14M / 14Q: Use Of N_AMRT_TERM In 14M CCFLM166 And FR-Y 14Q H2 'Amortization' Issue
(Doc ID 2809847.1)
Last updated on OCTOBER 03, 2021
Applies to:Oracle Financial Services - Regulatory Reporting for US Federal Reserve - Lombard Risk Integration Pack - Version 8.0.8 and later
Information in this document applies to any platform.
STG_LOAN_CONTRACTS.N_AMRT_TERM is used to populate FCT_COMMON_ACCOUNT_SUMMARY.N_AMRT_TERM. This FCT field is used in two MDRM: FR-Y 14M Schedule A1 CCFLM166, and FR-Y 14Q H2 'Amortization'.
CCFLM166 Balloon Term (In Months) has Fed instructions: For mortgages with a final balloon payment, report the term in months between the loan closing date and the due date for the final payment (based on maturity date) before the note resets (e.g., 84 months for a 7-year balloon). Hence the MDRM is requesting a number of months until the balloon payment for all loans that have a balloon payment.
Field 20 Amortization (K457) in FR-Y 14Q Schedule H2 requires a total number of months that the amortization schedule implies disregarding any balloon payments. See the following description in Fed instructions for this MDRM.
For loans with a monthly amortization schedule, report the original amortization term of the loan in months from the date given in Field 10 at the rate implied by the current payment disregarding any balloon payment.
Issue in logic:
1) Use of the same column for both FR-Y 14M CCFLM166 (Balloon Term) and FR-Y 14Q Schedule H2 Field 20 Amortization (K457) does not meet the requirement being different multiple definitions
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