and when the account has NOT been frozen.

The firm usually has situations where there is a fraud but the account is not frozen. The instructions for Schedule D.1 Line Item 1, "Reference Number" requires firms to report a unique identifier which identifies the account or account relationship for its entire life. We interpret that to mean an account reference number (ARN) assigned to the credit line provided to each customer. One ARN may have multiple 16-digit credit card accounts each of which is linked to a specific physical credit card associated to one line of credit under this ARN. In most cases, a customer is likely to have a fraudulent transaction on a specific 16-digit credit card account. Subsequently, when this 16-digit credit card account is frozen customers usually receive a replacement card with a new 16-digit credit card account number soon after the incident. The ARN which is associated to that customer's credit line will still be open. It's rare for fraud to occur on an ARN account level.

The firm is currently reporting Option 1 when a fraudulent transaction is identified on a 16-digit credit card account within an ARN during the current month even though the ARN is not frozen. In the subsequent month the fraudulent transaction may remain on the account if it has not been charged off from the account, however, that ARN is reported as Option "2 - No" in subsequent months.

Below is how the firm is reporting currently:

1. If the fraud identification and conclusion of investigation all happened within the same month, we report Option 1.
2. If the fraud was identified within the reporting month for the account, but the investigation is still ongoing as of the last day of the current reporting month, we report Option 1.
3. If the fraud was identified in previous months but the investigation was concluded in the current reporting month, we report Option 2.
4. If the fraud was identified in previous months but the investigation is still ongoing as of the last day of the current reporting month, we report Option 2.

A: If an account is not currently frozen due to a potential fraud and has not been closed for cause at the conclusion of a fraud investigation, report "2 – No" in FR Y-14M Schedule D.1 Line Item 108, "Fraud in the current month." (FRB Response: October 9, 2024)

Q (Y140001645, D.2 – Portfolio Level Table):

For the FR Y-14M Schedule D.2, should the Firm report interchange activity consistent US GAAP, where it is captured net within Non-Interest Income or would the FR Y-14M differ from GAAP and be captured as Non-Interest Expense?

The FR Y-14M Schedule D.2 has separate Line Items for Interchange Expenses and Interchange Income related to card associations, which is a divergence from US GAAP. Given this divergence, the FR Y-14M reporting instructions are not clear where the remainder of items that are recognized as interchange and are presented as contra non-interest income under GAAP should be reported. Should these amounts be reported in FR Y-14M Schedule D.2 line item 34 (Non- Interest Expense- All Other Expense) where the instructions refer to interchange? If not, where should they be reported in the FR Y-14M?

A: Firms should report interchange activity consistent with the instructions in FR Y-14M, Schedule D.2 (Domestic Credit Card Data Collection Data Dictionary Portfolio Level Table).

As noted in the FR Y-14M instructions, the FR Y-14M schedules are to be prepared and filed in accordance with U.S. GAAP. For stress testing purposes, the instructions ask firms to break down the components of net interchange income under U.S. GAAP into three separate Line Items: Interchange Income (Item 44), Total Non-Interest Expenses – Interchange Expenses (Item 30), and Total Non-Interest Expenses – All Other Expenses (Item 34). Items 30 and 34 are presented as contra Interchange Income. Firms should follow the instructions to report the interchange expense fees paid to the card associations (such as payment to partner) under Item 30 and report all other operating and other expenses associated with processing interchange under Item 34. Firms should also follow the instructions to report the interchange fees (revenues) received from the card associations under Item 44. (FRB Response: January 17, 2024)

Q (Y140001175, D.1 – Loan Level Table):

Line items 77 and 78 of schedule D.1 collect information on the variable rate index and margin for credit card accounts. Line item instructions reference line item 55 – Interest Type in Current Month, which was retired with the March 2020 revised instructions. The retired line item states to report whether the purchase APR is fixed or variable, but clarifies to report pre-workout terms if an account is in a temporary workout program. As field 55 will be eliminated (effective 3/31/2020) and fields 77 and 78 do not include any qualifying constraint, please clarify whether line items 77 and 78 should continue to reflect pre-workout variable rate information if an account is in a temporary workout plan.

A: Line items 77 and 78 should continue to reflect pre-workout variable rate information if an account is in a temporary workout plan. (FRB Response: November 18, 2020)

Q (Y140001208, D.1 – Loan Level Table):

The FR Y-14M Schedule D reporting instructions for Data Field #23 Total Cash Reward states "Institutions should report the cumulative reward available to the customer as of the reporting month." In instances where there are multiple credit card accounts that earn rewards that are contributed to the same single reward account, how should reporting institutions populate this data field? Should the total reward amount be duplicated for each credit card account, or should there be an even allocation of the total reward amount across each reward-earning credit card account?

A: The reward should be allocated to the relevant accounts if possible. The reward should not be duplicated across accounts. (FRB Response: November 12, 2020)