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Financial Services Law Insights and Observations

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  • Massachusetts Division of Banks updates extensions for licensee filings

    State Issues

    On March 30, the Massachusetts Division of Banks (DOB) issued an update for licensees to clarify the filing deadlines for financial statements and call reports in light of the NMLS policy decision. The DOB is providing a 60-day extension to file financial statements, a 30-day extension to submit Call Reports and the MCR Standard Financial Condition Report, and a 60-day extension for Annual Reports.

    State Issues Licensing NMLS Covid-19 Call Report Massachusetts

  • Idaho regulator provides updates on agency operations

    State Issues

    On March 26, the Idaho Department of Finance Consumer Finance Bureau (Department) issued updated guidance to its registrants and licensees regarding the Department’s current operations during the Covid-19 outbreak. In particular, the Department noted that though the offices will be closed to the public for the next 21 days, staff are continuing to process licensing and registration applications. The Department suggested that companies may choose to transition their license records to the NMLS to avoid delays. In addition, the Department noted that field examinations continue remotely, using phone and email in lieu of onsite reviews. Finally, the Department indicated deadlines were extended for mortgage companies to file mortgage call reports and financial statements, and that deadlines will be reviewed for required license renewals and reports as needed.

    State Issues Covid-19 Idaho Licensing Call Report Examination

  • NMLS extends deadline for reports and SAFE MLO test enrollment

    On March 25, in response to the Covid-19 pandemic, the NMLS Policy Committee extended the deadline for certain reporting obligations satisfied through NMLS, and the enrollment window for taking the SAFE MLO test.

    Companies required to submit financial statements, the Mortgage Call Report, and the Money Services Businesses Call Report will have an additional 60 days from pre-established deadlines to submit such reports. Individuals will have the testing window on their test appointments extended 180 days.

    The NMLS Resource Center has been updated with additional resources to provide updates on state agency operating status. In addition, the NMLS Policy Committee is encouraging states to accept documentation electronically that otherwise may have been required in hard copy.

    The full announcement can be found on the NMLS Resource Center.

    Licensing Mortgage Licensing NMLS Mortgage Origination Mortgages MLO Money Service / Money Transmitters Call Report Covid-19

  • OCC issues bulletin to community banks on filing of Call Reports

    Federal Issues

    On March 25, the OCC issued Bulletin 2020-24, which encourages institutions to file March 31 call reports by the filing deadline, but recognizes that Covid-19-related disruptions may cause filing delays. As such the OCC will not take action against institutions affected by Covid-19 for submitting in good faith the March 31 call report within 30 days of the filing deadline.  Further, institutions may amend the filing to correct for unintentional and incidental reporting errors within 30 days of the filing deadline without penalty. Institutions affected by Covid-19 that expect a delay in their March 31 call report submission or anticipate challenges in obtaining director attestations before submission of the call report are encouraged to contact their supervisory office.

    Federal Issues Covid-19 OCC Community Banks Call Report

  • FFIEC issues statement regarding Call Report filing delays

    Federal Issues

    On March 25, the FFIEC issued a statement providing that the federal banking agencies will not take action against any institution for submitting March 31, 2020, Reports of Condition and Income (Call Reports) after the respective filing deadline, as long as the report is submitted within 30 days of the official filing date. Institutions are encouraged to contact their primary federal regulator in advance of the official filing date if they anticipate a delayed submission.

    Federal Issues Covid-19 FFIEC Call Report

  • Agencies finalize Call Report capital-related reporting revisions

    Agency Rule-Making & Guidance

    On February 19, the FDIC issued FIL-11-2020 announcing the Federal Reserve Board, FDIC, and OCC have finalized capital-related reporting revisions (see Federal Register notice and FIL-10-2020) to the Consolidated Reports of Condition and Income (Call Reports) for certain banks (FFIEC 031, 041, 051) as well as the Regulatory Capital Reporting for Institutions Subject to the Advanced Capital Adequacy Framework (FFIEC 101). Among other things, the final revisions include changes to the capital simplifications rule and the community bank leverage ratio rule, in addition to Call Report instructional revisions taking effect in 2021 concerning reporting home equity lines of credit that convert from revolving to non-revolving status. These reporting revisions are subject to approval by OMB.

