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

The US Agencies had published a notice on the proposal to revise and extend the Call Reports, FFIEC 101, and FFIEC 002S on July 22, 2020. Additionally, on October 04, 2019, the agencies proposed call report and FFIEC 101 revisions to implement the agencies' proposed total loss absorbing capacity (TLAC) investments rule for advanced approaches banking organizations. The comment period for the July 2020 notice ended on September 21, 2020 while the comment period for the October 2019 notice ended on December 03, 2019, with the agencies subsequently adopting a TLAC investments final rule. After considering the comments received on these notices, the agencies are proceeding with the proposed revisions to the reporting forms and instructions for the Call Reports, FFIEC 101, and FFIEC 002, with certain modifications. 

As stated in the July 2020 notice, the reporting revisions associated with the interim final rules, the final deposit insurance assessments rule, and the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) provisions have been approved through the emergency clearance process, with these revisions having taken effect for the March 31, 2020 Call report and FFIEC 101; the June 30, 2020 call report, FFIEC 101, and FFIEC 002; and/or the September 30, 2020 FFIEC 002. Subject to approval, the reporting revisions for which emergency approvals were received will remain in effect, but with instructional clarifications for the modification to the eligibility in the final rule for the five-year 2020 Current Expected Credit Loss (CECL) transition provision. Also subject to approval, the additional revisions to the call report and FFIEC 002 instructions proposed in the July 2020 notice that are related to the amendment of the Regulation D of FED would be effective for reporting beginning in the first quarter of 2021.

For accounting-related changes proposed in the July 2020 notice, the revisions would take effect March 31, 2021, except for the revisions for last-of-layer hedging, which would be implemented following the adoption of a final last-of-layer hedge accounting standard of FASB. A final standard is not expected to be issued on this before the second half of 2021. The reporting revisions to Schedule RC-M for the international remittance transfer items discussed in Section II.D of the July 2020 notice would take effect from March 31, 2021. Reporting changes, to the Call Reports and the FFIEC 101, for the TLAC investments final rule would take effect from June 30, 2021. The Call Report instructional clarifications to the Glossary entry for “Accrued Interest Receivable” and Schedule RC-B for pledged equity securities would take effect on December 31, 2020, while the instructional clarifications to Schedule RI for shared fees and commissions from securities-related and insurance activities would take effect from March 31, 2021.

Related Link: Federal Register Notice

Comment Due Date: December 23, 2020

Keywords: Americas, US, Banking, COVID-19, TLAC, Call Report, FFIEC 101, FFIEC 102, Reporting, CARES Act, Regulatory Capital, Basel, US Agencies