FFIEC031_FFIEC041_20150203_omb

Supporting Statement for the
Consolidated Reports of Condition and Income
(FFIEC 031 and FFIEC 041; OMB No. 7100-0036)
Summary
The Board of Governors of the Federal Reserve System requests approval from the
Office of Management and Budget (OMB) to extend, with revision, the Federal Financial
Institutions Examination Council (FFIEC) Consolidated Reports of Condition and Income (Call
Reports) (FFIEC 031 and FFIEC 041; OMB No. 7100-0036). These data are required of state
member banks and are filed on a quarterly basis. The revisions to the Call Reports that are the
subject of this request have been approved by the FFIEC. The Federal Deposit Insurance
Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC) have also
submitted a similar request for OMB review to request this information from banks under their
supervision.
The Federal Reserve requires information collected on the Call Reports to fulfill its
statutory obligation to supervise state member banks. State member banks are required to file
both detailed schedules of assets, liabilities, and capital accounts in the form of a condition report
and summary statement as well as detailed schedules of operating income and expense, sources
and disposition of income, and changes in equity capital.
The Federal Reserve, the FDIC, and the OCC (the “agencies”) propose to revise for the
March 31, 2015, report date (1) the risk-weighted assets portion of Schedule RC-R, Regulatory
Capital, and (2) the line items related to securities lent and borrowed in Schedule RC-L,
Derivatives and Off-Balance Sheet Items. The current annual burden for the Call Reports is
estimated to be 195,415 hours and the proposed revisions are estimated to increase the annual
burden by 6,700 hours.
Background and Justification
Banks that are members of the Federal Reserve System are required by law to file reports
of condition with the Federal Reserve System. Section 9(6) of the Federal Reserve Act
(12 U.S.C. § 324) states:
... banks ... shall be required to make reports of condition and of the payment of dividends
to the Federal Reserve Bank of which they become a member. Not less than three of
such reports shall be made annually on call of the Federal Reserve Bank on dates to be
fixed by the Board of Governors of the Federal Reserve System. ...Such reports of
condition shall be in such form and shall contain such information as the Board of
Governors of the Federal Reserve System may require and shall be published by the
reporting banks in such manner and in accordance with such regulations as the said Board
may prescribe.
In discharging this statutory responsibility, the Board of Governors, acting in concert
with the other federal banking supervisory agencies since 1979 through the FFIEC, requires

banks to submit on the quarterly Reports of Condition and Income such financial data as are
needed by the Federal Reserve System to: (1) supervise and regulate banks through monitoring
of their financial condition, ensuring the continued safety of the public’s monies and the overall
soundness of the nation’s financial structure, and (2) contribute information needed for
background for the proper discharge of the Federal Reserve’s monetary policy responsibilities.
The use of the data is not limited to the federal government, but extends to state and local
governments, the banking industry, securities analysts, and the academic community.
Description of Information Collection
The Call Reports collect basic financial data from commercial banks in the form of a
balance sheet, income statement, and supporting schedules. The Report of Condition contains
supporting schedules that provide detail on assets, liabilities, and capital accounts. The Report of
Income contains supporting schedules that provide detail on income and expenses.
Within the Call Report information collection system as a whole, there are two reporting
forms that apply to different categories of banks: (1) all banks that have domestic and foreign
offices (FFIEC 031), and (2) banks with domestic offices only (FFIEC 041). Prior to March
2001, there were four categories of banks and four reporting forms. The FFIEC 031 was filed by
banks with domestic and foreign offices and the FFIEC 032, FFIEC 033, and FFIEC 034 were
filed by banks with domestic offices only and were filed according to the asset size of the bank.
There is no other series of reporting forms that collect from all commercial and savings
banks the information gathered through the Reports of Condition and Income. There are other
information collections that tend to duplicate certain parts of the Call Reports; however, the
information they provide would be of limited value as a replacement for the Call Reports. For
example, the Federal Reserve collects various data in connection with its measurement of
monetary aggregates, of bank credit, and of flow of funds. Reporting banks supply the Federal
Reserve with detailed information relating to such balance sheet accounts as balances due from
depository institutions, loans, and deposit liabilities. The Federal Reserve also collects financial
data from bank holding companies on a regular basis. Such data are presented for the holding
company on a consolidated basis, including its banking and nonbanking subsidiaries, and on a
parent company only basis.
However, Federal Reserve reporting forms from banks are frequently obtained on a
sample basis rather than from all insured banks. Moreover, these reporting forms are often
prepared as of dates other than the last business day of each quarter, which would seriously limit
their comparability. Institutions below a certain size are exempt entirely from some Federal
Reserve reporting requirements. Data collected from bank holding companies on a consolidated
basis reflect an aggregate amount for all subsidiaries within the organization, including banking
and nonbanking subsidiaries, so that the actual dollar amounts applicable to any bank subsidiary
are not determinable from the holding company reporting forms. Hence, these reporting forms
could not be a viable replacement for even a significant portion of the Call Reports since the
Federal Reserve, in its role as supervisor of insured state member banks, would be lacking the
data necessary to assess the financial condition of individual insured banks to determine whether
there had been any deterioration in their condition.

