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    US Agencies Propose to Revise and Extend Call Reports for Banks

    December 22, 2020

    FED updated the reporting form (FR VV-1) and instructions (including supplemental instructions) for Quantitative Measurements under Regulation VV, also known as the Volcker Rule. In addition, US Agencies (FDIC, FEC, and OCC) published two proposals to revise and extend the Consolidated Reports of Condition and Income or call reports (FFIEC 031, FFIEC 041, and FFIEC 051). One of the proposals involves changes to the call report forms and instructions for FFIEC 031 and FFIEC 041, to implement proposed amendments to the deposit insurance assessment system. Comments on this proposal must be submitted on or before February 16, 2021. In the other proposal, the agencies are consulting on an adjustment to the measurement date for certain total asset thresholds that trigger additional reporting requirements in the call reports only due to institutional asset growth in 2020 due to participation in COVID-19 response programs. Comments on this second proposal must be submitted on or before January 29, 2021.

    With respect to the proposal to implement amendments to the deposit insurance assessment system, the agencies are requesting comment on revisions to the reports and instructions for FFIEC 031 and FFIEC 041, to implement the proposed amendments of FDIC to the deposit insurance assessment system; these amendments are applicable to all large insured depository institutions, including highly complex insured depository institutions, to address the temporary deposit insurance assessment effects resulting from certain optional regulatory capital transition provisions related to the implementation of the current expected credit losses (CECL) methodology. These amendments to the call reports would enable FDIC to remove the double-counting of a specified portion of the CECL transitional amount or the modified CECL transitional amount, as applicable, in certain financial measures that are calculated using the sum of Tier 1 capital and reserves and that are used to determine assessment rates for large and highly complex insured depository institutions. 

    The proposal to adjust measurement date for certain asset thresholds addresses certain reporting requirements that are triggered as a result of the participation in COVID-19 response programs. The call report contains various total asset thresholds that are measured annually as of the June 30 report date and trigger additional reporting requirements once crossed, generally starting with the call reports for the first calendar quarter of the next calendar year. The agencies are focused on the total asset thresholds set at USD 10 billion or less, as these thresholds could impact a significant number of smaller community institutions. Many community institutions may have unexpectedly crossed these total asset thresholds during 2020 due to participation in Coronavirus Aid, Relief, and Economic Security (CARES) Act relief programs, which would otherwise trigger additional reporting obligations starting in calendar year 2021. The agencies expect that some of these institutions may fall below the relevant total asset threshold as of June 30, 2021. The agencies do not want to create a short-term increase in burden on these community institutions to comply with the additional reporting for a single year. For community institutions that remain above a total asset threshold as of the June 30, 2021 (which is the measurement date), the agencies grant one-year reporting relief while providing additional time to comply with any additional reporting requirements starting in 2022 rather than 2021.

     

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    Comment Due Date: February 16, 2021/January 29, 2021

    Keywords: Americas, US, Banking, COVID-19, Reporting, CARES Act, Basel, CECL, FR VV-1, Volcker Rule, Call Reports, US Agencies

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