November 19, 2018

US Agencies (FDIC, FED, and OCC) are proposing reduced reporting for eligible small insured depository institutions and for certain uninsured institutions that they supervise with less than USD 5 billion in total consolidated assets that otherwise meet the same criteria. The proposed rule would expand the number of institutions that may file the FFIEC 051 Call Report, which is the most streamlined version of the Call Report, and would provide for reduced reporting in the FFIEC 051 Call Report. The changes to the FFIEC 051 reporting requirements are proposed to take effect from March 31, 2019. Comment period on this consultation closes on January 18, 2019.

This Federal Register notice—which implements Section 205 of the Economic Growth, Regulatory Relief, and Consumer Protection (EGRRCP) Act—also includes a Paperwork Reduction Act notice to reduce the amount of data required to be reported on the FFIEC 051 Call Report for the first and third calendar quarters. In addition, the agencies are proposing to reduce the reporting frequency for a number of existing data items in the FFIEC 051 Call Report that are currently reported quarterly, which would further streamline the report in the first and third quarters. For covered depository institutions, the principal areas of reduced reporting in the first and third calendar quarters generally would include data items related to categories of risk-weighting of various types of assets and other exposures under the agencies' regulatory capital rules, fiduciary and related services assets and income, and troubled debt restructurings by loan category. For institutions with total assets of USD 1 billion or more, the agencies also are proposing to add to the FFIEC 051 Call Report certain data items that these institutions currently report in the FFIEC 041 Call Report, but generally with reduced reporting frequency. 

To be eligible to file the FFIEC 051 Call Report with its reduced reporting, an institution must meet the definition of a "covered depository institution."  In general, the proposal would define a "covered depository institution" as an institution with less than USD 5 billion in total assets (an increase from the current asset-size eligibility criterion for filing the FFIEC 051 Call Report of less than USD 1 billion) that meets all of the following non-asset-size criteria:

  • Has no foreign office
  • Is not an advanced approaches institution for regulatory capital purposes
  • Is not treated as a large or highly complex institution for deposit insurance assessment purposes
  • Is not subject to the filing requirements for the FFIEC 002 report of condition

Under the proposal, a covered depository institution would not be required to file the FFIEC 051 Call Report and would have the option to continue filing the FFIEC 041 Call Report. As proposed, an institution would determine whether it meets the less than USD 5 billion asset-size eligibility criterion for a particular calendar year based on the total assets reported on the balance sheet of its report of condition (Schedule RC, item 12, in the Call Report) for June 30 of the previous calendar year. This approach is consistent with the current Call Report instructions for determining eligibility to file the FFIEC 051 Call Report based on asset size. An institution with less than USD 5 billion in total assets that is eligible to use the FFIEC 051 Call Report under the proposal and would like to begin using this report form as of the proposed March 31, 2019, effective date, may find that it is unable to do so for that report date. In this situation, the institution may begin reporting on the FFIEC 051 Call Report as of the June 30, 2019 report date or in a subsequent calendar quarter of 2019 if it remains a covered depository institution.

 

Related Links

Comment Due Date: January 18, 2018

Keywords: Americas, US, Banking, Reporting, FFIEC 051, Call Reports, Covered Depository Institutions, EGRRCP Act, FFIEC 041, Proportionality, US Agencies

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