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Beginning March 1998, all banks were required to transmit their Call Report data
electronically. Banks do not have to submit hard copy Call Reports to any federal bank
supervisory agency unless specifically requested to do so.
Proposed Revisions
The agencies propose to revise for the March 31, 2015, report date (1) the risk-weighted
assets portion of Schedule RC-R and (2) line items related to securities lent and borrowed in
Schedule RC-L. Institutions may provide reasonable estimates for any new or revised Call
Report items initially required to be reported as of that date for which the requested information
is not readily available.
Schedule RC-R, Part II
The agencies propose to revise the reporting requirements for the risk-weighted assets
portion of Call Report Schedule RC-R, Regulatory Capital, by incorporating the standardized
approach, consistent with the revised regulatory capital rules. Compared to the current schedule,
the proposed risk-weighted assets portion of Schedule RC-R would provide a more detailed
breakdown of on-balance sheet asset and off-balance sheet item categories, remove the ratingsbased approach from the calculation of risk-weighted assets, reflect reporting of alternative riskweighting approaches not reliant on credit ratings, and include an expanded number of riskweight categories, consistent with the revised regulatory capital rules. Schedule RC-R, Part II,
Risk-Weighted Assets, would be divided into the following sections (1) on-balance sheet asset
categories and securitization exposures, (2) derivatives and off-balance sheet items, (3) totals,
and (4) memoranda items for derivatives. A brief description of each of these sections and the
corresponding line items in Schedule RC-R, Part II, are provided below.
Schedule RC-R, Part II, Balance Sheet Asset Categories and Securitization
Exposures, items 1-11
Proposed data items 1 through 8 reflect on-balance sheet asset categories (excluding
those assets within each category that meet the definition of a securitization exposure), similar to
the asset categories included in the current version of Schedule RC-R, but the proposed items
would capture greater reporting detail. The number of risk-weight categories to which the
individual assets in each asset category would be allocated would be expanded consistent with
the revised regulatory capital rules. On-balance sheet assets and off-balance sheet items that
meet the definition of a securitization exposure would be reported in items 9 and 10,
respectively.
Subject to the separate reporting of securitization exposures from the related on-balance
sheet asset category, total on-balance sheet assets are equal to the sum of item 1, cash and
balances due from depository institutions; securities which are composed of item 2.a, held-tomaturity (HTM) securities and item 2.b, available-for-sale (AFS) securities; item 3.a, federal
funds sold and item 3.b, securities purchased under agreements to resell; loans and leases held
for sale, which are composed of item 4.a, residential mortgage exposures, item 4.b, high
volatility commercial real estate (HVCRE) exposures, item 4.c, exposures past due 90 days or

