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From Banking and Finance Law Daily, November 7, 2018

Agencies propose simpler Call Reports for smaller institutions

By Richard A. Roth, J.D.

A proposal that would allow more financial institutions to use the simplest Call Report form, and that would reduce the information that the form requires, is being offered by the Federal Reserve Board, Office of the Comptroller of the Currency, and Federal Deposit Insurance Corporation. The joint proposal, which is required by the Economic Growth, Regulatory Relief, and Consumer Protection Act, would benefit simpler financial institutions that have less than $5 billion in total assets, including some uninsured institutions that are supervised by the Fed or the OCC. The proposal would benefit institutions that:

  • do not exceed the $5 billion threshold;
  • have no foreign offices;
  • are not insured branches of foreign banks;
  • do not use the advanced approaches method to calculate their risk-based capital requirements; and
  • are not deemed to be large or highly complex under the FDIC’s assessments regulations.

Effects of proposal. Currently, only financial institutions with less than $1 billion in assets may file the FFIEC 051, which is the simplest of the three Call Report forms. The agencies anticipate that increasing the threshold from $1 billion to $5 billion would mean that approximately 5,350 financial institutions could use this form, as opposed to the approximately 550 that currently may do so.

The proposal also would reduce the information that must be reported in the first and third quarters of each year. The agencies say they would remove 37 percent of the required data fields in these quarters. The data items to be removed cover asset risk-weighting, fiduciary services assets and income, and troubled debt restructuring. However, this reduction would be slightly offset by the addition of some data fields for institutions that have between $1 billion and $5 billion in assets.

The proposed changes still would allow a regulator to require an institution to file one of the more detailed Call Report forms if it is necessary for supervisory purposes.

Comments on the joint proposal will be accepted for 60 days after its Federal Register publication.

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