Survey of Terms of Business Lending

Board of Governors of the Federal Reserve System

Instructions for Preparation of

Survey of Terms of Business Lending

Reporting Form FR 2028A
Effective August 2012

General Instructions

Purpose
The Federal Reserve System uses data from this survey
to measure the cost of business borrowing from U.S.chartered banks and U.S. branches and agencies of
non-U.S. (foreign) banks for analysis of developments in
business credit markets.

Survey Scope
This survey covers commercial and industrial (C&I)
loans to U.S. addressees when funds are disbursed to
borrowers during the report period. The report period
covers the first full business week of February, May,
August, and November.
For U.S. commercial banks: The definition of ‘‘commercial and industrial loans’’ corresponds to that used for
Item 4 of Schedule RC-C, Part I, of the quarterly Report
of Condition (FFIEC 031&041). Include all such C&I
loans to U.S. addressees made during the report period.
For FFIEC 031 and 041 reporters, C&I loans to U.S.
addressees are reported in Item 4.a of Schedule RC-C,
Part I excluding items noted below. For banks with
foreign offices (FFIEC 031 reporters), include all such
loans that are booked at U.S. (domestic) offices of the
reporting bank (Column B of the FFIEC 031) as well as
at non-U.S. offices, whether in the Bahamas, the Cayman
Islands, or other locations, for which records are maintained at U.S. offices.
For U.S. branches and agencies of non-U.S. (foreign)
banks: The definition of ‘‘commercial and industrial
loans’’ corresponds to all loans to U.S. addressees that are
booked at the U.S. offices of the branch or agency or at
non-U.S. offices, whether in the Bahamas, the Cayman
Islands, or other locations, for which records are maintained at U.S. offices. These loans are reported, respectively in Item 4 of Schedule C, Part I, excluding items
noted below, of the quarterly Report of Assets and
FR 2028A
General Instructions

August 2012

Liabilities of U.S. Branches and Agencies of Foreign
Banks (FFIEC 002) and item 2.c(3) of the Report of
Assets and Liabilities of Non-U.S. Branches that Are
Managed or Controlled by a U.S. Branch or Agency of a
Foreign (Non-U.S.) Bank (FFIEC 002S). Include all such
C&I loans to U.S. addressees made during the report
period by the respondent U.S. branch or agency (excluding those held in its IBF) (Item 4.a of Schedule C,
Column A minus Column B).
‘‘U.S. addressee’’ encompasses borrowers domiciled in
the fifty states of the United States, the District of
Columbia, or U.S. territories and possessions, including
U.S. offices or subsidiaries of non-U.S. (foreign) businesses. For further detail, please refer to the Glossary
entry for ‘‘domicile’’ in the instructions for the quarterly
condition report (FFIEC 031&041 or FFIEC 002).
Include:
• New loans, takedowns under revolving credit agreements, notes written under credit lines, and renewals.
Renewals include new loans under revolving credit
agreements that roll over earlier loans, including conversions of revolving credits into term loans.
• Loans disbursed during the report period, even if the
loans are not entered onto your institution’s books or
loan record system until after the report period.
• Your institution’s portion of drawn loan participations
and syndications when funds are disbursed during the
reporting period. (See the glossary entry for syndications in the instructions for the quarterly condition
report.)
• Overnight loans.
• Construction and land development loans that are not
secured by real estate.
Exclude:
• Loans denominated in non-U.S. currencies.
• Loans of less than $10,000.
GEN-1

General Instructions

• Loans disbursed before the report period that are
entered onto your institution’s books or loan record
system during the report period.
• Loans purchased in the secondary loan market.
• Purchased open market paper, such as commercial
paper and acceptances, and factored loans (that is,
purchased accounts receivable).
• Loans made by an international division, international
operations subsidiary, or Edge or Agreement subsidiary of your institution.
• Loans made to non-U.S. addressees (business firms
domiciled outside of the fifty states of the United
States, the District of Columbia, or U.S. territories and
possessions).
• Loans secured by real estate, even if for commercial
and industrial purposes.
• Loans resulting from unplanned overdrafts to deposit
accounts. Note, however, that loans extended as part of

GEN-2

a cash management program that would be classified as
C&I loans on the quarterly condition report should be
reported on the survey.
• Existing loans on which the rate changes during the
survey week when no additional funds are disbursed
during the survey week. For example, an outstanding
loan advance that has an interest rate tied to prime
should not be reported when the prime rate changes
during the survey week. Similarly, an outstanding loan
that is repriced during the survey week in accordance
with a lending grid (for example, a loan rate tied to a
borrower’s financial ratios or bond rating) should not
be reported since no funds are disbursed during the
survey week.
• Intercompany loans.
• Loans held for trading purposes.
• Loans to financial institutions.

