FFIEC031_FFIEC041_FFIEC051_20180108_omb

Supporting Statement for the
Consolidated Reports of Condition and Income
(FFIEC 031, FFIEC 041, and FFIEC 051; OMB No. 7100-0036)
Summary
The Board of Governors of the Federal Reserve System (Board) requests approval from
the Office of Management and Budget (OMB) to extend for three years, with revision, the
Federal Financial Institutions Examination Council (FFIEC) Consolidated Reports of Condition
and Income (Call Reports) (FFIEC 031, FFIEC 041, and FFIEC 051; 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 Board 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 Board, the FDIC, and the OCC (the agencies) propose to revise the Call Reports to
be submitted on or after April 1, 2018, beginning with the reports reflecting the March 31, 2018,
report date, by addressing the changes in the accounting for equity investments to coincide with
the first reporting period in which the accounting changes will be adopted under U.S. generally
accepted accounting principles (GAAP) by certain reporting institutions. The agencies propose
to revise the Call Reports to be submitted on or after July 1, 2018, beginning with the reports
reflecting the June 30, 2018, report date, by deleting or consolidating of a large number of items,
raising certain reporting thresholds, and reducing the frequency of reporting for a number of
items. The agencies also propose to proceed with the scope revision to the FFIEC 031 and
FFIEC 041 reports to require all institutions with consolidated total assets of $100 billion or
more, regardless of whether an institution has any foreign offices, to file the FFIEC 031. The
current annual burden for the Call Reports is estimated to be 177,768 hours and the proposed
revisions are estimated to decrease the annual burden by 7,078 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 Call Reports 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 data, which is made
publicly available by the agencies, is used not only by the federal government, but also by 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 three reporting
forms that apply to different categories of banks: (1) all banks that have domestic and foreign
offices (FFIEC 031), (2) banks with domestic offices only (FFIEC 041), and (3) banks with
domestic offices only and total assets less than $1 billion (FFIEC 051).1
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 Board collects various data in connection with its measurement of monetary
aggregates, of bank credit, and of flow of funds. Reporting banks supply the Board with detailed
information relating to balance sheet accounts such as balances due from depository institutions,
loans, and deposit liabilities. The Board 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.
These reporting forms from banks, however, are frequently obtained on a sample basis
rather than from all insured banks. Moreover, these reporting forms are often prepared as of
1

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 according to the asset size of the bank. Prior to March 2017, there were two categories of
banks and two reporting forms. The FFIEC 031 was filed by banks with domestic and foreign offices and the (2) the
FFIEC 041 was filed by banks with domestic offices only.

2

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 Board 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 Board, 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.
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
As part of an initiative launched by the FFIEC in December 2014 to identify potential
opportunities to reduce burden associated with Call Report requirements for community banks,
the FFIEC and the agencies have taken several actions, including (1) the finalization in mid-2016
of a number of burden-reducing changes and other revisions to the Call Report that were
implemented in September 2016 and March 2017; (2) outreach to institutions to obtain a better
understanding of significant sources of reporting burden in their Call Report preparation
processes; and (3) the creation of a new streamlined FFIEC 051 Call Report for eligible small
institutions that took effect as of the March 31, 2017, report date.2
As another key part of the FFIEC’s community bank burden-reduction initiative, in 2015
the agencies accelerated the start of the next statutorily mandated review of the existing Call
Report data items (Full Review),3 which otherwise would have commenced in 2017. Users of
Call Report data items, who are internal staff at the FFIEC member entities, participated in a
series of nine surveys conducted over a 19-month period that began in mid-July 2015 and ended
in mid-February 2017. As an integral part of these surveys, users were asked to fully explain the
need for each Call Report data item they deem essential, how the data item is used, the frequency
with which it is needed, and the population of institutions from which it is needed. Call Report
schedules were placed into nine groups and prioritized for review, generally based on the level of
burden cited by banking industry representatives. Based on the results of the user surveys, the
agencies are in the process of identifying data items to be considered for removal, less frequent
collection, and new or revised reporting thresholds to reduce burden.
In addition, as a framework for the actions it is undertaking, the FFIEC developed a set of
guiding principles for use in evaluating potential additions and deletions of Call Report data
2

