In a letter to bank CEOs last night, the federal banking agencies restated that they would not take action against institutions that submit their March 31, 2020, Call Report after the filing deadline, provided that the report is submitted within 30 days of the original filing date. The agencies encouraged banks to contact their primary regulator if they anticipate a delayed filing. The filing date for the Call Report—except for certain institutions with foreign offices—is April 30.
The agencies said they are working to update the Call Report instruction books to reflect the community bank leverage ratio rule and the capital simplification rule, which took effect January 1. Additionally, the recent CARES Act changes providing relief to banks as a result of the coronavirus will also be applied to the Call Reports for March 31, 2020.
These changes include a revised definition of eligible retained income in the capital rule; permission for banks to neutralize the effects of purchasing assets through the Money Market Mutual Fund Liquidity Facility on their risk-based and leverage capital ratios; an optional delay of CECL effects on regulatory capital; and an optional early implementation of the standardized approach for calculating the exposure amount of derivatives, or SA-CCR.