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FDIC's FILs address Call Report burden reductions, EGRRCPA statutory amendment changes
On July 17, the FDIC issued Financial Institution Letter FIL-40-2018 reminding FDIC-supervised banks, savings associations, and community institutions that revisions to all three versions of the Consolidated Reports of Condition and Income (Call Reports) are effective as of the June 30 reporting date. The finalized changes modified Call Reports FFIEC 031, FFIEC 041, and FFIEC 051. Starting this quarter, institutions with consolidated total assets of at least $100 billion with no foreign offices are now required to use FFIEC 031 instead of FFIEC 041. In addition, the FDIC released supplemental submission instructions for institutions (see FIL-39-2018) and also addressed two reporting requirement changes made by the enactment of the Economic Growth, Regulatory Relief, and Consumer Protection Act S.2155/P.L. 115-174 that took effect immediately: (i) acquisition, development, or construction loans considered high volatility commercial real estate loans are subject to risk weighting with certain exemptions; and (ii) qualifying institutions may exclude a capped amount of reciprocal deposits from being treated as brokered deposits. Second quarter Call Reports are due July 30.
Agencies seek OMB approval on November 2017 Call Report revisions
On April 11, the Federal Reserve Board, FDIC, and OCC—as members of the Federal Financial Institutions Examination Council (FFIEC)—published a joint notice and request for comment for OMB review and approval regarding revisions to the Consolidated Reports of Condition and Income (Call Reports) for financial institutions. The finalized changes modify Call Reports applicable to banks with (i) domestic offices only and less than $1 billion in total assets (FFIEC 051); (ii) domestic offices only (FFIEC 041); and (iii) domestic and foreign offices (FFIEC 031). The changes include removing or consolidating certain data items and adding a new or raising certain existing reporting thresholds in the three versions of the Call Report. Comments must be submitted by May 11. Subject to OMB approval, the revisions would take effect as of the June 30, 2018 report date. As previously covered by InfoBytes, the changes were originally proposed in November 2017.
FFIEC finalizes November 2017 Call Report revisions
On March 30, the Federal Reserve Board, FDIC, and OCC—as members of the Federal Financial Institutions Examination Council (FFIEC)—announced finalized plans to reduce data reporting requirements and other regulatory requirements associated with the Consolidated Reports of Condition and Income (Call Reports) for financial institutions. According to the FFIEC, the finalized changes modify Call Reports applicable to banks with (i) domestic offices only and less than $1 billion in total assets (FFIEC 051); (ii) domestic offices only (FFIEC 041); and (iii) domestic and foreign offices (FFIEC 031). The changes include removing or consolidating certain data items and adding a new or raising certain existing reporting thresholds in the three versions of the Call Report. The changes were originally proposed in November 2017 (previously covered by InfoBytes here) and are effective June 30.
In January, the FFIEC also finalized other burden-reducing Call Report revisions based on a June 2017 proposal, as previously covered by InfoBytes.
Agencies finalize plans to further streamline Call Reports
On January 3, the Federal Reserve Board, FDIC, and OCC (agencies)—as members of the Federal Financial Institutions Examination Council (FFIEC)—announced finalized plans to reduce data reporting requirements and other regulatory requirements associated with the Consolidated Reports of Condition and Income (Call Reports) for financial institutions. According to the FFIEC, after reviewing comments related to the joint June 2017 proposal, the finalized changes will include:
- Reducing or remove the reporting frequency for approximately seven percent of the data items required on the Call Report for small institutions, effective June 30, 2018; and
- Revising Call Report schedules to align with the changes in accounting for equity securities, effective March 21, 2018.
The FFIEC noted that the agencies will not proceed with their June 2017 proposal to revise the instructions for determining past due status.
In addition to the June 2017 proposal, previous requests for proposed burden-reducing Call Report revisions were submitted by the agencies in August 2016 and November 2017 (see InfoBytes’ coverage of the August request here and the November request here).
Federal Banking Agencies Seek Comments on Proposal to Further Streamline Call Reports
On November 2, the Federal Reserve Board, FDIC, and OCC (agencies)—all members of the Federal Financial Institutions Examination Council (FFIEC)—issued a joint notice and request for comment on a proposal to further streamline the Consolidated Reports of Condition and Income (Call Reports) in an effort to reduce data reporting requirements and regulatory burdens for financial institutions. The proposal would modify Call Reports applicable to banks with (i) domestic offices only and less than $1 billion in total assets (FFIEC 051); (ii) domestic offices only (FFIEC 041); and (iii) domestic and foreign offices (FFIEC 031). The proposed revisions, which would eliminate or combine several data items and revise certain existing reporting thresholds, would take effect as of the June 30, 2018, report date. Comments on the proposal are due within 60 days after its publication in the Federal Register.
