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    US Agencies Propose Revisions to FFIEC Reports 031, 041, 051, and 101

    February 21, 2019

    US Agencies (FDIC, FED, and OCC) propose to extend for three years, with revision, consolidated reports of condition and income for banks with domestic and foreign offices (FFIEC 031), the consolidated reports of condition and income for banks with domestic offices only (FFIEC 041), and the consolidated reports of condition and income for banks with domestic offices only and total assets less than USD 1 billion (FFIEC 051). US Agencies also propose to extend for three years, with revision, the form on Regulatory Capital Reporting for Institutions Subject to the Advanced Capital Adequacy Framework (FFIEC 101). Comments must be submitted on or before March 18, 2019. Also published were the OMB supporting statements for call reports (FFIEC 031, 041, and 051) and FFIEC 101 report.

    In response to the new credit losses standard, US Agencies reviewed the existing FFIEC reports to determine which reports may be affected by FASB's Accounting Standards Update (ASU) No. 2016-13, “Financial Instruments—Credit Losses (Topic 326): Measurement of Credit Losses on Financial Instruments." As a result, on September 28, 2018, US Agencies had requested comment for 60 days on a proposal to revise and extend the FFIEC reports—Call Reports (FFIEC 031, FFIEC 041, and FFIEC 051) and FFIEC 101. The agencies also reviewed the existing FFIEC reports to determine which reports may be affected by Economic Growth, Regulatory Relief, and Consumer Protection (EGRRCP) Act. As a result, additional revisions were proposed for the Call Reports and FFIEC 101. The comment period for the September 2018 notice ended on November 27, 2018. The agencies received comments on the proposals covered in the notice from two entities, a bankers' association and a bank. The commenters recommended clarifications to the language used in the notice and associated reporting instructions as well as "clarifying edits" to the proposed revised reporting forms.

    In addition, in December 2018, the agencies approved a final rule amending their capital rule to address current expected credit losses methodology (CECL). The final rule included revised terminology for the allowance balance eligible for inclusion in regulatory capital. The agencies plan to make a conforming terminology revision for the reporting of regulatory capital on Schedule RC-R. After considering these comments, the agencies will proceed with the revisions proposed in the September 2018 notice to the Call Reports and FFIEC 101, as originally proposed, with some modification to FFIEC 031 and FFIEC 041. The agencies will incorporate appropriate clarifying edits suggested by commenters in the updated instruction books and report forms. The agencies are now submitting requests to OMB for review and approval of the extension, with revisions, of the FFIEC reports—Call Reports and FFIEC 101, among others.

     

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    Comment Due Date: March 18, 2019

    Keywords: Americas, US, Banking, Reporting, FFIEC 031, FFIEC 041, FFIEC 051, Call Reports, FFIEC 101, CECL, EGRRCP Act, IFRS 9, US Agencies

     

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