See 80 FR 56539 (September 18, 2015), 81 FR 45357 (July 13, 2016), 81 FR 54190 (August 15, 2016) (referred to
hereafter as the “August 2016 Call Report proposal”), and 82 FR 2444 (January 9, 2017) for further information on
the actions taken under this initiative.
3
This review is mandated by section 604 of the Financial Services Regulatory Relief Act of 2006 (12 U.S.C.
1817(a)(11)).

3

items and other revisions to the Call Report. In general, data items collected in the Call Report
must meet three guiding principles: (1) the data items serve a long-term regulatory or public
policy purpose by assisting the FFIEC member entities in fulfilling their missions of ensuring the
safety and soundness of financial institutions and the financial system and the protection of
consumer financial rights, as well as agency-specific missions affecting national and statechartered institutions; (2) the data items to be collected maximize practical utility and minimize,
to the extent practicable and appropriate, burden on financial institutions; and (3) equivalent data
items are not readily available through other means.
Based on the results of a portion of the user surveys, the agencies propose various
burden-reducing changes in this proposal. A summary of the FFIEC member entities’ uses of the
data items retained in the Call Report schedules covered in this portion of the user surveys is
included in Appendix A. The results of the agencies’ initial reviews of the first portion of the
user surveys were included in the agencies’ August 2016 Call Report proposal for a new
streamlined FFIEC 051 Call Report for eligible small institutions and burden-reducing revisions
to the existing FFIEC 031 and FFIEC 041 versions of the Call Report, which was finalized in
December 2016.4 The agencies are analyzing the results of the final portion of the user surveys
to determine any future proposed revisions to the FFIEC 031, FFIEC 041, and FFIEC 051.
Burden-reducing reporting changes from this last group of surveys will be proposed in a future
Federal Register notice with an anticipated June 30, 2018, implementation date. The schedules
reviewed in this last group primarily include schedules that collect data on complex or
specialized activities, several of which were removed and replaced by indicator questions and a
limited number of indicator items when the new FFIEC 051 was created. Therefore, revisions
proposed in this future notice may be likely to more significantly affect schedules and data items
in the FFIEC 031 and FFIEC 041.
General Discussion of Proposed Call Report Revisions
The Call Report schedules are being reviewed as part of the Full Review, conducted
through a series of nine user surveys. The results of a portion of the surveys were evaluated in
the development of this proposal. In addition, the results of certain surveys were re-evaluated
and further burden-reducing changes were incorporated into this proposal. In conjunction with
these evaluations, the agencies also considered comments received on their August 2016 Call
Report proposal, feedback and streamlining suggestions received during their banker outreach
activities as part of the community bank Call Report burden-reduction initiative, and comments
regarding the Call Report received during the Economic Growth and Regulatory Paperwork
Reduction Act review conducted by the FFIEC and the agencies5 (hereafter collectively referred
to as “industry comments and feedback”). The proposed revisions to the FFIEC 031,
FFIEC 041, and FFIEC 051, which are based on these analyses of the survey responses and
consideration of industry comments and feedback, are discussed below.

4

See 81 FR 54190 (August 15, 2016) and 82 FR 2444 (January 9, 2017). A summary of the FFIEC member
entities’ uses of the data items retained in the Call Report schedules covered in the first portion of the user surveys
was included in Appendix A of the latter notice.
5
See the Joint Report to Congress, Economic Growth and Regulatory Paperwork Reduction Act, March 2017,
www.ffiec.gov/pdf/2017_FFIEC_EGRPRA_Joint-Report_to_Congress.pdf.

