ABA Comments on Proposed Reporting Changes for Billion-Dollar BHCs

In a letter on Monday, ABA and the Clearing House commented on the Federal Reserve’s proposed changes to the FR Y-9C financial report that bank holding companies with more than $1 billion in assets are required to file quarterly. While the groups generally supported the proposed changes — which are nearly identical to those proposed for the Call Report — they raised concerns about the short timeframe given for banks to implement changes, as well as the income and non-income line items included in the report.

The letter pointed out that the changes do not seek to modify the deposit thresholds in Schedule HI or revise the impact of trading revenues of credit/debit valuation and adjustments to reflect the proposed changes to the Call Report, which could create confusion and force banks to maintain separate reporting systems. The groups urged the Fed to maintain consistency in the deposit insurance thresholds across all reports and to extend the implementation timeline to allow institutions more time to prepare for the changes.  For more information, contact ABA’s Alison Touhey.