In a comment letter today, the American Bankers Association welcomed the banking agencies’ most recent proposal to revise and streamline the Call Report and offered additional recommendations for improvements. Specifically, ABA urged the agencies to align the revised Call Report with other required regulatory reports, raise the threshold for the short-form Call Report from $1 billion in assets to $10 billion, establish an industry advisory committee, allow sufficient time for banks to implement future reporting changes and enhance the training process for revisions.
“We acknowledge and appreciate the [Federal Financial Institutions Examination Council]’s work to relieve the burden on Call Report filing and specifically note the FFIEC’s creation of a small bank report, release of the results of the interagency surveys, and efforts to make the instructions more clear,” ABA said. “We strongly support the FFIEC’s ongoing work to reform the Call Report, an ongoing project that is yielding important value for supervision as well as for successful bank management. This has been a model reform process.”