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The schedules reviewed in the portion of the user surveys evaluated in the development
of this proposal include:
• Schedule RI-D – Income from Foreign Offices (FFIEC 031 only)
• Schedule RI-E – Explanations
• Schedule RC-B – Securities
• Schedule RC-D – Trading Assets and Liabilities (FFIEC 031 and FFIEC 041 only)
• Schedule RC-K – Quarterly Averages
• Schedule RC-L – Derivatives and Off-Balance-Sheet Items
• Schedule RC-M – Memoranda
•
•
•
•

The schedules re-evaluated in the development of this proposal include:
Schedule RI – Income Statement
Schedule RC – Balance Sheet
Schedule RC-C, Part I – Loans and Leases
Schedule RC-N – Past Due and Nonaccrual Loans, Leases, and Other Assets

Table 1 summarizes the changes already finalized as part of the FFIEC’s community
bank Call Report burden-reduction initiative.
Table 1 – Data Items Revised as of March 31, 2017
Finalized Call Report Revisions
Items Removed, Net*
Change in Item Frequency to Semiannual
Change in Item Frequency to Annual
Items with a New or Increased Reporting
Threshold

051
967
96
10

041
60

031
68

7

13

“Items Removed, Net” reflects the effects of consolidating existing items, adding control
totals, and, for the FFIEC 051, relocating individual items from other schedules to Schedule SU,
some of which were consolidated in Schedule SU. In addition, included in this number for the
FFIEC 051, approximately 300 items were items that institutions with less than $1 billion in total
assets were exempt from reporting due to existing reporting thresholds in the FFIEC 041.
*

Table 2 summarizes the additional burden-reducing proposed revisions to data items
included in this notice. Detail for each affected data item is shown in Appendix B (FFIEC 051),
Appendix C (FFIEC 041), and Appendix D (FFIEC 031).

5

Table 2 – Proposed Data Revisions in this Notice
Proposed Call Report Revisions
Items Proposed to be Removed, Net*
Proposed Change in Item Frequency to
Semiannual
Proposed Change in Item Frequency to Annual
Items with a Proposed New or Increased
Reporting Threshold

051
54

041
106

031
86

17
26

31
3

31
3

26

106

178

“Items Proposed to be Removed, Net” reflects the effects of consolidating existing items and
relocating individual items to other schedules.
*

The agencies are also proposing revisions not related to the burden-reduction initiative.
The agencies would revise portions of several Call Report schedules to incorporate the revised
accounting for equity securities under Accounting Standards Update (ASU) No. 2016-01,
“Recognition and Measurement of Financial Assets and Financial Liabilities.”
The revisions to the FFIEC 031, FFIEC 041, and FFIEC 051 to address the change in
accounting for equity investments would be effective for Call Reports submitted on or after
April 1, 2018, beginning with those reflecting the March 31, 2018, report date. However, all
other revisions would be effective of Call Reports submitted on or after July 1, 2018, beginning
with those reflecting the June 30, 2018, report date.
Detail of Specific Proposed Call Report Revisions
A. Revisions to the FFIEC 051
Schedule RI
For the FFIEC 051, the agencies propose to consolidate securities brokerage and
investment banking income items 5.d.(1) and 5.d.(2) into revised item 5.d.(1), consolidate
insurance activities income items 5.d.(3) through 5.d.(5) into revised item 5.d.(2), remove
securitization income item 5.g, and remove non-deductible interest expense Memorandum item 1
as the agencies no longer need the current level of detail provided by each of these existing items
from smaller institutions eligible to file this version of the Call Report. Securitization income
would be included within other noninterest income in item 5.l.
Schedule RI-B
For the FFIEC 051, the agencies propose to remove Schedule RI-B, Part II,
Memorandum item 4 on allowances for credit losses on purchased credit-impaired loans, as the
agencies no longer need this item from smaller institutions eligible to file this version of the Call
Report.

