On February 24, BPI submitted a comment letter to the Fed, OCC, and FDIC responding to recently finalized reporting revisions to the Call Reports and the FFIEC 101. The letter encourages the agencies to allow Category I and II banks to use the standardized approach for counterparty credit risk (SA-CCR) methodology for Schedule RC-O Memorandum items 14 and 15 after they have adopted SA-CCR for the calculation of risk-weighted assets and total leverage exposure, and recommends that any clarification to the instructions related to the reporting and calculation of counterparty exposures be subject to a separate notice and comment process. Additionally, the letter requests that the agencies continue to allow notional reporting in the Call Report based on the contractual notional consistent with current practice, instead of a “SA-CCR notional” or adjusted notional.
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