    Agency Rule-Making & Guidance FDIC Federal Reserve OCC Call Report

  • Agencies finalize streamlined small-institution reporting

    Agency Rule-Making & Guidance

    On June 17, the FDIC, the OCC, and Federal Reserve issued the final rule to streamline regulatory reporting for qualifying small institutions to implement Section 205 of the Economic Growth, Regulatory Relief, and Consumer Protection Act. The agencies adopted the final rule as proposed in November 2018 (covered by InfoBytes here). The final rule permits depository institutions with less than $5 billion in assets—previously set at $1 billion—that do not engage in certain complex or international activities to file the FFIEC 051 Call Report, the most streamlined version of the Call Reports. Additionally, the rule reduces the existing reportable data items in the FFIEC 051 Call Report by approximately 37 percent for the first and third calendar quarters. The rule also includes similar provisions for uninsured institutions with less than $5 billion in total consolidated assets that are supervised by the Federal Reserve and the OCC. The rule notes that the agencies are also committed to “exploring further burden reduction and are actively evaluating further revisions to the FFIEC 051 Call Report, consistent with guiding principles developed by the FFIEC.” The rule will take effect 30 days after it is published in the Federal Register.

    Agency Rule-Making & Guidance OCC FDIC Federal Register Federal Reserve Call Report EGRRCPA

  • Agencies issue joint proposal to streamline small institution reporting requirements

    Agency Rule-Making & Guidance

    On November 7, the OCC, FDIC, and Federal Reserve issued a proposal to streamline regulatory reporting for qualifying small institutions to implement Section 205 of the Economic Growth, Regulatory Relief, and Consumer Protection Act. Specifically, the joint proposal would permit depository institutions with less than $5 billion in assets—previously set at $1 billion—that do not engage in certain complex or international activities to file the FFIEC 051 Call Report, the most streamlined version of the Call Reports. Additionally, the proposal would reduce the existing reportable data items in the FFIEC 051 Call Report by approximately 37 percent for the first and third calendar quarters. The proposal also includes similar provisions for uninsured institutions with less than $5 billion in total consolidated assets that are supervised by the Federal Reserve and the OCC. Comments on the proposal must be received within 60 days of publication in the Federal Register.

    Agency Rule-Making & Guidance FDIC Federal Register Federal Reserve OCC Call Report EGRRCPA

  • FDIC proposes to eliminate annual disclosure requirement for state nonmember banks

    Agency Rule-Making & Guidance

    On October 25, the FDIC published a proposed rule in the Federal Register to rescind the annual disclosure requirement applicable to all state nonmember banks and insured state-licensed branches of foreign banks (collectively, “banks”). Specifically, the FDIC is proposing to eliminate 12 CFR Part 350, which, in general, required banks to prepare annual disclosure statements consisting of (i) required financial data comparable to specified schedules in the Call Reports filed for the previous two years; (ii) information that the FDIC may request, such as enforcement actions; and (iii) other information the bank chooses to disclose. According to the proposal, the FDIC has determined that the regulation is “outdated and no longer necessary,” because, with widespread access to the internet, information about the financial condition and performance of individual banks is now “reliably and directly offered to the public through the FDIC’s and the Federal Financial Institutions Examination Council’s (FFIEC) websites” in the form of Call Reports and Uniform Bank Performance Reports. This eliminates the need for the annual disclosure statement requirements. Similar disclosure requirements have already been rescinded in recent years by the Federal Reserve Board and OCC. Comments on the proposed rule must be received by November 26.

    Agency Rule-Making & Guidance FDIC Federal Register Disclosures Call Report FFIEC

  • Federal banking agencies request comments on proposal to revise and extend various information collection procedures

    Agency Rule-Making & Guidance

    On September 28, the Federal Reserve Board, FDIC, and OCC (the Agencies)—with the approval of the Federal Financial Institutions Examination Council (FFIEC)—published a joint notice and request for comment proposing to extend and revise currently approved collections of information for: (i) Consolidated Reports of Condition and Income (Call Reports) for certain banks (FFIEC 031, 041, 051); (ii) Reports of Assets and Liabilities for branches and agencies of foreign banks (FFIEC 002, 002S); (iii) Foreign Branch Reports of Condition (FFIEC 030, 030S); and (iv) the Regulatory Capital Reporting for Institutions Subject to the Advanced Capital Adequacy Framework (FFIEC 101). Among other things, the proposed revisions generally address the revised accounting for credit losses described within Accounting Standards Update No. 2016-13, and include reporting changes for regulatory capital related to the Agencies’ current expected credit losses methodology.

    The revisions would begin taking effect March 31, 2019, for quarterly report date respondents; December 31, 2022, for annual report date respondents; and on later dates for certain respondents. Comments must be submitted by November 27.

    Agency Rule-Making & Guidance OCC Federal Reserve FDIC Call Report

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