6

Schedule RI-E
For the FFIEC 051, the agencies propose to remove the preprinted captions for items 1.f
and 1.h, as few institutions report having these components of other noninterest income in
amounts in excess of the existing reporting threshold for disclosing these components.6 The
remaining items 1.g and 1.i through 1.l would be renumbered as items 1.f through 1.j.
In addition, after reviewing the agencies’ data needs along with industry comments and
feedback requesting a higher threshold for disclosing components of other noninterest income
and other noninterest expense in Schedule RI-E, the agencies propose to increase the percentage
portion of the existing threshold for reporting other noninterest income components in items 1.a
through 1.j and other noninterest expense components in items 2.a through 2.p. The proposed
threshold for disclosing components of other noninterest income and other noninterest expense
would be amounts greater than $100,000 that exceed seven percent of Schedule RI, item 5.l and
item 7.d, respectively.7 This percentage is currently three percent. Upon evaluating the impact
of each percentage threshold, the agencies determined that a percentage threshold of seven
percent would provide a meaningful reduction in reporting burden without a loss of data that
would be necessary for supervisory or other public policy purposes.
The agencies further propose to reduce the frequency of collection for items 1.a through
1.j and 2.a through 2.p from quarterly to annually as of December 31. This proposal is based on
a comment received on the agencies’ August 2016 Call Report proposal recommending a
reduction in the reporting frequency of these items for smaller institutions.8 The agencies
believe the new reporting frequency better balances the agencies’ supervisory needs with
institutions’ reporting burden.
Schedule RC
For the FFIEC 051, the agencies propose to move the reporting of goodwill from existing
item 10.a on the balance sheet to Schedule RC-M, item 2.b, and combine existing items 10.a and
10.b on Schedule RC into a single item 10. This would consolidate the reporting of goodwill and
other intangible assets on Schedule RC into a single balance sheet item for intangible assets.
This proposed revision to Schedule RC was requested by a commenter on the agencies’ August
2016 Call Report proposal to facilitate institutions’ reporting by making their Call Report
processes more efficient and better focused. While the agencies believe the reporting and
disclosure of the amount of an institution’s goodwill is important, the agencies are indifferent as
to the location of the goodwill information in the Call Report.

6

After these two preprinted captions have been removed, if an institution has any other noninterest income
component currently disclosed in item 1.f or 1.h in an amount in excess of the reporting threshold, it would itemize
and describe this component in one of the subitems of item 1 without a preprinted caption.
7
The agencies increased the dollar portion of this reporting threshold from $25,000 to $100,000 effective
September 30, 2016.
8
See 82 FR 2444 (January 9, 2017) for discussion of the comments received on the August 2016 Call Report
proposal.

7

Schedule RC-B
For the FFIEC 051, the agencies propose to consolidate the reporting of an institution’s
holdings of U.S. government agency obligations, which are currently reported in items 2.a and
2.b, into a single item 2, and to consolidate the reporting of structured financial product holdings,
which are currently reported in items 5.b.(1) through 5.b.(3), into a single item 5.b, as the
agencies no longer need the current level of detail for these holdings in the Call Report. Banks
would still be required to report amortized cost and fair value information in columns A through
D for the proposed items 2 and 5.b. The agencies also propose to reduce the reporting frequency
of the data on sales and transfers of held-to-maturity securities reported in Memorandum item 3
from quarterly to semiannual (June 30 and December 31), as the agencies no longer need these
data items as frequently. This proposal is consistent with industry comments and feedback
recommending a shorter reporting form for two of the four quarters each year. The agencies also
propose to remove Memorandum items 6.a through 6.g, which provide detail on holding of
structured financial products, as smaller institutions eligible to file this version of the Call Report
generally do not hold these securities.
Schedule RC-C, Part I
For the FFIEC 051, the agencies propose to reduce the reporting frequency of
Memorandum items 7.a, 7.b, 8.a, and 12 (Columns A through C) from quarterly to semiannual
(June 30 and December 31), as the agencies no longer need these loan data in the Call Report as
frequently. This proposal is consistent with industry comments and feedback recommending a
shorter reporting form for two of the four quarters each year.
Schedule RC-K
For the FFIEC 051, the agencies propose to remove item 7, average trading assets, as the
agencies no longer need this quarterly average in the Call Report from institutions with domestic
offices only and assets less than $1 billion.
Schedule RC-L
For the FFIEC 051, the agencies propose to remove items 1.b.(1), 1.b.(2), and 1.d, as the
agencies no longer need the current level of detail for these types of unused commitments from
smaller institutions eligible to file this version of the Call Report.9 The agencies also propose to
reduce the reporting frequency of merchant credit card sales data in items 11.a and 11.b from
quarterly to semiannual (June 30 and December 31), as the agencies no longer need this
information in the Call Report as frequently. This proposal is consistent with industry comments
and feedback recommending a shorter reporting form for smaller institutions for two of the four
quarters each year.

