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    US Agencies Propose to Revise Call Reports, FFIEC 101, and FFIEC 002

    July 22, 2020

    US Agencies (FDIC, FED, and OCC) are requesting comment on revisions to the Call Reports (FFIEC 031, FFIEC 041, and FFIEC 051), the regulatory capital report for institutions subject to the advanced capital adequacy framework (FFIEC 101), and the report of assets and liabilities of U.S. branches and agencies of foreign banks (FFIEC 002). FFIEC has approved the proposal to revise and extend these reports. Draft reporting forms and instructions for Call Reports, FFIEC 101, and FFIEC 002 are available on the FFIEC website. Comments must be submitted by September 21, 2020.

    The proposed revisions relate to:

    • The interim final rules and final rule that revise the agencies' capital rule and have been issued in response to the COVID-19 disruptions, the FED regulations on reserve requirements and insider loans, and the FDIC assessments regulations
    • Certain sections of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) for which the agencies received emergency approvals from OMB
    • Changes to Call Reports and FFIEC 002 report in context of the U.S. generally accepted accounting principles (GAAP)
    • Call Report changes to reflect the expiration of the temporary exception for estimated disclosures on international remittance transfers and certain amendments to the Remittance Rule (recently finalized by CFPB)

    From March through June 2020, in response to the impact of COVID-19 pandemic, the agencies published interim final rules to make certain changes to their regulatory capital and liquidity rules. The agencies requested and received emergency approvals on April 03, 2020, from OMB to implement revisions to Call Reports, FFIEC 101, and FFIEC 002. The agencies are requesting comments on whether there should be any further changes to the items or instructions to implement the revisions for which emergency approvals were received from OMB. In regard to the Regulation D amendments, agencies are requesting comment on whether to adopt proposed revisions to the Call Reports and the FFIEC 002 to remove a reporting option that was implemented by the emergency approvals and could result in the collection of ambiguous data. The agencies have also requested comment in connection with each of the interim final rules described in the Federal Register Notice

    The revisions associated with the interim final rules, the proposed and final deposit insurance assessments rule, and the CARES Act provisions have been approved by OMB through the emergency clearance process and these revisions have taken effect for the March 31, 2020 Call Reports and FFIEC 101; for the June 30, 2020 Call Reports, FFIEC 101, and FFIEC 002; or the September 30, 2020 FFIEC 002. For additional proposed revisions to Call Reports and FFIEC 002 instructions that are related to the amendment of Regulation D, the agencies propose to make these revisions effective for reporting beginning in the first quarter of 2021. For changes related to US GAAP, the agencies are proposing to make the revisions effective as of the March 31, 2021 report date, except for the revisions for last-of-layer hedging, which would be implemented following the FASB adoption of a final last-of-layer hedge accounting standard. A final standard is not expected to be issued before the second half of 2021. The agencies are also proposing to make revisions to Schedule RC-M for the international remittance transfer items, effective March 31, 2021.

     

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    Comment Due Date: September 21, 2020

    Keywords: Americas, US, Banking, COVID-19, Call Report, FFIEC 101, FFIEC 002, Reporting, CARES Act, Regulatory Capital, Basel, US GAAP, US Agencies

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