US Agencies Propose Revisions to Call Reports and FFIEC 101 Report
US Agencies (FDIC, FED, and OCC) proposed to revise and extend, for three years, the FFIEC 101 report and the call reports (FFIEC 031, FFIEC 041, and FFEIC 051). On October 04, 2019, the agencies had proposed revisions to the Call Reports and the FFIEC 101 that would implement various changes to the agencies' regulatory capital rule that, as of that date, the agencies had finalized or were considering finalizing. After considering the comments received on the proposal, the agencies are proceeding with the proposed revisions to the reporting forms and instructions for the Call Reports and the FFIEC 101 (except for the reporting changes arising from the proposed total loss-absorbing capacity, or TLAC, holdings rule, which has not yet been finalized), but with certain modifications. In addition, the agencies are giving notice that they are sending the collections to OMB for review. Comments must be submitted by February 26, 2020.
The October 2019 notice had included proposed revisions to these reporting forms and instructions, for implementing various changes to the regulatory capital rule of the US Agencies; the changes to the regulatory capital rule involve the capital simplifications rule, the community bank leverage ratio (CBLR) rule, the proposed tailoring rule, the proposed TLAC holdings rule, the proposed rule for supplementary leverage ratio revisions for certain central bank deposits of custodial banks, the proposed rule for the standardized approach for counterparty credit risk (SA-CCR) on derivative contracts, and the high volatility commercial real estate (HVCRE) land development proposal. The comment period for the October 2019 notice ended on December 03, 2019. The agencies received comments on the proposed reporting changes covered in the notice from four entities: three bankers' associations and one savings association.
Except for the proposed TLAC holdings rule, the final rules have now been adopted for all of the regulatory capital rulemakings addressed in the October 2019 notice. The key modifications relate to the disclosure of an institution's election of the community bank leverage ratio framework, a change in the scope of the FFIEC 031 Call Report, and the reporting of home equity lines of credit that convert from revolving to non-revolving status. The reporting revisions that implement various changes to the agencies' capital rule would take effect in the same quarters as the effective dates of the capital rule changes, that is, primarily as of the March 31 and June 30, 2020 report dates. The Call Report revisions applicable to operating lease liabilities and home equity lines of credit would take effect in the first quarters of 2020 and 2021, respectively.
Since the proposed TLAC holdings rule has not been finalized, the agencies are not proceeding with the implementation of the TLAC-related reporting changes proposed in the October 2019 notice. Once the proposed TLAC holdings rule is finalized, the agencies plan to issue a thirty-day Federal Register notice to implement the associated reporting changes, which would address any comments received on the proposed changes.
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Comment Due Date: February 26, 2020
Keywords: Americas, US, Banking, Reporting, FFIEC 031, FFIEC 041, FFIEC 051, Call Reports, FFIEC 101, CBLR Framework, TLAC, Regulatory Capital, Basel III, US Agencies
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