On December 3, BPI submitted a comment letter to the Fed, OCC, and FDIC responding to proposed reporting revisions to the Call Reports and the FFIEC 101 (reporting of risk-weighted assets under the advanced approaches). The letter does not support adoption as proposed of the expansion in the scope of the Call Report for insured depository institution subsidiaries or the proposed change in reporting of home equity lines of credit that convert from revolving to non-revolving status in view of the potential significant operational challenges associated with these proposed changes. The letter encourages the agencies to eliminate supplementary leverage ratio data reporting tables from the FFIEC 101 and to provide an eighteen-month implementation period for the proposed reporting changes to the Call Reports related to the Total Loss Absorbing Capacity Holdings rule.
You Might Also Be Interested In...
Cybersecurity Financial Trades Call for Accessible, Functional and Simple Cyber Incident Reporting Rules
Security BPI Comments on NYDFS Proposal on Cybersecurity Requirements for Financial Services Companies
Regulatory Reporting and Accounting BPI Comments to Banking Agencies on Reporting of Notional Pool Balances on Schedule RC-O of the Call Reports
Regulatory Reporting and Accounting BPI and IIB Comment on Federal Reserve Proposal to Revise FR Y-7Q Capital and Asset Report for Foreign Bank Organizations
Regulatory Reporting and Accounting BPI Comments on Fed Proposal to Revise Structure Reporting and Recordkeeping Requirements for Domestic and Foreign Banking Organizations
More Posts by This Author
Bank Liquidity Why Regulators Should Consider Banks’ Borrowing Capacity from the Fed in Liquidity Assessments