To Whom it May Concern:
The Bank Policy Institute[1] welcomes the opportunity to respond to the joint request for information and 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 sources of regulatory reporting burden for institutions that file the Consolidated Reports of Condition and Income (Call Report) (FFIEC 031, FFIEC 041, and FFIEC 051) and ways that the agencies could streamline the Call Report forms and instructions.[2] The RFI states that the agencies are reviewing the data collected in the Call Report to “reduce or eliminate any items (other than those required by law) the agencies determine are no longer necessary or appropriate (statutory review).” It further states that the agencies “are seeking input on ways to streamline the Call Report to better align with the size and complexity of the reporting institution.” BPI strongly supports these goals and the agencies’ current efforts to minimize the reporting burden of the Call Report system for respondent firms. As the RFI accurately observes, Call Report preparation is not a fully automated process and often requires significant manual efforts from banks to complete the required reporting.
The Call Report collects important data that is used by the agencies to monitor the condition, performance and risk profile of individual institutions and the broader industry. Some of the data collected is essential for the agencies to fulfill their missions of ensuring the safety and soundness of the financial system. However, as recently stated in a speech by Federal Reserve Vice Chair for Supervision Michelle Bowman discussing regulatory reports such as the Call Report, “[o]ften, regulators and supervisors do not review the information and data that is submitted.”[3] Vice Chair Bowman also recently stated that the Federal Reserve initiated “a review of regulatory reporting requirements to ensure the data … collect[ed] are useful and necessary for supervisory and regulatory purposes.”[4] Given the Federal Reserve’s stated objective of strengthening supervision by focusing on “the most important risks threatening the safety and soundness of banking organizations”[5] and recent actions taken by the other agencies to similarly focus on the most material risks,[6] the Call Report presents a key area for reform and enhancement. We commend the agencies for initiating this review and welcome the opportunity to engage further during this process.
BPI welcomes the agencies’ focus on issues that present core financial risks and recent actions such as the current RFI to include the area of regulatory reporting within the agencies’ review. We encourage the agencies to conduct a holistic review of regulatory reporting requirements with an aim to minimize burden for firms, including by removing duplicative reporting requirements, reducing granular reporting requirements, aligning reporting requirements across forms, and eliminating any reporting requirements that are not used by the agencies to conduct supervision of material risk to the financial system. Regarding any newly proposed items for data collection across regulatory reports, the agencies should endeavor to provide respondents and the public with clear, concrete explanations and supporting justifications, including how each data element contributes to the effective supervision and monitoring of material financial risks.
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[1] The Bank Policy Institute is a nonpartisan public policy, research and advocacy group that represents universal banks, regional banks, and the major foreign banks doing business in the United States. The Institute produces academic research and analysis on regulatory and monetary policy topics, analyzes and comments on proposed regulations, and represents the financial services industry with respect to cybersecurity, fraud, and other information security issues.
[2] 90 Fed. Reg. 55240.
[3] Speech by Federal Reserve Vice Chair for Supervision Michelle W. Bowman at the California Bankers Association Bank Presidents Seminar, re: Modernizing Supervision and Regulation: 2025 and the Path Ahead (Jan. 7, 2026), available at: https://www.federalreserve.gov/newsevents/speech/bowman20260107a.htm.
[4] Speech by Federal Reserve Vice Chair for Supervision Michelle W. Bowman at Outlook 26: The New England Economic Forum (Jan. 16, 2026), available at: https://www.federalreserve.gov/newsevents/speech/bowman20260116a.htm.
[5] Mary Aiken (Acting Director) and Julie Williams (Acting Deputy Director), Board of Governors of the Federal Reserve System, Division of Supervision and Regulation, re: Statement of Supervisory Operating Principles (Oct. 29, 2025), available at: https://www.federalreserve.gov/newsevents/pressreleases/files/bcreg20251118a1.pdf.
[6] 90 Fed. Reg. 48835. (OCC and FDIC notice of proposed rulemaking to define the term “unsafe or unsound practice” and revise the supervisory framework for the issuance of matters requiring attention and other supervisory communications.)
