BPI Comments on Banking Agencies’ Revisions to Foreign Bank Branch Reporting

To Whom It May Concern:

The Bank Policy Institute [1] welcomes 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 Foreign Branch Report of Condition (FFIEC 030) and the Abbreviated Foreign Branch Report of Condition (FFIEC 030S).[2] BPI is supportive of the determination that “the [FR 2502q] data could instead be effectively collected through the FR 2314 and FFIEC 030.” [3] However, we have concerns that the current proposal would serve to significantly increase the burden on covered entities both for initial implementation and also on an ongoing basis. This would be contrary to the proposal’s determination that integrating the FR 2502q items into the FR 2314 and FFIEC 030 “would reduce overall respondent burden.”[4]

Our comments herein are aimed at aligning the scope of entities that would be required to provide the proposed new items on Schedule RAL-A of the FFIEC 030 with those currently subject to reporting on the FR 2502q, and to seek clarifications on proposed Schedule RAL-A line items 5 and 6. Additionally, to the extent the Agencies implement the proposed changes and maintain the proposed reporting scope, given the significance of the changes required and the operational challenges presented, we respectfully request a delayed effective date of at least four quarters following the issuance of final forms and instructions. If the Agencies were to limit the respondents for proposed Schedule RAL-A to those who meet the current requirements for reporting on the FR 2502q, firms would only need two additional quarters to implement these revisions, as further explained herein.

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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] 89 Fed. Reg. 3708.

[3] 89 Fed. Reg. 3708 at 3710.

[4] Id.