United States: Proposed Revisions To The Consolidated Reports Of Condition And Income (Call Report)

Effective today, the Federal Deposit Insurance Corporation (FDIC), the Federal Reserve Board, and the Office of the Comptroller of the Currency (collectively, the agencies) are requesting comment on additional burden-reducing revisions and certain other reporting changes to all three versions of the Call Report. These revisions are proposed to take effect March 31, 2018. The proposal results from ongoing efforts by the Federal Financial Institutions Examination Council (FFIEC) to ease reporting requirements and lessen reporting burden that is focused on, but not limited to, small institutions. The proposed reporting changes have been approved by the FFIEC and would affect the recently implemented FFIEC 051 Call Report for eligible small institutions as well as the FFIEC 041 and FFIEC 031 Call Reports. The FFIEC and the agencies will review and consider the comments as they finalize the revisions to the Call Report.

A key element of the community bank Call Report burden-reduction initiative is a statutorily mandated review of all existing Call Report data items based on responses to a series of nine surveys of internal users of Call Report data within the FFIEC member entities. Each survey covers a group of Call Report schedules. Reporting changes resulting from the agencies' evaluation of the responses to the first portion of the user surveys were included in the Call Report proposal published in August 2016 and finalized in December 2016 (see FIL-82-2016, dated December 30, 2016). The burden-reducing changes included in the agencies' current proposal result from the evaluation of responses to another portion of the user surveys, the re-evaluation of responses to certain previously reviewed surveys, and the agencies' consideration of industry comments and feedback, including comments received on the August 2016 Call Report proposal. These changes include the removal or consolidation of existing data items, reductions in the reporting frequency for other data items, and increases in certain reporting thresholds. A summary of the FFIEC member entities' uses of the data items retained in the Call Report schedules covered in the portion of the user surveys evaluated in the development of this proposal is included in an appendix to the attached Federal Register notice.

The agencies' statutory review of the Call Report data items is ongoing, and the agencies are analyzing the responses to the final portion of the user surveys. Further burden-reducing Call Report changes based on the review of these surveys will be proposed in a future Federal Register notice.

The agencies' proposal also includes two other revisions to the Call Report. The first proposal would revise the instructions by aligning the method for determining the past-due status of certain loans and other assets for Call Report purposes with an accepted industry standard. The second proposal would revise portions of several Call Report schedules in response to changes in the accounting for investments in equity securities under the Financial Accounting Standards Board's Accounting Standards Update No. 2016-01, "Recognition and Measurement of Financial Assets and Financial Liabilities."

Redlined copies of the FFIEC 051, FFIEC 041, and FFIEC 031 report forms showing the proposed burden-reducing changes and equity securities revisions are available on the FFIEC's website (https://www.ffiec.gov/ffiec_report_forms.htm) on the web page for each report form. Lists detailing the schedules and data items affected by the proposal are included as appendices to the attached Federal Register notice. These lists also have been posted on the FFIEC's website.

Disclaimer: This Alert has been prepared and published for informational purposes only and is not offered, nor should be construed, as legal advice. For more information, please see the firm's full disclaimer.

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