9

Any securities underwriting commitments currently reported in item 1.d would be included as part of all other
unused commitments in item 1.e.(3).

8

Schedule RC-M
For the FFIEC 051, the agencies propose to consolidate current items 2.b and 2.c, which
provide data on certain identifiable intangible assets, into a single item 2.c,10 and to consolidate
other real estate owned items 3.c and 3.f into a single item 3.c, as the agencies no longer need the
current level of detail in the Call Report that is provided in these separate items. As discussed
earlier under Schedule RC, the agencies are moving the goodwill amount formerly reported in
Schedule RC, item 10.a, to a recaptioned item 2.b on Schedule RC-M.
Schedule RC-N
For the FFIEC 051, the agencies propose to reduce the reporting frequency of
Memorandum items 7 and 8 on nonaccrual assets and Memorandum items 9.a and 9.b on
purchased credit-impaired loans from quarterly to semiannual (June 30 and December 31), as the
agencies no longer need these data in the Call Report as frequently. In connection with this
proposed change, Memorandum items 7 and 8 would collect data on additions to nonaccrual
assets and nonaccrual asset sales, respectively, during the preceding six months rather than the
preceding quarter as at present. This proposal is consistent with industry comments and
feedback recommending a shorter reporting form for two of the four quarters each year.
B. Revisions to the FFIEC 041
Scope Revision
The agencies propose to revise the scope of the FFIEC 041 to require all institutions with
consolidated total assets of $100 billion or more to file the FFIEC 031 instead, regardless of
whether an institution has any foreign offices. The agencies are proposing this change because
institutions with consolidated total assets of $100 billion or more without foreign offices are
considered to have a similar degree of complexity in their activities as institutions with
consolidated total assets of $100 billion or more and foreign offices that currently file the
FFIEC 031. This scope revision would affect a small number of institutions. Also, modifying
the scope of these two versions of the Call Report in this manner would enable the agencies to
remove a number of data items from the FFIEC 041 report that they no longer need to collect
from institutions with consolidated total assets less than $100 billion.
Schedule RI
For the FFIEC 041, the agencies propose to remove detail on trading revenues in
Memorandum items 8.a through 8.e, as the agencies no longer need this level of detail in the Call
Report from institutions with total assets less than $100 billion. The agencies would also remove
Memorandum items 8.f through 8.h, which currently only apply to institutions with total assets
of $100 billion or more. In addition, the agencies propose to reduce the reporting frequency of
Memorandum item 12 from quarterly to semiannual (June 30 and December 31), as the agencies
no longer need this data in the Call Report as frequently.
10

As explained in the description of the proposed revisions to Schedule RC of the FFIEC 051, existing item 2.b of
Schedule RC-M would be replaced by a revised item 2.b for reporting goodwill.

