The Clearing House (TCH), jointly with the ABA, submitted a comment letter to the FFIEC regarding proposed modifications to the Consolidated Reports of Condition and Income (the Call Report). The letter is very supportive of the FFIEC’s decision to accelerate the start of the next review of the Call Report and the FFIEC’s initiative to stream line the Call Report by better aligning it with recently implemented rules and standards. The comment letter specifically recommends that the FFIEC: (i) establish an industry advisory committee to provide the FFIEC with advice and guidance on issues related to FFIEC reports; (ii) work to ensure other required regulatory reporting forms are updated simultaneously; (iii) allow sufficient time for institutions to implement any reporting changes; (iv) release finalized instructional updates at least a quarter prior to implementation; and (v) provide enhanced, on-going, training opportunities both to introduce new line items as well as review those which were previously established.
You Might Also Be Interested In...
AML, Bank Secrecy Act and Sanctions BPI Submits Comment Letter to FinCEN Regarding AML Program Effectiveness
Bank Governance BPI Offers Recommendations to NY Financial Services Regulator on a Re-Proposed Regulation on Disclosure of Confidential Supervisory Information
Cybersecurity BPI Files Comment Letter with U.K. Banking Authorities in Response to Operational Resilience Proposals
Regulatory Reporting and Accounting BPI Submits Comment Letter to Banking Agencies on Revisions to Call Report
Consumer Affairs BPI Joins Joint Coalition Comment Letter Responding to CFPB NPR on General Qualified Mortgage Definition
More Posts by This Author
FinTech & Innovation FinTech and Big Tech Companies Want the Benefits of Banking Without the Responsibilities. Regulatory Loopholes Could Let Them Succeed.
COVID-19 Relief BPI and Joint Coalition Urge House and Senate Leadership to Address PPP Forgiveness Process
Bank Capital and Stress Testing The Farmer and the Seed Corn: Why Lowering the CCyB and Imposing Dividend Restrictions Are Opposites
AML, Bank Secrecy Act and Sanctions FinCEN Should Focus on Flexibility, Clarity and Coordination When Defining AML Effectiveness
COVID-19 Relief Loan Necessity Questionnaires -Borrower & Lender Coalition Letter to Congressional Leadership