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    US Agencies Revise FFIEC 101 and Call Reports for COVID Data Reporting

    June 12, 2020

    US Agencies (FDIC, FED, and OCC) have requested and received emergency approval from the U.S. Office of Management and Budget for certain revisions to the three versions of the call reports (FFIEC 031, FFIEC 041, and FFIEC 051) and the regulatory capital reporting for institutions subject to the advanced capital adequacy framework (FFIEC 101), effective as of the June 30, 2020 report date. FDIC has published supplemental instructions for reporting in accordance with these revisions in the call reports and the FFIEC 101 as of the June 30, 2020 report date. The redlined report form pages for call report revisions effective as of the June 30, 2020 report date are available on the FFIEC Reporting Forms webpages. The agencies will request public comment on these reporting changes through the standard Paperwork Reduction Act process at a later date.

    The revisions resulted from several interim final rules and a notice of proposed rulemaking issued by one or all of the agencies in response to the impact on the economy as a result of COVID-19. These revisions also resulted from certain provisions of the 2020 Coronavirus Aid, Relief, and Economic Security Act (CARES Act). The interim final rules and a notice of proposed rulemaking were published in the Federal Register from March through June 2020. The revisions include:

    • The revisions impacting the FFIEC 101 include updates to the calculation of certain amounts reported on Schedule A, Advanced Approaches Regulatory Capital, l, including the Supplementary Leverage Ratio Tables
    • Updates to the instructions for the calculation of certain amounts reported on Schedule RC-R, Regulatory Capital, that apply to the three versions of the call report
    • Revisions to the definitions of certain deposits reported on call report Schedule RC-E, Deposit Liabilities, in response to an interim final rule that amends Regulation D of FED
    • Changes to the reporting on extensions of credit to insiders on call report Schedule RC-M, Memoranda, in response to an interim final rule that excepts certain loans guaranteed under the Small Business Administration’s Paycheck Protection Program (PPP) from the requirements of section 22(h) of the Federal Reserve Act and the corresponding provisions of the Regulation O of FED

    Additionally, the call report revisions include the addition of new items on Schedule RC-C, Part I, Loans and Leases, and Schedule RC-M, Memoranda, to collect data on:

    • Eligible loan modifications under Section 4013, Temporary Relief from Troubled Debt Restructurings, of the CARES Act, with these items collected on a confidential basis
    • U.S. Small Business Administration PPP loans and borrowings under the Federal Reserve PPP Liquidity Facility or PPPLF
    • Holdings of assets purchased under the Money Market Mutual Fund Liquidity Facility or MMLF

     

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    Keywords: Americas, US, Banking, COVID-19, Call Report, FFIEC 101, Reporting, Paycheck Protection Program, MMLF, CARES Act, Supplemental Instructions, Supplementary Leverage Ratio, Regulatory Capital, Basel, US Agencies

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