Proposed Electronic Filing
Requirement for Call Reports
The Federal Reserve Board, the Federal Deposit
Insurance Corporation, and the Office of the
Comptroller of the Currency request your comments
on a proposal to discontinue their acceptance
of Reports of Condition and Income (Call Reports)
that banks file directly with them in hard copy
(paper) form. Under the proposal, the agencies
would, instead, accept only those Call Reports
filed with the agencies' electronic collection
agent, Electronic Data Systems Corporation (EDS).
The agencies would implement the new filing
practice during 1997, based on bank size. A
copy of the Federal Register notice explaining
this proposal is attached.
A bank could satisfy this proposed filing
requirement in one of two ways:
By using computer software to prepare its
reports in automated form. The bank would
then file the reports directly with EDS by
using a computer and modem or by sending EDS
a computer diskette.
By completing its reports in hard copy
(paper) form and arranging with a third party,
such as a Call Report software vendor, to
convert its paper reports to automated form
and file the reports with EDS.
The agencies are proposing to phase out accepting
hard copy (paper) Call Reports that banks file
directly with them according to the following
timetable:
Beginning June 30, 1997, banks with assets
of $50 million or more as of June 30, 1996,
will be required to file, or arrange for a
third party to file, their Call Reports electronically
or on computer diskette with EDS.
Beginning September 30, 1997, banks with
assets of $25 million or more as of June 30,
1996, will be required to file, or arrange
for a third party to file, their Call Reports
electronically or on computer diskette with
EDS.
Beginning December 31, 1997, all banks
will be required to file, or arrange for a
third party to file, their Call Reports electronically
or on computer diskette with EDS.
Currently, over 75 percent of all banks purchase
and use Call Report software, and more than
two-thirds of these banks submit their reports
to EDS electronically or on diskette. Significant
declines in the cost of computers and telephone
modems in recent years have made this equipment
affordable and cost-effective for even the smallest
financial institutions. The annual cost of Call
Report software for personal computers starts
at approximately $200 for small banks and the
software operates effectively on any 286 or
higher personal computer with a hard drive.
No formal computer training is necessary to
operate Call Report software. Banks have generally
found that the instruction manuals for the Call
Report software and the customer support help
desks operated by the software vendors provide
all the assistance necessary for their use of
the software. Call Report software vendors are
identified in the Federal Register notice.
The agencies have provided the Call Report
software companies with a significant number
of edits that the agencies normally use for
validating the Call Report information. As a
result, while each bank is responsible for the
quality of its Call Report data, a bank using
a commercial software package is able to correct
errors identified by the software prior to filing
the Call Report, and provide better quality
data to the agencies. This procedure saves a
bank time by reducing agency inquiries for data
correction after the Call Report has been filed.
The software also provides immediate confirmation
to a bank filing electronically that EDS has
received its Call Report. Thus, electronic submission
promotes the accuracy of Call Report data, and
speeds its receipt and processing.
Comments are invited on the proposed electronic
filing requirement from both users and nonusers
of Call Report software and the electronic filing
method. In particular, respondents are requested
to comment on the automated collection process
as a way to minimize the burden of preparing
and filing Call Reports, any initial implementation
costs to banks, and ongoing costs to banks after
initial implementation.
The Federal Register notice also requests
comment on whether the agencies should consider
discontinuing their acceptance of other hard
copy (paper) reports and, instead, accept only
reports that are filed electronically or on
computer diskette. These reports include:
the Annual Report of Trust Assets (form
FFIEC 001), which is filed annually as of
December 31 by insured depository institutions
with trust powers and nondeposit trust companies;
and
the Summary of Deposits, which is filed
annually as of June 30 by each bank with more
than one office.
Comments on the proposal should be submitted
by January 3, 1997, to any or all of the banking
agencies at the addresses listed in the attached
notice. For further information about this proposal,
national and FDIC-supervised banks should contact
Ms. Massie G. Nyman of the FDIC at (800) 688-3342,
extension 86590, or (202) 898-6590. State member
banks should contact Ms. Christine A. Reid of
the Federal Reserve Board at (202) 452-3485.
Distribution: Insured Commercial Banks and
FDIC-Supervised Savings Banks
Note: Paper copies of FDIC financial institution
letters may be obtained through the FDIC's Public
Information Center, 801 17th Street, N.W., Room
100, Washington, D.C. 20434 ((703) 562-2200)