General Instructions

FR 2028A
August 2012

Line Item Instructions

For example, if the stated rate of interest is 50 basis
points over prime, the nominal rate of interest
reported here should be the prime rate for the day of
the takedown plus 50 basis points.

Column number:
1.

Date made. Enter the calendar date the funds
reported in column 2 were disbursed, also known as
the effective date of the loan. For example, for funds
disbursed on May 3, enter ‘‘0503.’’
For the purpose of the survey, a loan renewal is
viewed as a new disbursal of funds. Thus, the
effective date of the loan to be entered into column 1
is the date of the renewal.

Report the rate in percent to three decimal places; for
example, for a loan made at 8-1/4 percent, enter
‘‘8.250.’’
4.

Do not report the date the loan was entered onto your
institution’s books or loan record system if that date
differs from the date of disbursement.
2.

Enter
0
1
2
4
12
24
52
360 or 365

Face amount of loan. Enter the face amount of the
loan in dollars even if held at fair value.
If the funds disbursed represent the first advance of a
loan agreement or an addition to an existing loan,
enter only the amount advanced on the date shown in
column 1. A loan advance or takedown refers to the
actual drawing of funds by a borrower under a loan
commitment agreement, not the amount of the facility.

3.

Nominal rate of interest. Enter the stated nominal
rate of interest–not the effective rate or APR—in
effect on the date that the loan was disbursed
(reported in column 1). The stated nominal rate
usually is shown in the note or agreement. If the loan
amount reported in column 2 is an advance, takedown, or renewal under an existing loan commitment, enter the rate of interest for this advance only.

FR 2028A
Line Item Instructions

August 2012

if interest is compounded or paid:
Only at maturity
Annually
Semiannually
Quarterly
Monthly
Semimonthly
Weekly
Daily

For example, if interest is calculated on a simple
basis (with no compounding over the period of
repayment) and is paid monthly, enter ‘‘12’’ for
monthly. Similarly, if interest is calculated on a
simple basis and paid quarterly, enter ‘‘4’’ for quarterly.

If the loan represents a renewal or renegotiation of an
existing loan, enter only the amount renewed or
renegotiated on the date in column 1.
If the loan is a participation or syndication, enter
only your institution’s portion of the loan in this
column.

Frequency with which interest is compounded or
paid. Enter the frequency with which interest is
compounded, or the frequency with which interest is
paid to the lender, whichever is greater.

5.

Prime Rate used as Base pricing rate.
Check ‘‘yes’’ when the loan rate is based on your
institution’s own prime (as reported in the FR 2028S
supplement to this report), any other lender’s prime
rate, a combination of other prime rates, or publicly
reported prime rate.
Check ‘‘no’’ when the loan rate is based on any other
rate (for example, the federal funds rate, the rate on
LI-1

Line Item Instructions

commercial paper, bankers acceptances, or the London Interbank Offered Rate (LIBOR)) or if no base
rate is used to determine the loan rate.
6.

Next date on which the loan rate may be recalculated. Enter the first date in YYYY/MM/DD format
on which the rate on the loan will be recalculated to
reflect changes in the base rate, if any.
For a loan rate that can be recalculated at any time
(as with many prime-based loans), enter the date
made, as reported in column 1.
If the interest rate on the loan is fixed for a period
less than the maturity of the loan (for example, a loan
that matures in 90 days but has a rate that is
recalculated every 30 days relative to the 30-day
LIBOR), enter the date on which the interest rate can
first be recalculated.
If the interest rate is fixed for the life of the loan,
enter the loan’s date of maturity, as reported in
column 7.
If the interest rate is fixed and the loan has no stated
date of maturity, enter ‘‘0.’’

7.