3

more or on nonaccrual, and item 4.d, all other exposures; loans and leases, net of unearned
income, which are composed of item 5.a, residential mortgage exposures, item 5.b, HVCRE
exposures, item 5.c, exposures past due 90 days or more or on nonaccrual, and item 5.d, all other
exposures; less item 6, allowance for loan and lease losses; item 7, trading assets; item 8, all
other assets; and on-balance sheet securitization exposures, which are composed of item 9.a,
HTM securities, item 9.b, AFS securities, item 9.c, trading assets, and item 9.d, all other onbalance sheet securitization exposures. As mentioned above, off-balance sheet securitization
exposures would be reported in item 10. Item 11 would collect total information on the
institution’s on-balance sheet asset categories and on-balance sheet securitization exposures,
including for each risk-weight category, calculated as the sum of items 1 through 9.
Schedule RC-R, Part II, Derivatives, Off-Balance Sheet Items, and Other Items
Subject to Risk Weighting, items 12-22
Proposed data items 12 through 22 pertain to the reporting of derivatives, off-balance
sheet items, and other items subject to risk weighting, excluding those that meet the definition of
a securitization exposure (which are reported in item 10 as discussed above).
Derivatives, off-balance sheet items, and other items subject to risk weighting consist of
item 12, financial standby letters of credit; item 13, performance standby letters of credit and
transaction-related contingent items; item 14, commercial and similar letters of credit with an
original maturity of one year or less; item 15, retained recourse on small business obligations
sold with recourse; item 16, repo-style transactions, which includes securities purchased under
agreements to resell (reverse repos), securities sold under agreements to repurchase (repos),
securities borrowed, and securities lent; item 17, all other off-balance sheet liabilities; unused
commitments, which is composed of item 18.a, the unused portion of commitments with an
original maturity of one year or less, excluding asset-backed commercial paper (ABCP) conduits,
item 18.b, the unused portion of eligible ABCP liquidity facilities with an original maturity of
one year or less, and item 18.c, the unused portion of commitments with an original maturity
exceeding one year; item 19, unconditionally cancelable commitments; item 20, over-the-counter
derivative; item 21, centrally cleared derivative contracts; and item 22, unsettled transactions
(failed trades).
Schedule RC-R, Part II, Totals, items 23-31
Proposed data items 23 through 31 apply the risk-weight factors to the exposure amounts
reported for assets, derivatives, off-balance sheet items, and other items subject to risk weighting
in items 11 through 22 and then calculate an institution’s total risk-weighted assets.
Item 25 would collect information on an institution’s risk-weighted assets by risk-weight
category. For each column, this is equal to the product of the amount reported item 23 for total
assets, derivatives, and off-balance sheet items by risk weight-category, multiplied by item 24,
the applicable risk-weight factor. Item 26 would collect an institution’s measurement of riskweighted assets for purposes of calculating the institution’s 1.25 percent of risk-weighted assets
limit on the allowance for loan and lease losses. Item 27 would collect an institution’s
standardized market risk-weighted assets, if applicable.

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Item 31 would collect an institution’s total risk-weighted assets, calculated as item 28,
risk-weighted assets before deductions for excess allowance of loan and lease losses and
allocated transfer risk reserve, less item 29, excess allowance for loan and lease losses, and less
item 30, allocated transfer risk reserve.
Schedule RC-R, Part II, Derivatives, Memorandum items 1-3
In proposed memorandum items 1 through 3, an institution would report the current
credit exposure and notional principal amounts of its derivative contracts.
Memorandum item 1 would continue collect the institution’s total current credit exposure
amount for all interest rate, foreign exchange rate, gold, credit, equity, precious metals (except
gold), and other derivative contracts covered by the regulatory capital rules after considering
applicable legally enforceable bilateral netting agreements.
Memorandum items 2 and 3, respectively, would collect, by remaining maturity and type
of contract, the notional principal amounts of the institution’s over-the-counter and centrally
cleared derivative contracts subject to the revised regulatory capital rules. Data on interest rate,
foreign exchange rate and gold, credit (investment grade reference assets), credit (noninvestment grade reference assets), equity, precious metals (except gold), and other derivative
contracts would be reported separately. At present, institutions report these notional principal
amounts and remaining maturities, but without distinguishing between over-the-counter and
centrally cleared derivatives. In addition, foreign exchange rate contracts and gold contracts
would be combined in Memorandum items 2 and 3, whereas each of these two types of contracts
currently is reported separately in Memorandum item 2.
Schedule RC-L
Call Report Schedule RC-L collects regulatory data on derivatives and off-balance sheet
items. The agencies propose to revise the reporting requirements for off-balance sheet exposures
related to securities lent and borrowed, consistent with the revised regulatory capital rules.
Compared to the current schedule, the proposed changes to Schedule RC-L would require all
institutions to report the amount of securities borrowed. At present, institutions include the
amount of securities borrowed in the total amount of all other off-balance sheet liabilities
reported in item 9 of Schedule RC-L if the amount of securities borrowed is more than 10
percent of total bank equity capital and they disclose the amount of securities borrowed if that
amount is more than 25 percent of total bank equity capital. In addition, the proposed changes to
Schedule RC-L would place the line item for securities borrowed in a new item 6.b immediately
after the line item for securities lent, which would be renumbered from item 6 to item 6.a.
Time Schedule for Information Collection
The Call Reports are collected quarterly as of the end of the last calendar day of March,
June, September, and December. Less frequent collection of Call Reports would reduce the
Federal Reserve’s ability to identify on a timely basis those banks that are experiencing adverse
changes in their condition so that appropriate corrective measures can be implemented to restore

