Banking Regulators Seek Comment on Small Institution Call Report
Last week the FFIEC issued a press release seeking comment on the proposed new and streamlined Call Report for small financial institutions. I encourage you and your staff to review this proposal closely and take time to submit comments via the Federal Register for the agencies to consider as part of the process.
Background: On Friday, August 5, 2016, state and federal banking agencies, as members of the Federal Financial Institutions Examinations Council (FFIEC), issued for public comment a new and streamlined Call Report for small financial institutions. The new Call Report would apply to financial institutions with domestic offices only and less than $1 billion in total assets. This represents approximately 90 percent of all institutions required to file Call Reports. The new Call Report will lessen the reporting burden for community banks by reducing the existing Call Report from 85 to 61 pages, resulting from the removal of approximately 950, or about 40 percent, of the nearly 2,400 data items in the Call Report.
In evaluating changes to the Call Report for small financial institutions, the FFIEC has sought to balance reporting burden against regulators’ need for reliable data to ensure these institutions operate in a safe and sound manner and are able to meet the financial needs of the communities they serve.
In addition to the new streamlined Call Report proposal, regulators are also requesting comments on certain proposed revisions to the two existing versions of the Call Report, which would remain applicable to institutions not qualifying for the streamlined Call Report.
The changes in the Call Report proposals are in direct response to comments received during the recent Economic Growth and Regulatory Paperwork Reduction Act (EGRPRA) process.
Comments are requested on all aspects of the proposals, and given the potentially significant changes to these proposals, a significant number of comments are expected. Often, the most helpful comments are those that provide specific examples or illustrate how a proposal will affect the institution.
Again, I encourage you to evaluate these proposals as they will have a direct impact on Call Report submissions going forward. The agencies request comments on the proposed changes no later than 60 days after the date of their publication in the Federal Register. The proposal is available online at http://www.ffiec.gov/press/PDF/FRN-Small_Bank_Call_Report.pdf.
Jan Lynn Owen
Department of Business Oversight