FDIC published the financial institution letters (FIL-21-2019 and FIL-22-2019) that offer guidance on submission of Call Reports FFIEC 051, FFIEC 041, and FFIEC 031 for the first quarter of 2019. Reporting under these Call Reports comes under the purview of the three US Agencies: FDIC, FED, and OCC. The letter states that the Call Report for the March 31, 2019 report date must be submitted to the Central Data Repository (CDR) of the US Agencies by April 30, 2019. Certain institutions with foreign offices have five additional calendar days to file their reports. Additionally, supplemental instructions for March 2019 have been released for guidance on reporting issues.

Eligible small institutions, generally those with domestic offices only and total assets less than USD 1 billion as of June 30, 2018, have the option to file the FFIEC 051 or the FFIEC 041 Call Report as of the March 31, 2019 report date. Such institutions are expected to file the same report form, either the FFIEC 051 or the FFIEC 041, for each quarterly report date during 2019. The US Agencies are revising several Call Report schedules this quarter, in response to the new accounting standard on credit losses. The changes to the Call Report also implement the agencies' recent revisions to the regulatory capital rules, which include a regulatory capital transition for the effects of the initial adoption of the current expected credit losses (CECL) methodology in ASU 2016-13, which is the Accounting Standards Update issued by FASB to implement the IFRS 9 equivalent regime in United States. Since ASU 2016-13 has different effective dates for different institutions and permits early adoption in 2019, the changes to the Call Report related to credit losses will be phased in between March 31, 2019 and December 31, 2022. 

Furthermore, the US Agencies continue to consider the comments received on a proposal to reduce reporting for certain institutions with less than USD 5 billion in total assets in the Call Report (in FIL 74-2018, dated November 19, 2018). The proposal includes revisions to the FFIEC 051 reporting requirements that, if finalized, would take effect no earlier than September 30, 2019.

 

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Keywords: Americas, US, Banking, Call Reports, FFIEC 031, FFIEC 041, FFIEC 051, Reporting, Supplemental Instructions, CECL, IFRS 9, US Agencies

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