5

their safety and soundness. State member banks must submit the Call Reports to the appropriate
Federal Reserve Bank within 30 calendar days following the as-of date; a five-day extension is
given to banks with more than one foreign office.
Aggregate data are published in the Federal Reserve Bulletin and the Annual Statistical
Digest. Additionally, data are used in the Uniform Bank Performance Report (UBPR) and the
Annual Report of the FFIEC. Individual respondent data, excluding confidential information,
are available to the public from the National Technical Information Service in Springfield,
Virginia, upon request approximately twelve weeks after the report date. Data are also available
from the FFIEC Central Data Repository Public Data Distribution (CDR PDD) website
(https://cdr.ffiec.gov/public/). Data for the current quarter are made available, shortly after a
bank’s submission, beginning the first calendar day after the report date. Updated or revised data
may replace data already posted at any time thereafter.
Legal Status
The Board’s Legal Division has determined that Section 9 of the Federal Reserve Act (12
U.S.C. § 324) authorizes the Federal Reserve to require these reports from all state member
banks. The Board’s Legal Division has determined that the following data items are
confidential: (1) the FDIC deposit insurance assessment information reported in response to
item 2.g on Schedule RI-E, (2) the prepaid deposit insurance assessments information reported in
response to item 6.f on schedule RC-F, and (3) the information regarding other data for deposit
insurance and FICO assessments reported in respond to memorandum items 6-9 and 14-15 on
schedule RC-O. This information can be exempt from disclosure pursuant to the Freedom of
Information Act (5 U.S.C. §§ 552 (b)(4) and (8)) for periods beginning June 30, 2009. The
Board’s Legal Division also determined that the individual respondent information contained in
the trust schedule, RC-T are exempt from disclosure pursuant to the Freedom of Information Act
(5 U.S.C. §§ 552(b)(4) and (8)) for periods prior to March 31, 2009. Finally, Column A and
memorandum item 1 to Schedule RC-N, Past Due and Nonaccrual Loans, Leases, and Other
Assets are exempt from disclosure pursuant to the Freedom of Information Act (5 U.S.C. §§
552(b)(4) and (8)) for periods prior to March 31, 2001.
Consultation Outside the Agency and Discussion of Public Comments
On June 23, 2014, the agencies, under the auspices of the FFIEC, published an initial
notice in the Federal Register (79 FR 35634) requesting public comment for 60 days on the
extension, with revision, of the Call Reports. The comment period for this notice expired on
August 22, 2014. The agencies collectively received comments on the proposal from three
entities (one banking organization, one consulting firm, and one U.S. government agency). In
addition, the Board received comments from three entities (two banking organizations and one
bankers’ association) on proposed revisions to the reporting of risk-weighted assets in Schedule
HC-R of the Consolidated Financial Statements for Holding Companies (FR Y-9C; OMB No.
7100-0128). In this instance, the agencies considered the comments on the proposed revisions to
the FR Y-9C because they parallel the proposed revisions to the Call Report. Collectively, the
commenters asked for (1) clarification on the applicability of the proposed reporting

