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Nov 4 -- The Office of the Comptroller of the Currency (OCC), Treasury; Board of Governors of the Federal Reserve System (Board); and Federal Deposit Insurance Corporation (FDIC) invite public comments to OMB regarding continuation of Consolidated Reports of Condition and Income (Call Reports).
 
The agencies propose to extend for three years, with revision, the FFIEC 031, FFIEC 041, and FFIEC 051 Call Reports.

Report Title: Consolidated Reports of Condition and Income (Call Report).

Form Number: 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), and FFIEC 051 (Consolidated Reports of Condition and Income for a Bank with Domestic Offices Only and Total Assets Less Than $5 Billion).

Frequency of Response: Quarterly.
 
The Call Report information collections are mandatory: 12 U.S.C. 161 (national banks), 12 U.S.C. 324 (state member banks), 12 U.S.C. 1817 (insured state nonmember commercial and savings banks), and 12 U.S.C. 1464 (federal and state savings associations). At present, except for selected data items and text, these information collections are not given confidential treatment.

Banks and savings associations submit Call Report data to the agencies each quarter for the agencies' use in monitoring the condition, performance, and risk profile of individual institutions and the industry as a whole. Call Report data serve a regulatory or public policy purpose by assisting the agencies in fulfilling their shared missions of ensuring the safety and soundness of financial institutions and the financial system and protecting consumer financial rights, as well as agency-specific missions affecting national and state-chartered institutions, such as conducting monetary policy, ensuring financial stability, and administering federal deposit insurance. Call Reports are the source of the most current statistical data available for identifying areas of focus for on-site and off-site examinations. Among other purposes, the agencies use Call Report data in evaluating institutions' corporate applications, including interstate merger and acquisition applications for which the agencies are required by law to determine whether the resulting institution would control more than 10 percent of the total amount of deposits of insured depository institutions in the United States. Call Report data also are used to calculate institutions' deposit insurance assessments and national banks' and federal savings associations' semiannual assessment fees.
 
 A. New Item for SA-CCR
On January 24, 2020, the agencies issued a final rule (SA-CCR final rule) that amends the regulatory capital rule to implement a new approach for calculating the exposure amount for derivative contracts for purposes of calculating total risk-weighted assets (RWA), which is called SA-CCR. The final rule also incorporates SA-CCR into the determination of the exposure amount of derivatives for total leverage exposure under the supplementary leverage ratio and the cleared transaction framework under the capital rule. Banking institutions that are not advanced approaches institutions may elect to use SA-CCR to calculate standardized total RWA by notifying their appropriate federal supervisor. Advanced approaches institutions are required to use SA-CCR to calculate standardized total RWA starting on January 1, 2022. Advanced approaches institutions may adopt SA-CCR prior to January 1, 2022, but must notify their appropriate federal supervisor of early adoption.

On July 22, 2021, the agencies proposed to revise Schedule RC-R, Part I, Regulatory Capital Components and Ratios, on all versions of the Call Report by adding a new line item 31.b, “Standardized Approach for Counterparty Credit Risk opt-in election.” The agencies proposed to add this new item to identify institutions that have chosen to early adopt or voluntarily elect SA-CCR. This information allows for enhanced comparability of the reported derivative data and for better supervision of the implementation of the framework at these institutions. Due to the inherent complexity of adopting SA-CCR, identification of non-advanced approaches institutions that choose to voluntarily adopt SA-CCR is particularly important for their supervision.

The comment period for the July 2021 notice ended on September 20, 2021. The agencies received one comment that was generally supportive of the proposed new Call Report line item related to the SA-CCR final rule. The agencies did not receive any other comments on the proposed change and intend to add the new item for SA-CCR as proposed. The agencies made available on the FFIEC website redline changes related to SA-CCR in the forms and instructions for Schedule RC-R, Part I, Regulatory Capital Components and Ratios, and the agencies will use these same redline changes for this notice as well.

B. Instruction Revisions for DTAs
On May 10, 2021, the agencies published a proposed rule on Tax Allocation Agreements (Tax NPR) with request for comment.[6] Consistent with the proposed requirements and discussion in the Tax NPR, the agencies proposed to revise the Call Report instructions Glossary entry for “Income Taxes” to address treatment of temporary difference deferred and operating loss and tax credit carryforward DTAs in the July 2021 notice.

The agencies are still considering comments received on the Tax NPR. Therefore, the agencies are deferring consideration of any instruction changes related to DTAs to a future Paperwork Reduction Act notice, which will also provide an opportunity for additional comment on the instructions. The agencies did receive two comments on the proposed instruction revisions for DTAs, which will be considered when developing that notice.

III. Timing
As stated in the July 2021 notice, the proposed reporting change for the new item related to SA-CCR would take effect starting with the December 31, 2021, Call Report.

FFIEC Central Data Repository's Public Data Distribution (Select "Call Reports") https://cdr.ffiec.gov/public/ManageFacsimiles.aspx
Call Reports submission to OMB: https://www.reginfo.gov/public/do/PRAViewICR?ref_nbr=202110-1557-002 Click on IC List for data collection forms, Click View Supporting Statement for technical documentation. Submit comments through this site.
FR notice inviting public comments: https://www.federalregister.gov/documents/2021/11/04/2021-24060/agency-information-collection-activities-submission-for-omb-review-comment-request
 
For AEA members wishing to submit comments, "A Primer on How to Respond to Calls for Comment on Federal Data Collections" is available at https://www.aeaweb.org/content/file?id=5806

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