To Whom It May Concern:
The Bank Policy Institute1 welcomes the opportunity to comment on the Proposal by the Board of Governors of the Federal Reserve System to revise 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 (FR 2900, FR 2910a, FR 2915, FR 2930; OMB No. 7100–0087).2
BPI appreciates the Federal Reserve’s continued efforts to streamline reporting and to “reduce reporting burden associated with reserve requirements.”3 Specifically, we support the Federal Reserve’s proposed elimination of the quarterly FR 2900 reporting, as well as the proposed discontinuation of the collection of the FR 2910a and FR 2930. However, the proposed revisions to the FR 2900 may not have the intended significant impact on reducing reporting burden for firms, as firms will still need to track some of the relevant data for the remaining fields. For example, while the Federal Reserve has proposed to remove line items A.1.a “Demand deposits: Due to depository institutions” and A.1.b “Demand deposits: Of U.S. Government” from the FR 2900 weekly reporting, firms will still be required to track the relevant data for these line items in order to segment out and produce the required data for the revised weekly Line item A.1 “Demand deposits due to the public.” Additionally, this data would also be required for the proposed annual line item E.1.a. “Net Transaction Accounts.” While the reorganization and reduction in frequency of certain FR 2900 reporting is well intentioned and appreciated, firms will still be faced with the operational burden of tracking a number of these data items proposed for deletion for the purposes of the remaining items in the revised FR 2900.
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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. 54577 (September 2, 2020).
[3] Board of Governors of the Federal Reserve System, Supporting Statement for 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 (FR 2900, FR 2910a, FR 2915, and FR 2930; OMB No. 7100-0087) at page 8, available at https://www.federalreserve.gov/reportforms/formsreview/FR%202900%20OMB%20SS.pdf