6

requirements, (2) additional new items, (3) combining two items, (4) opening certain risk-weight
categories for some items, and (5) clarification of or additional instructions for certain line items.
One commenter noted that in several places the proposed reporting instructions refer the
reader to the agencies’ regulatory capital rules for additional information. The commenter
requested that the agencies incorporate the information from the regulatory capital rules into the
reporting instructions. The agencies believe that adding such text to the reporting instructions
would unduly add significant length to the instructions, and do not believe it is necessary to
incorporate the complete text of the agencies’ regulatory capital rules into the reporting
instructions. However, the agencies will revise the proposed reporting instructions to more
clearly cross-reference the regulatory capital rules.
One commenter requested the addition of a separate line item for total equity exposures,
while another commenter requested the addition of a three-way breakout of equity exposures to
investment funds similar to that found in the Regulatory Capital Reporting for Institutions
Subject to the Advanced Capital Adequacy Framework (FFIEC 101; OMB No. 7100-0319). The
FFIEC 101 requires institutions to report equity exposures to investment funds by the
methodology used to risk weight these exposures. The agencies do not believe it is necessary to
add line items for reporting equity exposures by risk-weighting methodology to the Call Report.
Furthermore, the agencies would not import into the Call Report the equity exposure reporting
template found in the FFIEC 101 because this would add complexity and burden for smaller
institutions that complete the Call Report. However, because of the approaches available for risk
weighting investments in investment funds (including mutual funds), the agencies would add
data items for reporting the exposure amount and risk-weighted asset amount of such
investments to the appropriate balance sheet asset categories. The agencies also would include
more detailed guidance related to equity exposure reporting in the final instructions for Schedule
RC-R, Part II.
Schedule RC-R, Part II
Two commenters noted that several risk-weight categories for item 8, “Other assets,” on
the proposed reporting form are not available for data input (i.e., the categories are shaded out),
but the commenters stated the categories may be applicable, particularly to address the exposures
underlying separate account bank-owned life insurance (BOLI) assets. The agencies agree with
these comments and, because of the risk-weighting approaches that can be applied to separate
account BOLI assets, would provide new data items for the exposure amount and risk-weighted
asset amount of these BOLI assets, which would be reported separately from the other risk
weightings within item 8, “Other assets.” In addition, the agencies would allow data input in the
150 percent and 300 percent risk-weight categories for item 8, “Other assets.”
One commenter requested clarification of the reporting in item 8 of default fund
contributions (DFCs) made by the reporting institution to qualifying central counterparties
(QCCPs). The commenter noted that the proposed reporting instructions for item 8 state that
such contributions should be allocated to the risk-weight categories defined for column B
through column Q. However, the commenter observed that DFCs to QCCPs are subject to two
alternative methodologies (Methods 1 and 2) for calculating risk-weighted assets, one of which

7

may result in risk weightings not captured in column B through column Q.
In response to this comment, the agencies would provide new data items for the exposure
amount and risk-weighted asset amount of DFCs to QCCPs, which would be reported separately
from the risk weightings otherwise captured in item 8. The instructions would describe how to
use these data items to report DFCs under Method 1 as well as Method 2.
One commenter noted that items 2 through 8 could include securitization exposures, and
when added with item 9, “On-balance sheet securitization exposures,” would double count such
exposures in reporting item 11, “Total assets.” The agencies note that the reporting instructions
for each proposed balance sheet asset category (items 1 through 8) explicitly state that the
reporting institution is to exclude securitization exposures. Nevertheless, the agencies would
clarify the proposed reporting form by adding guidance explicitly stating that institutions should
exclude securitization exposures from items 2 through 8 and report them in item 9.1
Although the proposed reporting form and instructions addressed the reporting of an
institution’s securitization exposures and the treatment of financial collateral, the agencies noted
during their review of the proposal that it did not clearly address the risk weighting and reporting
of assets and certain other items secured by financial collateral in the form of securitization
exposures or mutual funds, nor did it fully address the two approaches for recognizing the effects
of qualifying financial collateral. The approaches for risk weighting securitization exposures and
investments in mutual funds also are applicable to such exposures when they serve as financial
collateral. To accommodate the possible risk weight outcomes when exposures are secured by
these types of collateral, the agencies would include data items in new columns R and S for
reporting the exposure amount and risk-weighted asset amount of these collateralized exposures
separately from the other risk weightings within appropriate balance sheet asset categories (and
derivative and off-balance sheet item categories).
One commenter noted that in accordance with section 37 of the agencies’ revised
regulatory capital rules, banking organizations must calculate the exposure amount and riskweighted assets for repo-style transactions on a netting set basis. A netting set may contain
transactions that are reported as assets, liabilities, and off-balance sheet items (as long as they are
executed under the same master netting agreement), and the basis for the risk-weighted assets
calculation is the net exposure, adjusted for volatility and foreign exchange haircuts. As
proposed, Schedule RC-R, Part II, would have split the reporting of repo-style transactions
between assets (reported in item 3, “Federal funds sold and securities purchased under
agreements to resell,” i.e., reverse repos) and liabilities and off-balance sheet items (reported in
item 16, “Repo-style transactions (excluding reverse repos)”). However, since risk-weighted
assets for repo-style transactions are based on the net exposure at a netting set level (inclusive of
volatility and foreign exchange haircuts), the proposal’s method for allocating repo-style
transaction exposures between two reporting items and across the risk-weight categories in a way
that would tie back to the amounts required to be reported in column A of Schedule RC-R,
Part II (i.e., for item 3, the balance sheet carrying amount, and for item 16, the notional value),
1

The agencies would add a similar clarification to the proposed reporting form regarding derivatives and offbalance sheet items that are securitization exposures by explicitly stating that institutions should exclude them from
items 12 through 21 and report them in item 10.

