BPI Submits Letter on Fed, FFIEC Call Report and FR Y-9C Supplemental Reporting Instructions for Operating Lease Liabilities

On June 26, BPI submitted a letter to the three banking agencies with respect to the Supplemental Reporting Instructions issued by the Fed and Federal Financial Institutions Examination Council (FFIEC) in March regarding reporting of operating lease liabilities under the new accounting standard effective January 1. Arguing that operating lease liabilities should not be reported as secured borrowings under existing regulatory reporting definitions of those terms and that the FFIEC’s interpretation would result in higher FDIC assessments for banks of all sizes, the letter urges the agencies to withdraw the instructions and reissue them for public notice and comment with the clarification that operating lease liabilities should be reported as unsecured borrowings.