ABA Letter to the Agencies on Call Report Changes Related to Regulatory Capital Standards

The American Bankers Association (ABA) appreciates the opportunity to comment on the Notice of Proposed Rulemaking for Call Report and FFIEC 101 Reporting Revisions (the Proposal) to modify FFIEC Forms 031, 041, and 051, commonly referred to as the Consolidated Reports of Condition and Income (the Call Report). The Call Report provides data on individual banks, allows for trend analysis of bank condition and trend information about the overall banking industry, and serves as the basis for other reporting and policy analysis. Additionally, the data provided in the Call Reports serve as a foundation for other required regulatory reporting. The Proposal would make revisions to implement various changes to the agencies’ capital rule that the agencies have finalized or are considering finalizing.

With respect to the specific changes articulated in the proposal, ABA opposes the clarification to state that revolving open-end lines of credit that have converted to non-revolving closed-end status should be reported as closed-end loans. As discussed more fully below, we have identified 4 additional items that may benefit from clarification, that appear inconsistent with other items, or that we believe are minor errors.