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    US Agencies Propose to Amend Call Reports, FFIEC 002, and FFIEC 002S

    February 05, 2021

    US Agencies (FDIC, FED, and OCC) proposed revision and three-year extension of the forms and instructions for the Call Reports FFIEC 031, FFIEC 041, and FFIEC 051. Revision and three-year extension is also being proposed for form FFIEC 002, which is the report on assets and liabilities of U.S. branches and agencies of foreign banks, and form FFIEC 002S, which is the report on assets and liabilities of a non-U.S. branch that is managed or controlled by a U.S. branch or agency of a foreign bank. The comment period on the proposed notice ends on April 06, 2021, while changes to the Call Reports and the FFIEC 002 reports are proposed to take effect as of the June 30, 2021 report date.

    The US Agencies are now requesting comment on revisions to the reporting forms and instructions for the Call Reports and the FFIEC 002 related to the exclusion of sweep deposits and certain other deposits from reporting as brokered deposits. The proposed changes were indicated by the US Agencies in the October 2020 final rule on Net Stable Funding Ratio (NSFR) final rule and by the FDIC in the December 2020 final rule on brokered deposits and interest rate restrictions, respectively. In addition, the US Agencies are proposing revisions to the Call Report and FFIEC 002 instructions addressing brokered deposits to align them with the final rule on brokered deposits and interest rate restrictions. Under the final rules on NSFR and the brokered deposits, the US Agencies had stated their intent to update the Call Report to obtain data that will assist in better evaluations of funding stability for sweep deposits over time to determine their appropriate treatment under applicable liquidity regulations. The intended update would also help to assess the risk factors associated with sweep deposits for determining their deposit insurance assessment implications, if any, as stated by the US Agencies. 

    In line with this announced intent, the US Agencies are now proposing to add new data items applicable to all institutions that file the Call Report and all insured institutions that file the FFIEC 002. Specifically, five data items would be added to Schedule RC-E, Deposit Liabilities, on all three versions of the Call Report (FFIEC 031, FFIEC 041, and FFIEC 051) and would be applicable to insured depository institutions of all sizes. These five data items would be collected quarterly on the FFIEC 031 and 041 Call Reports and semiannually on the FFIEC 051 Call Report. In addition, four data items would be added to Schedule RC-E, Deposit Liabilities on the FFIEC 031 Call Report only and would be completed quarterly only by institutions with USD 100 billion or more in total assets. On the FFIEC 002, the five data items would be added to Schedule O, Other Data for Deposit Insurance Assessments, as Memorandum items 8.a through 8.d and 9, and would be reported quarterly by the insured U.S. branches of foreign banks of all sizes.

     

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    Comment Due Date: April 06, 2021

    Keywords: Americas, US, Banking, COVID-19, Paycheck Protection Program, Small Business Administration, Credit Risk, Loan Guarantee, Regulatory Capital, Basel, FED

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