Proposed Agency Information Collection Activities; Comment Request (Regulators propose revisions to and extension of the call report filing requirements of (foreign) banks and of certain asset and liabilities reports of foreign banks and bank branches)

The Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System (FED), and the Federal Deposit Insurance Corporation (FDIC) are requesting comments on their proposed revised data collection in connection with „Call Reports“ and the FFIEC 002 and 002S reports. Call reports must be filed by all banks and bank holding companies located in the US. They consist of a summary of documentations such as loan and deposit information, investment information including asset sale information, changes in the bank’s capital information, and the regular financial statements including income statement and balance sheet.
The affected reports subject to proposed revisions are the following:
FFIEC 031 – Consolidated Reports of Condition and Income for a Bank with Domestic and Foreign Offices.
FFIEC 041 – Consolidated Reports of Condition and Income for a Bank with Domestic Offices Only.
FFIEC 051 – Consolidated Reports of Condition and Income for a Bank with Domestic Offices Only and Total Assets Less Than $5 Billion.
FFIEC 002 – Report of Assets and Liabilities of U.S. Branches and Agencies of Foreign Bank.
FFIEC 002S – Report of Assets and Liabilities of a Non-U.S. Branch that is Managed or Controlled by a U.S. Branch or Agency of a Foreign (Non-U.S.) Bank.
Among others, the reports or their instructions would be revised to
– modify the instructions for the Call Report Schedule RC–C, Part I, „Loans and Leases, Memorandum item 1“ and Schedule RC–N, „Past Due and Nonaccrual Loans, Leases, and Other Assets, Memorandum item 1“ to allow the collection of information on „borrowers experiencing financial difficulty (BED)“, a new accounting measure introduced by the Financial Accounting Standards Board (FASB) in 2022 to replace the „troubled debt restructuring measure (TDR)“ to determine and account for expected credit losses (ECL) of financial institutions.
– make similar adjustments to Schedule RC–M and Schedule RC–O as well as the glossary to reflect this change from TDR to BED.
– make similar revisions to the instructions of FFIEC 002, Schedule N, „Past Due, Nonaccrual, and Restructured Loans, Columns C and D“ to reference the new BED; and
– clarify in Schedule RC–M, Memoranda, instructions that institutions must use a website of their own (an internet websites operated by the reporting institution itself) to disclose the website where they solicit deposits.
Finally, the agencies propose that all revisions would be effective as of the March 31, 2024 report date to provide sufficient time to prepare for corresponding system changes.
For detailed information on the proposed revisions, please refer to the original legal document.