Call Report for Banks - Recent Changes, Highlights, and Pitfalls
In January, 2017, the Agencies announced the approval of a new FFIEC 051 form effective with the March, 2017 call report. For domestic banks with less than $1 billion in assets the new 051 form will reduce the number of pages in the call report from 85 to 60 and eliminate 40% of the existing line items. The frequency of data collection is also reduced for some of the schedules.
In July, 2016, the Agencies finalized the changes to the March, 2017 and September, 2016 Call Reports. The revisions include burden-reducing changes, as well as revised items, and a couple of instructional changes. The most significant change is the increase in the CD deposit threshold from $100,000 to $250,000, which will be effective with the March, 2017 Call Report.
Basel III risk-based capital changes became effective with the first call report filing in 2015. The line items related to the Capital Conservation Buffer were required for the first time in March, 2016. We'll review clarifications on the risk reporting of loan categories, deferred tax assets, equity securities, unused commitments, and interest rate locks.
2016/2017 Approved Revisions:
- New FFIEC 051 form for banks with assets of less than $1 billion
- Increase in the deposit size threshold used to report certain deposit information from $100,000 to $250,000 in RC-E, RI, and RC-K (March, 2017)
- Elimination of items on certain restructured loans, certain assets covered by loss sharing agreements
- Increase in reporting thresholds on RI-E, RC-D, RC-F, RC-G, RC-Q
- Additional contact information for CEO
- Additional preprinted captions in RC-F and RI-E
- Revision of statements used to describe audit work on RC
- Deletion of RI 11, extraordinary items
- Instruction update on reporting of net gains/losses and OTTI on equity securities that do not have readily determinable fair values
- Elimination of certain items on Other than temporary impairment
Risk Based Capital Clarifications:
Who Should Attend
- loan categories
- deferred tax assets
- equity securities
- unused commitments
- interest rate locks
This update will benefit more experienced Call Report preparers, reviewers, and auditors. It will supplement annual comprehensive Call Report training recommended by bank regulators.
Ann Thomas has thirty years of experience in bank accounting and control. She received a BA in Accounting from the University of Houston in 1982. From 1982 through 1997 she worked with Judith Alexander Jenkins, as Alexander & Associates and subsequently Alexander & Leavelle, providing planning, financial reporting, regulatory reporting, and operational and compliance auditing services to over ninety independent banks.
In 1998, she organized Thomas Consulting. At Thomas Consulting she now prepares bank plans, monthly financial reports, performs regulatory compliance audits and training and internal control audits for several banks. Additionally, she prepares and reviews Call Reports for several banks. Ms. Thomas has taught numerous call report seminars for state banking associations.
She has presented the Call Report Seminar to and has responded to questions from thousands of bankers in over 16 states. Her experience in working with a broad range of independent financial institutions is of unique value in understanding Call Report questions and in communicating with bankers in their language.
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