Maturity date. Enter either the date in YYYY/
MM/DD format of maturity or the date of the final
repayment of the loan amount. Enter the year, month,
and day on which the loan matures.
For loans made under a revolving loan facility or
other types of commitments, enter the maturity date
of the takedown disbursed on the date reported in
column 1. Do not report the date of termination of
the commitment.
For renewals, enter the maturity date of the renewal
made on the date reported in column 1, not the
maturity date of the original loan.
If a revolving credit is converted to a term loan
during the survey week, enter the maturity date of
the new term loan.
For loans with no stated maturity, enter ‘‘0’’ in
columns 7 and 9 .

8.

LI-2

Prepayment Penalty. Check ‘‘yes’’ under ‘‘Prepayment penalty’’ when the borrower must pay a penalty
or fee (sometimes called a ‘‘breakage fee’’) in order
to repay or reprice the loan before its scheduled
maturity or the next scheduled date on which the rate
is scheduled to be reset (if any). If no such fee or

penalty applies, check ‘‘no’’ under ‘‘Prepayment
penalty.’’
9.

Number of scheduled repayments over term of
loan. Include the number of scheduled repayments
of principal over the term of the loan. Exclude
interest-only payments.
For loans made under a revolving loan facility, enter
the number of repayments scheduled for the takedown advanced on the date reported in column 1.
Do not include any payments scheduled for the
facility prior to the date reported in column 1.
For loans with a single scheduled repayment of
principal, enter ‘‘1.’’
If repayments are not explicitly scheduled, enter
‘‘0.’’
For loans with no stated maturity, enter ‘‘0’’ in
columns 7 and 9 .

10. Commitment status. Commitments are broadly
defined to include all promises to lend that are
expressly conveyed, orally or in writing, to the
borrower. Commitments generally fall into two types
of arrangements: formal commitments and informal
lines of credit.
A formal commitment is a commitment for which a
bank has charged a fee or other consideration or
otherwise has a legally binding commitment. It is
usually evidenced by a binding contract, to lend a
specified amount, frequently at a predetermined
spread over a specific base rate. It requires that the
borrower meet covenants in the contract and pay a
fee on the unused credit available. These include
revolving credits under which the borrower may
draw and repay loans for the duration of the contract.
A line of credit is defined as an informal arrangement
under which the lender agrees to lend within a set
credit limit and to quote a rate on demand for a
takedown amount and maturity requested by the
borrower. These arrangements may not be legally
binding.
Authorizations or internal guidance lines, where the
customer is not informed of the amount, are not to be
considered as commitments.
If the loan was made under a formal or informal
commitment, enter (rounded to thousands of dollars)
the amount of the total commitment (both used and
Line Item Instructions

FR 2028A
August 2012

Line Item Instructions

unused) under which this loan was made. If the loan
was not made under a formal or informal commitment, enter ‘‘0.’’
If your institution was part of a syndicate making a
larger loan to this borrower or the loan was a
participation, the amount of the commitment reported
in this column should be only the amount that your
institution has agreed to lend.
11. Date of Commitment. If the loan was made under a
formal agreement, please enter the date on which the
pricing terms under which the loan was made
became effective. (Pricing terms would include, for
example, spreads over base rates at which the borrower is able to draw down funds while the commitment remains in effect.) This date commonly would
be the date on which the formal loan commitment
letter was signed or became legally binding. If the
commitment agreement under which the loan was
made is a renewal of an earlier commitment, enter
the renewal date and not the date of the original
commitment. If the loan was made under an informal
commitment or if it was not made under any commitment, enter zero.
12. Syndication or participation status. The terms
‘‘syndication’’ and ‘‘participation’’ encompasses a
variety of arrangements among institutions to make
loans. When each participating lender agrees in
advance to fund and be at risk only up to a specified
percentage of the total credit and the contract is
executed by all participants and the borrower, the
arrangement is often referred to as a syndication.
When a lead lender originates the transaction and is
the only party to the contract with the borrower and
sells shares as prearranged with others, the arrangement is referred to as a participation. If the loan
amount reported represents your institution’s portion
of a participation or syndication, check whether it
was originated by your institution or by other lenders. If the loan does not represent a participation or
syndication with other lenders, check ‘‘Not Syndicated or Participated.’’

