Home > Regulation & Examinations >
Laws & Regulations > FDIC
Federal Register Citations |
|||
FDIC Federal Register Citations Spiro State Bank
From: Ty Barrett [mailto:spstbank@ipa.net]
Sent: Wednesday, September 28, 2005 10:38 AM To: Comments Subject: Consolidated Reports of Condition and Income, 3064-0052 From: This email is to serve as our comment to the "Proposed Revisions to the
Reports of Condition and Income (Call Report)", as discussed in FIL
-86-2005. I have several years of experience dealing with Call Report
preparation. First as a bank examiner with the OCC, and second as
preparing call reports for a 50 million dollar community bank. I will say
that any revisions to reduce the call report burden on community banks is
greatly needed. The call report has become burdensome for small banks as
it has expanded to 42 reportable pages and hundreds of pages of
instructions. The call report now takes me and my staff approximately one
week to prepare at quarter end. That is one month a year spent preparing a
call report in a small community bank. With expanding consolidation in the banking industry bringing on the
era of "Mega-Banks" such as Morgan Chase and Citigroup, small community
banks under 250 million represent miniscule risk to the banking industry
and the FDIC insurance fund. However, there seems to be a constant need
for more information that will not lead to meaningful regulatory scrutiny
in small community banks. For example, take the proposed revisions to further breakdown
construction and land development loans. This may seem like a simple item
to break down. But it would require most community banks to revisit all of
these loans in their bank and assign additional codes to them so that at
the end of the quarter our computer systems could produce this line item
for a call report. When if you looked at the risk in the community banking
group of bank's less than 250 million that information is probably
insignificant. Several years ago there were different call reports and different
instructions for banks based on size and complexity. Even further back,
banks only had to submit their balance sheet and income statement
information quarterly. Let the regional and mega-banks, where the risk
lies, provide you expanded call report information if needed. But any
expansion to the call report for small community banks is unwarranted
unless it is truly meaningful. Ask community bank examiners in the field what information on the call
report and the UPBR is really important to them in accessing the risk in
small community banks and I think policy makers would be surprised by how
much call reports could be scaled back. Sincerely Ty Barrett
|
||
Last Updated 09/28/2005 | Regs@fdic.gov |