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.
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