BPI Comments on Banking Agencies’ Proposal to Revise Call Reports, FFIEC 101 and FFIEC 002

To Whom it May Concern:

The Bank Policy Institute1 welcomes the opportunity to comment on 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”), Regulatory Capital Reporting for Institutions Subject to the Advanced Capital Adequacy Framework, and the Report of Assets and Liabilities of U.S. Branches and Agencies of Foreign Banks.2

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[1] The Bank Policy Institute is a nonpartisan public policy, research and advocacy group, representing the nation’s leading banks and their customers. Our members include universal banks, regional banks and the major foreign banks doing business in the United States. Collectively, they employ almost 2 million Americans, make nearly half of the nation’s small business loans, and are an engine for financial innovation and economic growth.

[2] 85 Fed. Reg. 74784 (November 23, 2020) (hereafter, the “Joint Notice”).