Call report materials ready for banks – which include new topic on reporting TDRs

Materials for quarterly call reports and guidance on certain issues were distributed Thursday by the federal insurer of bank deposits for reporting on banks’ condition and income for the first quarter of 2022 – including new guidance on reporting loan modifications to borrowers experiencing financial difficulties.

Except for certain institutions with foreign offices, completed call reports must be received by April 30, the agency noted.

According to the Federal Deposit Insurance Corp. (FDIC) in a financial institution letter (FIL 17-2022), the new section on troubled loans reflects the Accounting Standards Update (ASU 2022-02) from the Financial Accounting Standards Board (FASB), “Financial Instruments – Credit Losses (Topic 326): Troubled Debt Restructurings and Vintage Disclosures.”

For those banks following ASU 2022-02, the letter states, the new topic provides guidance on how an institution should report its loan modifications to borrowers experiencing financial difficulties.

Other key points made in the letter include:

  • A bank with more than one foreign office, other than a “shell” branch or an international banking facility, is permitted an additional five calendar days to submit its call report data, electronically (by May 5).
  • Banks should use total consolidated assets as of the June 30, 2021, report date to determine their eligibility to file the FFIEC 051 call report or the FFIEC 041 call report as of March 31, 2022. Institutions are expected to file the same report form for each quarterly report date during 2022. The June 30, 2021, report date should also be used in determining whether an institution has crossed certain total asset thresholds that require additional data items to be reported in its call report for report dates in calendar year 2022.
  • The Legal Entity Identifier (LEI) was added to the call report beginning with the March 31, 2017, report date. Since then, the agency said, regulators and market participants have recognized the importance of the LEI as a key improvement in financial data systems. “However, a recent review of reported data identified a significant number of institutions that have an LEI but are not reporting the LEI on their call report. Institutions are reminded that the LEI must be provided on the call report if the institution already has an LEI. An institution that does not have an LEI is not required to obtain one for purposes of reporting it on the call report.”

FIL-17-2022: Consolidated Reports of Condition and Income for First Quarter 2022