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Financial Services Law Insights and Observations

FFIEC releases its revisions to call reports during open comment period

Bank Regulatory FFIEC Federal Reserve FDIC Call Report

On May 22, members of the FFIEC, comprising the FDIC, Fed, and OCC, released their changes to how banks report their financial information through all three versions of the Call Report (FFIEC 031, FFIEC 041, and FFIEC 051) and the FFIEC 002 report. These revisions are intended to improve data accuracy and promote reporting consistency across institutions.

The first wave of updates will affect all three versions of the Call Report, as well as the FFIEC 002, and will go into effect on June 30. The primary focus will be on the alignment of reporting language with recent changes in accounting standards. Changes will include replacing references to “troubled debt restructurings” and will be replaced with “modifications to borrowers experiencing financial difficulty.” Additionally, the revisions will include new standards for electronic signatures. In addition, the agencies are implementing revisions related to the reporting of loans to nondepository financial institutions and government-backed structured financial products.

The agencies will still consider public comments on other proposed changes, including revisions to reporting requirements for loan modifications for struggling borrowers, past-due loans, and long-term debt. These potential future revisions aim to further enhance bank financial reporting clarity. Comments on these revisions must be submitted by June 21.