After considering comments received on the November 2020 proposal, US Agencies (FDIC, FED and OCC) are proceeding with the proposed revisions to the reporting forms and instructions for Call Reports FFIEC 031, FFIEC 041, and FFIEC 051. The proposed revisions address measurement dates of total asset thresholds associated with the reporting of certain data in the Call Reports. These reporting changes are subject to approval by the U.S. Office of Management and Budget (OMB). Thus, the agencies are now giving notice of their plan to submit to OMB a request to approve the revision and extension of these information collections and again invite comment on the renewal. Comments must be submitted by March 22, 2021.
These changes to the Call Reports pertain to the interim final rule of the banking agencies, which was published on December 02, 2020. This rule provides relief to financial institutions with less than USD 10 billion in total assets as of December 31, 2019, by allowing them to calculate their asset size for applicable thresholds in certain rules during calendar years 2020 and 2021 based on the lower of total assets as of December 31, 2019, or as of the normal measurement date. Consistent with this interim final rule, the agencies are permitting an institution to use the lesser of the total consolidated assets reported in its Call Report as of December 31, 2019, or June 30, 2020, when determining whether the institution has crossed certain total asset thresholds to report additional data items in its Call Reports for report dates in calendar year 2021. These thresholds include the USD 5 billion threshold for limiting eligibility to use the FFIEC 051 version of the Call Report and the USD 100 million, USD 300 million, USD 1 billion, and USD 10 billion thresholds for reporting certain additional data items in the Call Reports. The agencies are allowing this relief for calendar year 2021 only.
In addition, the interim final rule allows institutions that temporarily exceed the USD 10 billion total asset threshold to use the community bank leverage ratio framework in Call Report Schedule RC-R from December 31, 2020, through December 31, 2021, provided they meet the other qualifying criteria for this framework. For report dates after the effective date of the agencies' asset thresholds rule through December 31, 2021, institutions that elect to use the community bank leverage ratio framework would report community bank leverage ratio information in Call Report Schedule RC-R, Part I, as reflected in the Call Report instruction book, except that item 32 (Total assets) on that schedule should reflect the lesser of the institution's total assets as of December 31, 2019, or as of the current quarter-end report date and other qualifying criteria reported on that schedule based on percentages of total assets should use the total assets as of the current quarter-end report date. The changes to the forms can be reviewed via the redlined copies of the FFIEC 031, FFIEC 041, and FFIEC 051 Call Report forms that are available on the FFIEC webpage for each report. These redlined copies indicate the affected footnotes and draft Supplemental Instructions providing guidance on the temporary adjustment to the measurement date for certain total asset thresholds.
- FDIC Notification
- Federal Register Notice
- Interim Final Rule, December 2020
- FFIEC Forms and Instructions
- Presentation on Proposed Revisions (PDF)
Comment Due Date: March 22, 2021
Keywords: Americas, US, Banking, Reporting, Call Reports, FFIEC 031/041/051, CBLR Framework, Regulatory Capital, FFIEC 051, Basel, COVID-19, US Agencies
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