Administration (SBA), check ‘‘yes.’’ For all other
loans, check ‘‘no.’’
14. Loan secured. Indicate by checking the appropriate
space whether the loan is secured by collateral of any
kind.
15. Risk rating. If your institution assigns internal risk
ratings to business loans, enter the numerical designation from the list provided below that most closely
matches the definition of the internal rating assigned
to this loan. Do not enter your institution’s own
internal risk rating.
If your institution rates loans, but a particular loan is
unrated, or not yet rated, enter ‘‘0’’ for that loan.
If your institution does not assign internal risk
ratings to business loans, either (a) leave this column
blank or (b) use the categories presented below to
make the assignment.
The definitions provided here take account of both
the characteristics of the borrower and the protections provided in the loan contract. Note that the
definitions are intended to characterize ranges of
risk; hence the definition of your institution’s internal rating for a loan probably will not exactly match
any of the provided definitions. Enter the numerical
designation that corresponds most closely to the
internal rating of your institution.
The risk rating categories provided here are not
intended to establish a supervisory standard for the
maintenance or reporting of internal risk rating systems.
Minimal risk (enter ‘‘1’’). Loans in this category have
virtually no chance of resulting in a loss. They would
have a level of risk similar to a loan with the following
characteristics:
• The customer has been with your institution for many
years and has an excellent credit history.
• The customer’s cash flow is steady and well in excess
of required debt repayments plus other fixed charges.

13. Guaranteed by SBA.1 If the loan was guaranteed,
either in part or in whole, by the Small Business

• The customer has an AA or higher public debt rating.

1. See www.sba.gov/category/navigation-structure/loans-grants/smallbusiness-loans/sbas-role.

• The management is of uniformly high quality and has
unquestioned character.

FR 2028A
Line Item Instructions

August 2012

• The customer has excellent access to alternative sources
of finance at favorable terms.

LI-3

Line Item Instructions

• The collateral, if required, is cash or cash equivalent
and is equal to or exceeds the value of the loan.

likely the recovery of the value of the loan in the event
of default.

• The guarantor, if required, would achieve approximately this rating if borrowing from your institution.

• The guarantor, if required, would achieve approximately this rating if borrowing from your institution.

Low risk (enter ‘‘2’’). Loans in this category are very
unlikely to result in a loss. They would have a level of
risk similar to a loan with the following characteristics:

Acceptable risk (enter ‘‘4’’). Loans in this category
have a limited chance of resulting in a loss. They would
have a level of risk similar to a loan with the following
characteristics:

• The customer has an excellent credit history.
• The customer’s cash flow is steady and comfortably
exceeds required debt repayments plus other fixed
charges.
• The customer has a BBB or higher public debt rating.
• The customer has good access to alternative sources of
finance at favorable terms.
• The management is of high quality and has unquestioned character.
• The collateral, if required, is sufficiently liquid and has
a large enough margin to make very likely the recovery
of the full amount of the loan in the event of default.
• The guarantor, if required, would achieve approximately this rating if borrowing from your institution.
Moderate risk (enter ‘‘3’’). Loans in this category have
little chance of resulting in a loss. This category should
include the average loan, under average economic conditions, at the typical lender. Loans in this category would
have a level of risk similar to a loan with the following
characteristics:
• The customer has a good credit history.
• The customer’s cash flow may be subject to cyclical
conditions, but is adequate to meet required debt
repayments plus other fixed charges even after a limited period of losses or in the event of a somewhat
lower trend in earnings.
• The customer has limited access to the capital markets.
• The customer has some access to alternative sources of
finance at reasonable terms.
• The firm has good management in important positions.
• Collateral, which would usually be required, is sufficiently liquid and has a large enough margin to make

LI-4

• The customer has only a fair credit rating but no recent
credit problems.
• The customer’s cash flow is currently adequate to meet
required debt repayments, but it may not be sufficient
in the event of significant adverse developments.
• The customer does not have access to the capital
markets.
• The customer has some limited access to alternative
sources of finance possibly at unfavorable terms.
• Some management weakness exists.
• Collateral, which would generally be required, is sufficient to make likely the recovery of the value of the
loan in the event of default, but liquidating the collateral may be difficult or expensive.
• The guarantor, if required, would achieve this rating or
lower if borrowing from your institution.
Special mention or classified asset (enter ‘‘5’’).
Loans in this category would generally fall into the
examination categories: ‘‘special mention,’’ ‘‘substandard,’’ ‘‘doubtful,’’ or ‘‘loss.’’ They would primarily be
work-out loans, as it is highly unlikely that new loans
would fall into this category.
16. Location of Borrower. Enter the two character state
abbreviation where the borrower is located. For
a complete list of state abbreviations, please see the
Federal Information Processing Standards Publication
5-2 (FIPS 5-2) at www.itl.nist.gov/fipspubs/fip52.htm.. If the location of the borrower is unknown or
the loan was made under syndication or participation, leave as blank.

