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    US Agencies Propose Changes to Call Reports and Instructions

    July 22, 2021

    Certain regulatory authorities in the US are extending period for completion of the review of certain residential mortgage provisions and for publication of notice disclosing the determination of this review until December 20, 2021. The published Federal Register notice refers to the definition of qualified residential mortgage, the community-focused residential mortgage exemption, and the exemption for qualifying three-to-four unit residential mortgage loans, in each case as set forth in the Credit Risk Retention Regulations adopted by the agencies. The relevant US authorities are the Board of Governors of the Federal Reserve System (FED), the Federal Deposit Insurance Corporation (FDIC), the Office of the Comptroller of the Currency (OCC), the Federal Housing Finance Agency (FHFA), and the United States Department of Housing and Urban Development (HUD). Additionally, FDIC, FED, and OCC, in short the US Agencies, proposed to revise and extend for three years the Call Reports FFIEC 031, FFIEC 041, and FFIEC 051 and the associated instructions, with the comment period on this proposal ending on September 20, 2021.

    The US Agencies are requesting comment on proposals to add, to the Call Reports, a new item related to the final rule on the standardized approach for counterparty credit risk (SA-CCR) and to clarify instructions for reporting of deferred tax assets: 

    • The agencies are proposing to revise Schedule RC-R, Part I, Regulatory Capital Components and Ratios, on all versions of the Call Report by adding a new line item 31.b, “Standardized Approach for Counterparty Credit Risk opt-in election.” This new item would be intended to identify institutions that have chosen to early adopt or voluntarily elect SA-CCR. Due to the inherent complexity of adopting SA-CCR, this identification is important for non-advanced approaches institutions that choose to voluntarily adopt SA-CCR. A non-advanced approaches institution that adopts SA-CCR would enter “1” for “Yes” in line item 31.b. All other non-advanced approaches institutions would leave this item blank. An advanced approaches institution that elects to early adopt SA-CCR prior to the January 01, 2022 mandatory compliance date would enter “1” for “Yes” in line item 31.b. After January 01, 2022, an advanced approaches institution would leave this item blank. This proposed reporting change would take effect starting with the December 31, 2021 Call Report. This item would no longer be applicable to advanced approaches institutions starting with the March 31, 2022 report date.
    • FED, FDIC, and OCC had published a proposed rule on Tax Allocation Agreements (Tax NPR) on May 10, 2021. Consistent with the proposed requirements and discussion in the Tax NPR, the agencies propose to revise the Call Report instructions to clarify the Glossary entry for “Income Taxes” to address treatment of temporary difference deferred tax items and operating loss and tax credit carryforward deferred tax assets.

     

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    Comment Due Date: September 20, 2021

    Keywords: Americas, US, Banking, Call Reports, FFIEC 031, FFIEC 041, FFIEC 051, SA-CCR, Credit Risk, Credit Risk Retention, RRE, Mortgage Lending, Reporting, US Agencies

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