To Whom it May Concern:
The Bank Policy Institute 1 welcomes the opportunity to comment on the proposal by the Board of Governors of the Federal Reserve System to revise the Financial Statements for Holding Companies (FR Y-9 reports; OMB Control Number 7100-0128) and the Consolidated Report of Condition and Income for Edge and Agreement Corporations (FR 2886b; OMB Control Number 7100-0086).2
BPI appreciates the Federal Reserve’s efforts to eliminate ambiguity in reporting and to resolve issues stemming from the temporary revisions to the FR Y-9C and FR 2886b that were previously implemented underemergency approval from the U.S. Office of Management and Budget.3 Consistent with our recent comment letters on the proposed revisions to the Call Reports and the FR 2900, FR 2910a, FR 2915, FR 2930,4 our letter on the FR Y-9C and FR 2886b highlights a few areas that require further clarification from the Federal Reserve, primarily regarding the proposed revisions that would implement the Federal Reserve’s amendments to Regulation D, which remove the numeric limits on monthly transfers and withdrawals from the definition of “savings deposits” (Regulation D IFR).5 A number of the recommendations outlined in this letter would also align with further proposed revisions to the Call Report contained in the recent Joint notice and request for comment by the agencies (Call Report Joint Notice).6 In addition, we also include recommendations regarding the Proposed Revisions Related to U.S. GAAP contained in the Current Proposal.
To read the full comment letter, click here, or click on the download button below.
[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. 63553 (October 8, 2020) (hereafter, the “Current Proposal”).
[3]See Board of Governors of the Federal Reserve System, June 2020 COVID-19 Related Supplemental Instructions (FR Y-9C report), available at https://www.federalreserve.gov/reportforms/supplemental/Final_Revised_Combined%20FR%20Y-9C%201Q2020%20and%202Q2020%20COVID-19%20Related%20Supplemental%20Instructions.pdf.
[4]See the Bank Policy Institute Letter re: Call Report, FFIEC 101, and FFIEC 002 Revisions (September 21, 2020), available at https://bpi.com/wp-content/uploads/2020/09/BPI-Comment-Letter-re-Call-Report- FFIEC-101-and-FFIEC-002-Revisions-9-21-2020.pdf; and The Bank Policy Institute Letter re: Revisions to the Reports of Deposits: Report of Transaction Accounts, Other Deposits, and Vault Cash; Annual Report of Deposits and Reservable Liabilities; Report of Foreign (Non-U.S.) Currency Deposits; and Allocation of
Low Reserve Tranche and Reservable Liabilities Exemption (October 30, 2020) (collectively, the “BPI Reg D Reporting Letters”).
[5] 85 Fed. Reg. 23445 (April 28, 2020).
[6] See 85 Fed. Reg. 74784 (November 23, 2020).