9

Schedule RI-E
For the FFIEC 041, the agencies propose to remove the preprinted captions for items 1.f
and 1.h, as few institutions report having these components of other noninterest income in
amounts in excess of the existing reporting threshold for disclosing these components.11 The
remaining items 1.g and1.i through 1.l would be renumbered as items 1.f through 1.j.
In addition, after reviewing the agencies’ data needs along with industry comments and
feedback requesting a higher threshold for disclosing components of other noninterest income
and other noninterest expense in Schedule RI-E, the agencies propose to increase the percentage
portion of the existing threshold for reporting other noninterest income components in items 1.a
through 1.j and other noninterest expense components in items 2.a through 2.p. The proposed
threshold for disclosing components of other noninterest income and other noninterest expense
would be amounts greater than $100,000 that exceed seven percent of Schedule RI, item 5.l and
item 7.d, respectively.12 This percentage is currently three percent. Upon evaluating the impact
of each percentage threshold, the agencies determined that a percentage threshold of seven
percent would provide a meaningful reduction in reporting burden without a loss of data that
would be necessary for supervisory or other public policy purposes.
Schedule RC
For the FFIEC 041, the agencies propose to move the reporting of goodwill from existing
item 10.a on the balance sheet to Schedule RC-M, item 2.b, and combine existing items 10.a and
10.b on Schedule RC into a single item 10. This would consolidate the reporting of goodwill and
other intangible assets on Schedule RC into a single balance sheet item for intangible assets.
This proposed revision to Schedule RC was requested by a commenter on the agencies’ August
2016 Call Report proposal to facilitate institutions’ reporting by making their Call Report
processes more efficient and better focused.13 While the agencies believe the reporting and
disclosure of the amount of an institution’s goodwill detail is important, the agencies are
indifferent as to the location of the information in the Call Report.
Schedule RC-B
For the FFIEC 041, the agencies propose to consolidate the reporting of an institution’s
holdings of U.S. government agency obligations, which are currently reported in items 2.a and
2.b, into a single item 2, and to consolidate the reporting of structured financial product holdings,
which are currently reported in items 5.b.(1) through 5.b.(3), into a single item 5.b, as the
agencies no longer need the current level of detail for these holdings in the Call Report.
Institutions would still be required to report amortized cost and fair value information in columns
A through D for the proposed items 2 and 5.b. The agencies also propose to reduce the reporting
11

If an institution has the component of other noninterest income currently disclosed in item 1.f or 1.h in an amount
in excess of the reporting threshold, it would itemize and describe this component in one of the subitems of item 1
without a preprinted caption.
12
The agencies increased the dollar portion of this reporting threshold from $25,000 to $100,000 effective
September 30, 2016.
13
See 82 FR 2444 (January 9, 2017) for discussion of the comments received on the August 2016 Call Report
proposal.

10

frequency of the data on sales and transfers of held-to-maturity securities reported in
Memorandum item 3 from quarterly to semiannual (June 30 and December 31), as the agencies
no longer need these data items in the Call Report as frequently. This proposal is consistent with
industry comments and feedback recommending a shorter reporting form for two of the four
quarters each year.14 The agencies also propose to add a reporting threshold of $10 billion or
more in total assets before institutions must complete Memorandum items 5.a though 6.g,
columns A through D, as the agencies no longer need this information in the Call Report from
institutions under this proposed threshold.
Schedule RC-C, Part I
For the FFIEC 041, the agencies propose to reduce the reporting frequency of
Memorandum items 7.a, 7.b, 8.a, 8.b, 8.c, and 12.a through 12.d (columns A through C) from
quarterly to semiannual (June 30 and December 31), as the agencies no longer need these loan
data in the Call Report as frequently. This proposal is consistent with industry comments and
feedback recommending a shorter reporting form for two of the four quarters each year.
Schedule RC-D
For the FFIEC 041, the agencies propose to change the reporting threshold for the overall
schedule so that the schedule would be applicable to institutions with total trading assets of $10
million or more in any of the four preceding calendar quarters from the current threshold of $2
million in average trading assets over this same period. In addition, all institutions meeting the
FDIC’s definition of a large institution or a highly complex institution for deposit insurance
assessment purposes would be required to complete Schedule RC-D. The agencies are proposing
this reporting threshold change because they no longer need to collect this detailed data in the
Call Report from institutions with a lesser amount of trading assets that are not large or highly
complex institutions.
•
•
•
•
•
•
•