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does not align with the treatment of repo-style transactions under the revised regulatory capital
rules. The commenter recommended that the agencies amend the reporting form to collect all
repo-style transactions in a single item, and amounts attributed to risk-weighting categories for
this item would tie to an “exposure” amount reported in Column A.
The agencies agree with this comment and would revise the proposed item 16 of
Schedule RC-R, Part II, to include all repo-style transactions in a retitled item 16, “Repo-style
transactions,” which would now also include securities purchased under agreements to resell
(reverse repos) in order for institutions to calculate their exposure based on master netting set
agreements. In addition, consistent with the Call Report balance sheet (Schedule RC), proposed
item 3 of Schedule RC-R, Part II, would be split into item 3.a, “Federal funds sold (in domestic
offices),” and item 3.b, “Securities purchased under agreements to resell.” However, after an
institution reports the balance sheet carrying amount of its reverse repos in column A of item 3.b,
it would report this same amount as an adjustment in column B of item 3.b, resulting in no
allocation of the balance sheet carrying amount of reverse repos across the risk-weight categories
in item 3. This reporting methodology would ensure that the sum of the balance sheet asset
amounts reported in items 1 through 9, column A, of Schedule RC-R, Part II, that an institution
would report in item 11 of Schedule RC-R, Part II, would continue to equal the “Total assets”
reported in item 12 of the Call Report balance sheet (Schedule RC).
Another commenter noted that, under the agencies’ revised regulatory capital rules, a
banking organization is required to hold risk-based capital against all repo-style transactions,
regardless of whether the transactions generate on-balance sheet exposures. The commenter also
noted that the proposed reporting instructions for Schedule RC-R, Part II, state that “Although
securities sold under agreements to repurchase are reported on the balance sheet (Schedule RC)
as liabilities, they are treated as off-balance sheet items under the regulatory capital rules.” The
commenter then questioned the intent of the agencies’ proposed reporting form that would
require an institution to calculate a capital charge for these “off-balance sheet items” despite the
fact that the security pledged by the institution as collateral for the repo remains on the balance
sheet for accounting purposes and would therefore attract a separate on-balance sheet risk
weighting. The agencies adopted this reporting approach for consistency with the revised
regulatory capital rules, which recognize that institutions face counterparty credit risk when
engaging in repo-style transactions. However, under certain conditions, the agencies’ revised
regulatory capital rules also allow institutions to recognize the risk mitigating effects of financial
collateral when risk weighting their repo-style exposures. The final reporting form and
instructions for Schedule RC-R, Part II, would implement this treatment of repo-style
transactions, which is set forth in the revised regulatory capital rules.
The final version of Schedule RC-R, Part II, would also include a new line item 22,
“Unsettled transactions (failed trades),” in order to more clearly assess risk-based capital against
delayed trades where the counterparty has failed to deliver an instrument or make a required
payment in a timely manner.
One commenter noted that, prior to the proposed revisions, the instructions for
Memorandum item 1 stated that all written option contracts (except those that are, in substance,
financial guarantees) are not covered by the risk-based capital standards. However, this

