Agencies Revised Consolidated Reports of Condition – June 2020

June 12, 2020 – FDIC, FRB, and OCC have received emergency approval from OMB for certain revisions to three versions of the Call Report (namely FFIEC 031, FFIEC 041, and FFIEC 051). Including for the regulatory capital reporting for institutions subject to the advanced capital adequacy framework (FFIEC 101), effective as of June 30, 2020 reporting date.

Origin of Revisions

These revisions resulted from several interim final rules and a notice of proposed rule issued by agencies in response to impact on markets and strains on economy of Covid. The four revisions made, also resulted from provisions of the recent 2020 CARES Act.

Updates to Instructions

Updates to the instructions for the calculation of amounts reported on Schedule RC-R, regulatory capital, and for the calculation of certain amounts on Schedule A, advanced approaches regulatory capital, which appear on the FFIEC 101.

New items on Call Report

New items on-call report Schedule RC-C, Part I, loans and leases; Schedule RC-M, memoranda, to collect data on eligible loan modifications under Sec. 4013, temporary relief from troubled debt restructurings of the CARES Act, collected confidentially. Also on SBA’s Paycheck Protection Program (PPP) loans, under PPP Liquidity Facility and holdings of assets purchased under the Money Market Mutual Fund Liquidity Facility.

Definition Revisions

Revisions to the definitions of certain deposits reported on-call report Schedule RC-E, deposit liabilities, in response to an IFR amending the board’s Regulation D.

Reporting Changes

Changes to the reporting on extensions of credit to insiders on-call report Schedule RC-M, memoranda, in response to a Board IFR that excepts certain loans guaranteed under the Small Business Administration’s PPP from the requirements of section 22(h) of the Federal Reserve Act and the corresponding provisions of the Board’s Regulation.

Effective Date

The effective date for these revisions is the June 30, 2020 reporting date.

Client Impact:

As-of 6/30/2020 Call Report & FFIEC 101 Reporting Changes

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