BPI Comments on Banking Agencies’ Regulatory Reporting Proposal

Ladies and Gentlemen:

The Bank Policy Institute [1] appreciates the opportunity to comment on the joint proposal[2] issued by the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency that would amend the Consolidated Reports of Condition and Income (the “Call Report”), the Regulatory Capital Reporting for Institutions Subject to the Advanced Capital Adequacy Framework (the “FFIEC 101”), and the Market Risk Regulatory Report for Institutions Subject to the Market Risk Capital Rule (the “FFIEC 102”).[3] The Proposal broadly addresses aspects of the Call Report, FFIEC 101 and FFIEC 102 reporting forms that are intended to reflect the proposed revisions to the regulatory capital rules that the Agencies proposed in July 2023, commonly referred to as “Basel III Endgame,” which would amend the capital requirements applicable to large banks[4] and banks with significant trading activity.[5]

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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] FDIC, Federal Reserve, OCC, Proposed Agency Information Collection Activities; Comment Request, 89 Fed. Reg. 5,297 (Jan. 26, 2024).

[3] See Proposed Agency Information Collection Activities; Comment Request, 89 Fed. Reg. 5,297 (Jan. 26, 2024). This letter focuses in particular on the aspects of the Proposal relating to the regulatory capital numerator, credit risk, operational risk and other overarching issues. The comment letter on the Proposal submitted by the International Swaps and Derivatives Association, Inc. (“ISDA”) and the Securities Industry and Financial Markets Association (“SIFMA”) address other aspects of the Proposal. We support the recommendations from ISDA/SIFMA and urge the Agencies to implement our recommendations and those in the ISDA/SIFMA letter.

[4] In this letter, the term “bank” includes all banking organizations as defined in the Basel III Endgame proposal. See 88 Fed. Reg. at 64,030, note 1.

[5] See Regulatory Capital Rule: Large Banking Organizations and Banking Organizations With Significant Trading Activity, 88 Fed. Reg. 64,028 (Sept. 18, 2023).