Banking Agencies Issue Guidance on Call Report Changes

The FDIC, FRB, and OCC have issued supplemental instructions for completing required call reports and risk-based capital reporting, along with reminders to depository institutions regarding interim final rules and notices issued in March 2020, which revised requirements and delayed reporting as part of the agencies’ COVID-19 response. 

As you may recall, call reports for most institutions are now due April 30, 2020, reflecting a thirty-day extension.  Moreover, the FFIEC will not take action against delayed reports as long as the report is submitted within 30 days of the deadline. 

A number of changes were made through the March 2020 interim final rules to allow banking organizations greater flexibility during the COVID-19 pandemic.  These changes include:

• Redefining “eligible retained income” to reduce the impact of automatic limits on capital distributions; 
• Allowing banking organizations to exclude certain assets related to non-recourse loans acquired through the Money Market Mutual Fund Liquidity Facility (MMLF);
• Granting banking organizations that implement the Accounting Standards Update No. 2016-13 prior to the end of 2020 the option to delay required reports related to current expected credit losses for two years, followed by a three-year transition period; and
• Permitting financial institutions to implement the Standardized Approach for Calculating the Exposure Amount of Derivative Contacts (SA-CCR) on a “best efforts” basis during the first quarter of 2020 if organizations follow additional terms listed in the interim final rule.  No changes were made to the mandatory compliance date of January 1, 2022.