TO: CHIEF EXECUTIVE OFFICER (also of interest to the Chief Financial Officer)
SUBJECT: Revisions to the Consolidated Reports of Condition and Income (Call Reports) and the FFIEC 002 Report
On May 22, 2024, the Federal Deposit Insurance Corporation (FDIC), the Board of Governors of the Federal Reserve System (Board), and the Office of the Comptroller of the Currency (collectively, the agencies), under the auspices of the Federal Financial Institutions Examination Council (FFIEC), published the attached final regulatory reporting changes in the Federal Register. These reporting changes proposed by the agencies on September 28, 2023 (see FIL-53-2023) and December 27, 2023 (see FIL-68-2023), would apply to all three versions of the Call Report (FFIEC 031, FFIEC 041, and FFIEC 051) and to the Report of Assets and Liabilities of U.S. Branches and Agencies of Foreign Banks (FFIEC 002), as applicable, and are subject to approval by the U.S. Office of Management and Budget.
In the September 2023 notice, the agencies proposed revisions to all three versions of the Call Report (FFIEC 031, FFIEC 041 and FFIEC 051) and the Board proposed revisions, as applicable, to the FFIEC 002 related to the Financial Accounting Standards Board’s (FASB) Accounting Standards Update (ASU) 2022-02, “Financial Instruments—Credit Losses (Topic 326): Troubled Debt Restructurings and Vintage Disclosures” (ASU 2022-02), reporting on internet website addresses of depository institution trade names, and reporting on past due loans. In the December 2023 notice, the agencies proposed revisions to all three versions of the Call Report (FFIEC 031, FFIEC 041 and FFIEC 051) and the Board proposed revisions, as applicable, to the FFIEC 002 related to the reporting of loans to nondepository financial institutions (NDFIs) and other loans, guaranteed structured financial products, and proposed long-term debt requirements. In addition, this notice included a proposal to adopt ongoing standards for electronic signatures to comply with the Call Report signature and attestation requirement.
After considering the comments received on these notices, the agencies are moving forward with certain proposed revisions related to replacing references to “troubled debt restructurings” with “modifications to borrowers experiencing financial difficulty” consistent with ASU 2022-02, the reporting on the internet website addresses of depository institution trade names, and the adoption of the standards for electronic signatures. These updates to the Call Report and FFIEC 002 report forms and instructions will be effective as of the June 30, 2024, report date.
The agencies are implementing revisions related to reporting of loans to NDFIs as of the December 31, 2024, report date. The agencies are also adding a new Memorandum item that would identify the amounts reported as a structured financial product that are guaranteed by U.S. Government agencies or sponsored agencies, which would be effective as of the December 31, 2024, report date.
The agencies are continuing to review comment letters related to loan modifications to borrowers experiencing financial difficulty under ASU 2022-02, as well as the proposed clarification on the reporting of past due loans and proposed reporting of long-term debt requirements, for further changes to the Call Report and the FFIEC 002.
The agencies encourage you to review the proposed regulatory reporting revisions and comment on those aspects of interest to you. You may send comments on this reporting proposal to any or all of the agencies by the methods described in the attached Federal Register notice. Comments must be submitted by June 21, 2024.
Redlined copies of the FFIEC 031, FFIEC 041, and FFIEC 051 Call Report forms and the FFIEC 002 report form showing the proposed changes and the related draft reporting instructions will be available on the FFIEC’s webpages for these reports, which can be accessed from the FFIEC’s Reporting Forms webpage.
Please share this letter with individuals responsible for preparing Call Reports at your institution. For further information about the proposed Call Report changes, institutions should contact their assigned Call Report analyst. If you do not know the analyst assigned to your institution, state member institutions should contact their Federal Reserve District Bank, while national institutions, FDIC-supervised banks, and savings associations should contact the FDIC’s Data Collection and Analysis Section in Washington, D.C., by telephone at (800) 688‑FDIC (3342) or email to FDICInfoReq@fdic.gov.
signed by
Judith E. Dupré
Executive Secretary
Distribution: FDIC-Supervised Banks and Savings Institutions, National Institutions, State Member Institutions, and Savings Associations