Letter details asset-level thresholds in 2021 for call reports, allowing lesser of year-end ’19 or MY ’20

Changes related to asset threshold relief that would apply to the three versions of bank call reports – and allow banks to use the lesser of year-end 2019 or June 2020 asset levels as a starting point for reporting in 2021 – are addressed in a letter sent Friday to insured banks and thrifts by the federal banking agencies.

According to a financial institution letter (FIL-8-2021) from the Federal Deposit Insurance Corp. (FDIC), the changes apply to the three versions of the Call Report (FFIEC 031, FFIEC 041, and FFIEC 051), as appropriate. The reporting changes, proposed by the agencies Nov. 30, 2020, are subject to approval by the White House Office of Management and Budget (OMB).

According to the FDIC letter, the banking agencies (FDIC, Federal Reserve, and Office of the Comptroller of the Currency) under the auspices of the Federal Financial Institutions Examination Council (FFIEC), published the attached final regulatory reporting changes in the Federal Register on Thursday (Feb. 18).

The FDIC letter states that, consistent with an interim final rule (IFR) published Dec. 2, the agencies are permitting an institution to use the lesser of the total consolidated assets reported in its call report as of Dec. 31, 2019, or June 30, 2020, when determining whether the institution has crossed certain total asset thresholds to report additional data items in its call reports for report dates in calendar year 2021.

The thresholds, the letter states, include the $5 billion threshold for limiting eligibility to use the FFIEC 051 version of the call report and the $100 million, $300 million, $1 billion, and $10 billion thresholds for reporting certain additional data items in the call reports.

The letter notes that the agencies are allowing this relief for calendar year 2021 only.

“In addition, the IFR allows institutions that temporarily exceed the $10 billion total asset threshold to use the community bank leverage ratio framework in Call Report Schedule RC R from Dec. 31, 2020, through Dec. 31, 2021, provided they meet the other qualifying criteria for this framework,” the letter states. “For each of these report dates, an institution would use the lesser of its total assets as of December 31, 2019, or as of the current quarter-end report date to determine whether it has met the $10 billion total asset threshold.”

FDIC FIL-8-2021: Revisions to the Consolidated Reports of Condition and Income (Call Report) Related to Asset Threshold Relief