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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:
Spiro State Bank
Spiro, Oklahoma

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
Vice President
Spiro State Bank
918-962-2453



Last Updated 09/28/2005 Regs@fdic.gov

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