BPI Supports Call Report Revisions to Improve Securities Reporting Consistency

To Whom It May Concern:

The Bank Policy Institute[1] welcomes the opportunity to respond to the joint notice and request for comment 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) and Report of Assets and Liabilities of U.S. Branches and Agencies of Foreign Banks (FFIEC 002).[2]

BPI is supportive of the purpose of the proposed revisions to the Call Reports in improving the consistency of reporting of nondepository financial institution (“NDFI”) exposures and guaranteed structured financial products. Additionally, we are supportive of the proposed revisions to these forms which would adopt ongoing standards for electronic signatures to comply with the Call Report signature and attestation requirement. Our comments herein are aimed at suggesting further enhancements that would be beneficial with respect to the reporting of non-purpose loans secured by securities (“non-purpose loans”) and loans for purchasing or carrying securities, as well as to highlight certain necessary clarifications. Considering the significance of the changes required by the proposed revisions and the significant operational challenge presented as described in more detail in Section VI, we respectfully request a delayed effective date of at least four quarters following the issuance of final forms and instructions to allow firms adequate time to develop and test the necessary systems and governance and controls frameworks to implement these changes.

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

[1] BPI is a nonpartisan public policy, research, and advocacy group, representing the nation’s leading banks and their customers. BPI’s members include universal banks, regional banks, and major foreign banks doing business in the United States. Collectively, they employ almost two million Americans, make nearly half of the nation’s small business loans, and are an engine for financial innovation and economic growth.

[2] 88 Fed. Reg. 89489.