The American Bankers Association recommended that banking agencies make several changes to their proposed revisions of the Federal Financial Institutions Examination Council reports—including the Call Report—such as pushing back the effective date of the revisions.
The Federal Reserve, FDIC and Office of the Comptroller of the Currency in January proposed to expand and add several disclosures to the reports related to loans and other receivables from non-depository financial institutions. The proposal would add a requirement to disclose amounts for the consolidated bank that are currently only reported for domestic offices. It also would clarify that margin loans are included in loans for purchasing or carrying securities, and would require a disaggregation of loans to non-depository institutions in categories such as loans to mortgage credit intermediaries and private equity funds.
In its comments, ABA said the June 30 effective date for the revisions is not enough time for compliance, as such changes typically take six to nine months to implement. The association also said the proposal needs more clarity regarding which loans are to be included as “other loans” to non-depository institutions for reporting purposes.
