Letter outlines revisions to call reports reflecting long list of rule revisions made in response to coronavirus crisis

Revisions to three versions of the federal banking agencies’ call report – approved in an emergency action – which resulted from at least nine new rules issued in response to the financial impact of the coronavirus pandemic are outlined in a financial institution letter issued by the federal insurer of bank deposits Friday.

In its letter (FIL-60-2020), the Federal Deposit Insurance Corp. (FDIC) said that it and the Federal Reserve and Office of the Comptroller of the Currency (OCC) requested and received emergency approval from the White House Office of Management and Budget (OMB) to make the changes to the three call report versions (which are: FFIEC 031, FFIEC 041, and FFIEC 051). The agency also said the form “Regulatory Capital Reporting for Institutions Subject to the Advanced Capital Adequacy Framework” (FFIEC 101), effective as of the June 30, 2020, report date, had also been modified.

“These revisions resulted from several interim final rules (IFRs) and a notice of proposed rulemaking (NPR) issued by one or all of the agencies in response to the impact on the financial markets and the strains on the U.S. economy as a result of the Coronavirus Disease 2019 (COVID-19),” the letter states. “These revisions also resulted from certain provisions of the 2020 Coronavirus Aid, Relief, and Economic Security Act (CARES Act),” enacted into law March 27.

The letter says details of the changes include:

  • Updates to the instructions for the calculation of certain amounts reported on Schedule RC-R, Regulatory Capital, that apply to the three versions of the Call Report and for the calculation of certain amounts reported on Schedule A, Advanced Approaches Regulatory Capital, on the FFIEC 101.
  • New items on Call Report Schedule RC-C, Part I, Loans and Leases, and Schedule RC-M, Memoranda, to collect data on:
    • Eligible loan modifications under Section 4013, Temporary Relief from Troubled Debt Restructurings, of the CARES Act, with these items collected on a confidential basis;
    • Small Business Administration (SBA) Paycheck Protection Program (PPP) loans and borrowings under the Federal Reserve PPP Liquidity Facility (PPPLF); and
    • Holdings of assets purchased under the Money Market Mutual Fund Liquidity Facility (MMLF). The agencies said they expect the collection of these new items to be time-limited.
  • 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 (12 CFR 204).
  • 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 O (12 CFR 215).

FDIC FIL-60-2020: Revisions to the Consolidated Reports of Condition and Income (Call Report) and the FFIEC 101 Report