Previous requests for proposed burden-reducing Call Report revisions were submitted by the agencies in August 2016 and June 2017. (See InfoBytes’ coverage of the August request here.)
Nationwide Mortgage Licensing System Unveils New Money Services Businesses Call Report
On April 1, the Nationwide Mortgage Licensing System (NMLS) Money Services Businesses (MSB) unveiled “the first comprehensive report to consolidate state MSB reporting requirements and provide a database of nationwide MSB transaction activity.” It also allows licensees to report directly in NMLS for all states on a quarterly and annual basis. The release of the MSB Call Report culminates “a multi-year effort by state regulators to develop a tool to standardize and streamline routine reporting requirements for state-licensed Money Services Businesses”—including money transmitters, check cashers, and prepaid card issuers. The MSB Call Report contains three sections: (i) “company financial information”; (ii) “information about the licensee’s company and state level transactional activity”; (iii) “company permissible investments information”; (iv) “and transaction destination country information.” According to the MSB Call Report webpage, 18 state agencies will adopt the MSB Call Report for Q1 2017 reporting.
NMLS is the system of record for non-depository, financial services licensing or registration in participating state, territory and local agencies. Although NMLS does not grant or deny license authority, it does—in participating jurisdictions—serve as the official system for companies and individuals seeking to apply for, amend, renew and surrender licenses. NMLS is also the sole system of licensure for mortgage companies and the system of record for the registration of depositories, subsidiaries of depositories, and Mortgage Loan Originators (MLOs) under the CFPB’s Regulation G (S.A.F.E. Mortgage Licensing Act—Federal Registration of Residential Mortgage Loan Originators).
Additional information and a list of the state agencies that have adopted the report as of March 2017 can be accessed through the NMLS Resource Center.
FDIC Releases Presentation Materials Explaining New Streamlined “FFIEC 051 Call Report” for Eligible Small Institutions
Earlier this month, the FDIC released presentation materials used during a recent webinar hosted by the Federal Financial Institutions Examination Council (FFIEC) for the purpose of explaining the new streamlined “FFIEC 051 Call Report” for eligible small institutions. As previously covered by InfoBytes, the Federal banking agencies – including the FDIC, the Fed, and the OCC – are implementing a new Call Report for financial institutions with only domestic offices and less than $1 billion in total assets (see FIL-82-2016). The proposed changes – which go into effect on March 31 – modify the existing “FFIEC 041” and “FFIEC 031” versions of the Call Report as part of an ongoing initiative to reduce the burden associated with Call Report requirements for community banks. Among other things, the streamlined Call Report reduces the existing Call Report from 85 to 61 pages, resulting from the removal of approximately 950 (or about 40 percent) of the nearly 2,400 data items in the Call Report.
OCC to Host Credit Risk and Operational Workshops for Directors of National Community Banks and Federal Savings Associations; Banking Agencies to Conduct Webinar to Introduce New FFIEC Call Report
On March 2, the Office of the Comptroller of the Currency (OCC) announced that it will host two workshops in Phoenix on April 11-12 for directors of OCC supervised national community banks and federal associations. The Credit Risk workshop (April 11) will cover strategies to recognize trends and problems in credit risk within the loan portfolio, and the Operational Risk workshop (April 12) will discuss key components of operational risk, governance, third-party risk, vendor management, and cybersecurity.
Also on March 2, four members of the Federal Financial Institutions Examination Council (FFIEC) (Federal Reserve Board, Federal Deposit Insurance Corporation, Office of the Comptroller of the Currency, and the Conference of State Bank Supervisors) announced the implementation of the new streamlined FFIEC 051 Call Report, effective March 31, 2017, that will introduce burden-reducing changes to the existing versions of the Call Report and will be available to eligible small institutions. “’Eligible small institutions’ are [defined as] institutions with domestic offices only and total assets of less than $1 billion, excluding those that are advanced approaches institutions for regulatory capital purposes.” The revisions to the requirements are subject to approval by the OMB. On March 8, the FFIEC will conduct a webinar from 2:00 p.m. to 3:30 p.m. ET to introduce the new Call Report and explain the revisions.
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