BPI and IIB Comment on Banking Agencies’ Proposed Call Report Revisions

To Whom It May Concern:

The Bank Policy Institute and the Institute of International Bankers (together, the Associations)1 welcome the opportunity to respond to the joint notice and request for comment by the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency regarding revisions to the Consolidated Reports of Condition and Income (Call Reports).2 The Associations are generally supportive of the proposed new Call Report line item related to the Standardized Approach for Counterparty Credit Risk final rule; however, we urge the agencies not to proceed with the proposed revisions that would establish requirements for tax allocation agreements between institutions and their holding companies in a consolidated tax filing group.3

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[1] See Appendix A for descriptions of the Associations.

[2] 86 Fed. Reg. 38810 (July 22, 2021).

[3] 86 Fed. Reg. 24755 (May 10, 2021) (hereafter the Tax Allocation Agreement NPR).