Line Item Instructions

FR 2028A
August 2012

Questions and Answers

(4) Should we report business credit card loans?

Survey Scope
(1) The survey covers the first full business weeks of
February, May, August, and November. Do we
report loans made each day?
A. Report loans made only on the days your
Federal Reserve Bank asks you to report. Depending on the size of your institution, your Federal
Reserve Bank may negotiate the number of days on
which loans made should be reported. Once this
determination is made, loans should be reported on
consistent days each quarter.
(2) It is burdensome to eliminate loans of less than
$10,000 from our report. May we include them?
A. Yes, you may include loans of less than $10,000
if it is easier for you to do so.
(3) Under what circumstances is a drawdown under
a line of credit considered a rollover? When
should we report such loans on the FR 2028A?
A. A new drawdown under a line of credit that is
used to pay off a previous drawdown is a rollover
and should be reported on the FR 2028A. For
example, many drawdowns under lines of credit
that are priced off of the 30-day LIBOR have a
maturity of 30 days. Such drawdowns may be
rolled over after 30 days; that is, a new drawdown
is used to pay off the maturing drawdown. In this
case, the new loan should be reported on the FR
2028A. In contrast, many drawdowns priced off of
the prime rate have no stated maturity, and so they
do not need to be rolled over. NOTE: Outstanding
prime-based loans should not be reported when the
prime rate changes. Similarly, term loans that
reprice from time to time (for example, those priced
off of the 30-, 60-, or 90-day LIBOR), are not new
loans, and so such loans should not be reported
when they reprice.
FR 2028A
Questions and Answers

August 2012

A. In principle, single charges of more than $10,000
should be reported since they are included in C&I
loans on the Call Report and the FFIEC 002 and
they exceed the threshold for inclusion on the FR
2028A. Report single charges that exceed $10,000.
Do not report outstanding balances. However, if
virtually all business credit card charges at your
institution are under the $10,000 threshold and it
would be a burden to report the larger ones, you
may exclude them. If you do not know the size of
the charges that make up the balance, you may
exclude them.
(5) Should we report business loans disbursed under
overdraft facilities?
A. On the Call Report, loans resulting from
unplanned overdrafts are excluded from C&I loans
(they are reported in other loans), so they should
not be reported here. However, loans extended
under cash management arrangements that would
be included in C&I loans on the Call Report should
be reported if they exceed the $10,000 threshold for
inclusion on the FR 2028A.
(6) Loans are posted to our computerized record
system with a lag of a few days. Can we report
the loans that are posted to our computerized
record system during the survey week rather
than loans that are disbursed during the survey
week?
A. No. The lag between the date of disbursement
and the date the loan is posted would lead to errors
since some of the reported loans would not have
been extended during the survey week. As a result,
their terms would not necessarily be similar to
those on loans that were extended during the survey
week.
Q&A-1

Questions and Answers

Column 1: Date made
(7) Can we report the date the loan is posted rather
than the date the loan was disbursed?
A. No, because then the Federal Reserve would
compare the rates charged on the loans to market
rates on the days the loans were posted rather than
the days the loans were disbursed. Because market
rates can move significantly from day to day, this
reporting error could lead to errors in the measurement of loan spreads. In addition, for loans with
short maturities, this type of misreporting can lead
to loans having reported dates of maturity before
the reported date that they were made.
Column 3: Nominal rate of interest
(8) Our institution calculates an effective loan rate
for internal purposes. Should we simply report
that rate?
A. No, report the stated nominal rate on the loan.
The Federal Reserve will calculate effective rates
on a consistent basis for all respondents based on
the nominal rate and compounding frequency
reported on the FR 2028A. Column 4: Frequency
with which interest is compounded or paid
(9) At our institution interest is sometimes calculated and accrued in an interest receivables
account more frequently than the balance of
that account is paid off by the borrower. Should
the frequency of compounding be reported as
the frequency with which interest is accrued in
the interest receivables account or the frequency
with which the borrower pays the accrued interest?
A. In this case the frequency to report depends on
whether interest is charged on the account balance
in the interest receivables account. If interest is
charged on the account balance, then you should
report the frequency with which interest is accrued
in the receivables account. If interest is not charged
on the account balance, then report the frequency
with which the borrower pays the accrued interest.
Column 5: Prime Rate used as Base pricing rate
(10) Our institution prices some loans off of our own
prime and other loans off another prime rate
Q&A-2

