Revisions to the Consolidated Reports of Condition and Income and Other Regulatory Reports

Summary:

The banking agencies, under the auspices of the Federal Financial Institutions Examination Council (FFIEC), have finalized revisions to the Consolidated Reports of Condition and Income (Call Report) and certain other FFIEC reports that primarily address changes in the accounting for credit losses under the Financial Accounting Standards Board's Accounting Standards Update (ASU) 2016-13. Other revisions to these reports result from the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA) and relate to the reporting of high volatility commercial real estate (HVCRE) exposures and reciprocal deposits. These revisions, which were issued for comment in September 2018, are subject to approval by the U.S. Office of Management and Budget.

Statement of Applicability to Institutions under $1 Billion in Total Assets: This Financial Institution Letter applies to all FDIC-supervised banks and savings associations, including community institutions.

Highlights:

• The changes related to credit loss reporting affect all three versions of the Call Report (FFIEC 031, FFIEC 041, and FFIEC 051), as well as the following FFIEC reports that are applicable to a limited number of institutions:
  • Foreign Branch Report of Condition (FFIEC 030),
  • Abbreviated Foreign Branch Report of Condition (FFIEC 030S), and
  • Regulatory Capital Reporting for Institutions Subject to the Advanced Capital Adequacy Framework (FFIEC 101).
• The changes to the Call Report and the FFIEC 101 report implement the agencies' recent revisions to the regulatory capital rules for the current expected credit losses (CECL) methodology in ASU 2016-13, including a CECL regulatory capital transition.
• Because ASU 2016-13 has different effective dates for different institutions, the reporting changes related to credit losses will be phased in between March 31, 2019, and December 31, 2022.
• The reporting changes involving the reporting of HVCRE exposures and reciprocal deposits arise from two sections of EGRRCPA that were effective upon enactment on May 24, 2018. As a consequence, these changes affected reporting in the Call Report and the FFIEC 101 report beginning as of the June 30, 2018, report date.
• Redlined copies of the FFIEC report forms showing the reporting changes related to credit losses are available on the report forms webpage on the FFIEC's website.
• The agencies currently are considering the comments received on a separate proposal to implement Section 205 of EGRRCPA on reduced reporting for covered institutions in the Call Report (see FIL 74-2018, dated November 19, 2018). Although the proposal included revisions to the FFIEC 051 reporting requirements that were proposed to take effect March 31, 2019, these reporting changes, if finalized, would take effect no earlier than June 30, 2019.

Distribution:

• FDIC-Supervised Institutions

Suggested Routing:

• Chief Financial Officer
• Chief Accounting Officer
• Call Report Preparer

Paper copies may be obtained via the FDIC's Public Information Center, 3501 Fairfax Drive, E 1002, Arlington, VA 22226 (877-275-3342 or 703-562-2200).