Letter to the FFIEC on the Call Report and the 002 Report Changes

To Whom It May Concern:

The American Bankers Association (ABA) welcomes the opportunity to comment on the joint Notice of Proposed Rulemaking (the Proposal) by the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (Banking Agencies) on Federal Financial Institutions Examination Council's (FFIEC) revisions 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, data provided in Call Reports serve as a foundation for other required regulatory reporting.

The Proposal would make revisions to expand and add several disclosures related to loans to and other receivables from non-depository financial institutions (NDFIs). It adds a requirement to disclose amounts for the consolidated bank that are currently only reported for domestic offices. The Proposal clarifies that margin loans are included in loans for purchasing or carrying securities and it requires a disaggregation of loans to NDFIs in the following categories of NDFIs:

• Loans to mortgage credit intermediaries
• Loans to business credit intermediaries
• Loans to private equity funds
• Loans to consumer credit intermediaries
• Other loans to nondepository financial institutions

The effective date in the Proposal will be for Call Reports for the June 30, 2024 reporting date.

Download the comment letter to read the full text.