9

statement was omitted from the proposed instructions for Memorandum item 1. The commenter
asked if this was an explicit change in the reporting of written option contracts. Written option
contracts continue to be excluded from reporting in Memorandum item 1, consistent with the
revised regulatory capital rules. The agencies would clarify this exclusion in the proposed
instructions for Memorandum item 1.
Existing Memorandum item 2 would be revised to provide for separate reporting, by
remaining maturity and type of contract, of the notional principal amounts of the institution’s
over-the-counter and centrally cleared derivative contracts subject to the revised regulatory
capital rules.
Schedule RC-L
One commenter noted that the current instructions for item 9 state to “report all securities
borrowed against collateral (other than cash)” for such purposes as serving “as a pledge against
deposit liabilities or delivery against short sales,” whereas the current instructions for item 6 state
to report all securities owned that are “lent against collateral or on an uncollateralized basis.”
The commenter characterizes current item 9 as inclusive of only certain types of securities
borrowings such as those collateralized by “other than cash” and those “for purposes as a pledge
against deposit liabilities or short sales,” whereas current item 6 covers all types of securities
lending regardless of the type of collateral. The commenter asks for clarification of the scope of
these two items.
Similar to current item 6 of Schedule RC-L, the instructions for item 6.b would clarify
that institutions should report all types of securities borrowing, regardless of collateral type. The
phrase “other than cash” would be deleted from the final instructions for item 6.b of Schedule
RC-L.
Treatment of Financial Subsidiaries
During the review of the proposed reporting forms and instructions, the agencies noted
that the instructions were not clear regarding the treatment of assets and liabilities of financial
subsidiaries for purposes of the capital calculations. Pursuant to 12 U.S.C. § 24a(c), all assets
and liabilities of financial subsidiaries must be deconsolidated and deducted for purposes of
determining an institution’s compliance with the agencies’ regulatory capital standards. While
the statutory treatment was explicitly included in the prior instructions, it was inadvertently
omitted from the proposed instructions for Schedule RC-R, Part II. Therefore, the agencies
would include language in the instructions specifically addressing the treatment of financial
subsidiaries. Generally, any assets of financial subsidiaries reported in Call Report Schedule RC,
Balance Sheet, and therefore included in the balance sheet amounts reported in column A of
Schedule RC-R, Part II, would be reported as deductions in column B of Schedule RC-R, Part II.
Derivatives and off-balance sheet items of financial subsidiaries would not be included for
purposes of applying credit conversion factors and risk weighting in the remainder of
Schedule RC-R, Part II.

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In addition, the agencies would clarify the instructions for the calculation of total assets
for leverage ratio purposes in Schedule RC-R, Part I.B, to state that the assets of financial
subsidiaries reported in Schedule RC, Balance Sheet, must be reported as a deduction in item 38
of Part I.B.
On February 2, 2015, the agencies published a final notice in the Federal Register
(80 FR 5618).
Estimate of Respondent Burden
The current annual reporting burden for the Call Report is estimated to be 195,415 hours
and would increase to 203,277 hours as shown in the following table. The average estimated
hours per response for Call Report filers would increase from 58.09 hours to 60.07 hours due to
the proposed changes. This reporting requirement represents 1.3 percent of the total Federal
Reserve paperwork burden.
Number of
respondents2

Annual
frequency

Estimated
average hours
per response

Estimated
annual burden
hours

Current

841

4

58.09

195,415

Proposed

846

4

60.07

203,277

Change

7,862

The current total annual cost to state member banks is estimated to be $9,946,624 and
with the proposed revisions would increase to $10,346,799.3 This estimate represents costs
associated with recurring salary and employee benefits, and expenses associated with software,
data processing, and bank records that are not used internally for management purposes but are
necessary to complete the Call Reports.
With respect to the changes that are the subject of this submission, banks would incur a
capital and start-up cost component, but the amount would vary from bank to bank depending
upon its individual circumstances and the extent of its involvement, if any, with the particular
type of activity or product about which information would begin to be collected. An estimate of
this cost component cannot be determined at this time.

2

Of the 846 respondents required to comply with this information collection, 632 respondents are considered a
small entity as defined by the Small Business Administration (i.e., entities with $550 million or less in total assets).
www.sba.gov/content/small-business-size-standards.
3
Total cost to the public was estimated using the following formula: percent of staff time, multiplied by annual
burden hours, multiplied by hourly rate (30% Office & Administrative Support at $18, 45% Financial Managers at
$61, 15% Lawyers at $63, and 10% Chief Executives at $86). Hourly rates for each occupational group are the
(rounded) mean hourly wages from the Bureau of Labor and Statistics (BLS), Occupational Employment and Wages
May 2013, published April 1, 2014, www.bls.gov/news.release/ocwage.nr0.htm Occupations are defined using the
BLS Occupational Classification System, www.bls.gov/soc/.

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Sensitive Questions
This collection of information contains no questions of a sensitive nature, as defined by
OMB guidelines.
Estimate of Cost to the Federal Reserve System
The current annual cost to the Federal Reserve System for collecting and processing the
Call Reports are estimated to be $1,500,837 per year. This amount includes the routine annual
cost of personnel, printing, and computer processing, as well as internal software development
cost for maintaining and modifying existing operating systems used to edit and validate
submitted data.

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