reported in the financial press. Should both
types of loan be reported based on the prime
rate?
A. Yes, report both types of loans based on the
prime rate.
(11) Should a loan be reported as being prime based
if the loan rate is based on a formula that
incorporates more than one base rate including
the prime rate? (For example, a loan rate that
can be priced off of either the prime rate or the
fed funds rate, depending on the level of the two
rates.)
A. In this case, the base rate should not be reported
as prime. This situation should not be confused
with loans that allow the borrower to choose from a
menu of base rates and spreads. In that case, check
‘‘yes’’ if the base rate chosen by the customer for
the particular loan being reported is the prime rate
and check ‘‘no’’ if the base rate is other than the
prime rate.
Column 6: Next date on which the loan rate may be
Recalculated
(12) Rates on some loans at our institution adjust in
ways not covered in the instructions. For example, the rates on some loans are tied to the prime
rate as of the first day of each month. How
should we report the next date on which the loan
rate may be recalculated in this case?
A. Generally, report the first date on which the rate
to be charged is subject to change. In the example,
this date would be the first of the next month after
the loan was made.
Column 8: Prepayment Penalty
(13) At our institution, fixed-rate loans can be prepaid at the borrower’s discretion, but the borrower has to make up the difference between the
interest that would have been paid on the loan
over its remaining term and the interest that our
institution can earn over the same period by
investing the amount of the prepayment. Does
this arrangement constitute a prepayment fee?
A. Yes, such a loan should be reported as having a
prepayment fee.
Questions and Answers

FR 2028A
August 2012

Questions and Answers

Column 10: Commitment status
(14) Sometimes our institution makes loans as part of
a participation, and we do not know the commitment status or amount. In such cases, what
amount should we report as the amount of the
commitment?
A. In this case, enter ‘‘0’’ as the amount of commitment.
Column 11: Date Commitment Extended
(15) If the commitment was first arranged as an
informal line of credit and later formalized,
which date should be reported?
A. Report the date on which the commitment was
formalized.
(16) If the commitment has been renewed since it was
first agreed upon, should the date the pricing
terms were set be the date of the original terms
or the date of the most recent renewal?
A. The date reported should be for the most recent
renewal of the commitment.
(17) If there is a difference between the date the
commitment was formally agreed upon and the
date that the commitment became effective,
which date should be given?
A. Report the date on which the pricing terms
contained in the commitment were set.
Column 14: Loan secured
(18) On small business loans our institution often
requires the principals of the business borrowing the money to provide personal guarantees
for repayment. Should these loans be classified
as secured?
A. No, the loan should be classified as secured only
if it is backed by specific assets.
(19) Our institution does not consider a loan to be
collateralized if the collateral is very small relative to the size of the loan, or if we believe that
the collateral is unlikely to be collected in the
event of default. Should such loans be classified
as secured when reported on the FR 2028A?
FR 2028A
Questions and Answers

