BPI, SIFMA and ABA Comment on Proposal by Banking Agencies on Call Report and FFIEC 002 Deposit-Related Revisions

To Whom it May Concern:

The Bank Policy Institute, the Securities Industry and Financial Markets Association, and the American Bankers Association (collectively, the Associations)[1] welcome the opportunity to comment on the proposal 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 Consolidated Reports of Condition and Income (Call Reports) (FFIEC 031, FFIEC 041, and FFIEC 051).[2] The Associations understand the agencies’ need to evaluate the behavior of sweep accounts in order to determine their appropriate treatment under liquidity regulations and are generally supportive of the agencies’ further research into and analysis of funding stability and the behavior of bank counterparties over time.

However, firms have concerns with the proposed new reporting items, specifically that the revisions are duplicative of existing reporting requirements for many firms, as well as the proposed implementation timeline. Our other comments herein highlight areas of the proposal related to the reporting treatment of certain deposits consistent with changes in the brokered deposits final rule[3] and definitions that require further clarification from the agencies.

To read the full comment letter, click here, or click on the download button below.

[1]  See Appendix 1 for a description of the Associations.

[2]  86 Fed. Reg. 8480 (February 5, 2021).

[3]  86 Fed. Reg. 6742 (January 22, 2021) (hereafter, the Brokered Deposits Final Rule).