Agency Information Collection Activities; Submission for OMB Review; 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 branches)

In February 2023, 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) requested 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 the then proposed revisions were 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.
The regulators thereby proposed to modify the reports or their instructions to consolidate certain data items and refine the information to be reported on securitizations. Other proposed modifications included the removal of the „optional tax worksheet“ and the provision of instructions in pdf format only in the future (please see EventID 19902 for more information).
Based on the feedback the regulators have received to their initial consultation, the agencies have again somewhat modified the „proposed“ revisions and are now seeking feedback again on these proposed changes. A corresponding consultation document was published in the Federal Register. Specifically, the regulators would retain four data items on the FFIEC 031, FFIEC 041, and FFIEC 051 Call Report forms which are necessary for the assessment of FDIC insurance and which were previously suggested to be removed. The affect items are the following – as quoted:
– Schedule RC–M, item 13.b.(7), “Portion of covered other real estate owned included in items 13.b.(1) through (6) above that is protected by FDIC loss-sharing agreements”
– Schedule RC–N, item 12.f, “Portion of covered loans and leases included in items 12.a through 12.e above that is protected by FDIC loss-sharing agreements”
– Schedule SU, item 9.c.(2), “Past due 90 days or more and still accruing”
– Schedule SU, item 9.c.(3), “Nonaccrual”
Finally, the agencies propose that all revisions would be effective as of the September 30, 2023 report date to provide additional time to prepare for the changes (initially, the changes were scheduled to come into force on June 30, 2023).