August 2012

A. No, you may use your institution’s definition of
whether or not a loan is collateralized.
Column 15: Risk rating
(20) Our institution does not rate loans. Should we
nevertheless report risk ratings based on the
definitions provided in the instructions?
A. If your institution does not find it excessively
burdensome, such ratings would be valued by the
Federal Reserve. However, respondents that do not
have internal ratings need not provide risk ratings
on the FR 2028A.
(21) Our institutions’ internal rating system does not
match the ratings provided in the instructions.
Can we report our institutions’ internal ratings?
A. No. Please use the definitions provided in the
instructions. The reported ratings have to be based
on a common set of definitions so that the Federal
Reserve can understand the meaning of the ratings
assigned, calculate average ratings across institutions, and make comparisons of ratings over time.
(22) The definition of our institution’s internal ratings do not line up with the definitions provided
in the instructions. How should we translate the
ratings?
A. It is inevitable that there be some slippage
between the internal ratings of individual lenders
and the common definitions used on the FR 2028A.
For each internal rating at your institution, report
on the FR 2028A the rating provided in the instructions with the definition that matches most closely.
(23) Our institution reports hundreds of loans each
quarter. How can we take the time to judge the
riskiness of each of them when preparing our
report?
A. It should not be necessary to exercise any
judgment when preparing the report. An employee
of your institution familiar with your internal riskrating system should prepare a correspondence, or
mapping, from your internal risk ratings to the
ratings defined in the instructions. With that correspondence, you can convert the internal ratings into
the common ratings without any additional judgment. Of course, if your institution changes the
Q&A-3

Questions and Answers

definitions of its internal risk ratings, the correspondence will have to be adjusted. Please check before
each survey week to see if the definitions of your
internal ratings have changed. A worksheet is provided for your institution’s use in mapping your
internal risk ratings to the ratings defined for the FR
2028A.
(24) Our institution does not rate loans until after
they have been made, hence we cannot include
this information on the FR 2028A. How should
we report risk ratings?
A. If your institution does not have loan risk ratings
available at the time of the survey, then it should
follow the instructions for institutions that do not
rate loans (see the survey instructions and question
20).
(25) The risk ratings on our loans change over time,
reflecting changes in customers’ balance sheets
and business prospects. Do we need to provide
updates?
A. The survey only collects information on ratings
when loans are disbursed. Do not provide updated
information on loan risk ratings unless the original
data reported were in error.
(26) Our institution’s ratings are limited to pass or
not pass. How should we map these ratings into
the common ratings?
A. In this case, follow the instructions for institutions that do not rate loans (see the survey instructions and question 20).

Q&A-4

(27) How should we rate a loan that is quite risky in
terms of the probability of default, but has
excellent collateral?
A. The risk rating reported on the FR 2028A should
take into account all protections provided in the
loan contract. In this case, the loan should be
reported as not very risky because the excellent
collateral makes it very unlikely that your institution will sustain a loss.
(28) Our institution’s internal risk ratings are for
borrowers rather than for loans, and so do not
take into account the protections provided by
the loan contract. Should we still try to report
loan risk ratings?
A. Yes. Since the rating of the customer will
generally have a significant effect on the rating of
the loan, please report the loan risk rating that most
closely corresponds to your institution’s internal
rating of the borrower. Although this information
may not be as precise as it is for institutions that
rate loans, it is preferable to having no information
at all.
(29) Our institution occasionally makes loans that
have more than one risk rating, for example a
better rating for that part of the loan that is
secured. How should we report the rating on
such a loan?
A. In this case, choose the rating that applies to the
largest part of the loan. If the ratings are split
evenly, choose the highest-risk rating.

Questions and Answers

FR 2028A
August 2012

Risk Rating Worksheet

Risk Rating Worksheet
This worksheet is for a respondent’s internal use in mapping its own internal risk ratings to the ratings defined for the
FR 2028A. It should be revised if the institution changes its risk ratings. This worksheet should not be submitted to the
Federal Reserve Bank.
Respondent Rating(s)

Equivalent FR 2028A Rating1
1 Minimal Risk - Loans in this category have virtually no
change of resulting in a loss.
2 Low risk - Loans in this category are very unlikely to
result in a loss.
3 Moderate risk - Loans in this category have little
chance of resulting in a loss. This category should include
the average loan, under average economic conditions, at
the typical lender.
4 Acceptable risk - Loans in this category have a limited
chance of resulting in a loss.
5 Special mention or classified asset - Loans in this category would generally fall into the examination categories:
‘‘special mention,’’ ‘‘substandard,’’ ‘‘doubtful,’’ or ‘‘loss.’’
They would primarily be work-out loans, as it is highly
unlikely that new loans would fall into this category.

1. The complete definitions of the rating categories are provided in the instructions.
FR 2028A
Risk Rating Worksheet

August 2012

RRW-1