The agencies also propose to consolidate:
Structured financial products in current items 5.a.(1) through 5.a.(3) into a single new
item 5.a;
Loan detail in current items 6.a.(1), 6.a.(2), 6.a.(4), and 6.a.(5) into a single new item
6.a.(2);
Certain residential loan detail in current items 6.a.(3)(a) through 6.a.(3)(b)(2) into a single
new item 6.a.(1);
Consumer loan information in items 6.c.(1) through 6.c.(4) into a single item 6.c;
Loan detail in current Memorandum items 1.a.(1), 1.a.(2), 1.a.(4), and 1.a.(5) into a single
new Memorandum item 1.a.(2);
Certain residential loan detail in current Memorandum items 1.a.(3)(a) through
1.a.(3)(b)(2) into a single new Memorandum item 1.a.(1); and
Consumer loan information in Memoranda items 1.c.(1) through 1.c.(4) into a single new
Memorandum item 1.c.
The agencies no longer need to collect the existing level of detail in the Call Report from

14

See 82 FR 2444 (January 9, 2017).

11

those institutions that would be required to complete Schedule RC-D under its proposed revised
reporting threshold. The agencies also propose to remove Memorandum items 2.a though 10, as
the agencies no longer need to collect the current level of detail in the Call Report from
institutions with less than $100 billion in total assets.
Schedule RC-K
For the FFIEC 041, the agencies propose to revise the reporting threshold for item 7 on
average trading assets. This item would only need to be completed by institutions with $10
million or more in total trading assets in any of the four preceding calendar quarters and by all
institutions meeting the FDIC’s definition of a “large institution” or a “highly complex
institution” for deposit insurance assessment purposes. This proposed revised reporting
threshold is consistent with the proposed threshold for completing Schedule RC-D discussed
above. The agencies no longer need this quarterly average in the Call Report from institutions
with less than $10 million in trading assets that are not large or highly complex institutions.
Schedule RC-L
For the FFIEC 041, the agencies propose to consolidate items 1.a.(1) and 1.a.(2) into a
single item 1.a.(1), as the agencies no longer need the current level of detail in the Call Report
for these types of unused commitments. The agencies also propose to remove item 8 on spot
foreign exchange contracts, as the agencies no longer need this information in the Call Report
from all institutions with assets less than $100 billion. By removing item 8, spot foreign
exchange contracts would be reported as part of an institution’s all other off-balance sheet
liabilities in item 9 of Schedule RC-L if the amount of such contracts exceeds 10 percent of the
institution’s total equity capital. Spot foreign exchange contracts would be disclosed as a
component of the institution’s all other off-balance sheet liabilities if the amount exceeds 25
percent of total equity capital.
The agencies also propose to remove columns B, C, and D, for items 16.a through
16.b.(8), and instead include these data on over-the-counter derivatives within column E for
derivatives with all other counterparties. The agencies no longer need the separate detail in the
Call Report provided by the disaggregated data on over-the-counter derivatives for monoline
financial guarantors, hedge funds, and sovereign governments for institutions filing the
FFIEC 041. The agencies also propose removing items 16.b.(4) though 16.b.(6) for the
remaining columns A and E, and instead including the fair value of the three types of securities
collateral currently reported in items 16.b.(4) through 16.b.(6) within the collateral amount
reported in the respective columns of item 16.b.(7). The agencies no longer need the separate
breakout of these types of collateral in the Call Report for institutions filing the FFIEC 041.
The agencies also propose to reduce the reporting frequency of items 1.b.(1), 1.b.(2),
11.a, and 11.b from quarterly to semiannual (June 30 and December 31), as the agencies no
longer need these data in the Call Report as frequently. This proposal is consistent with industry
comments and feedback recommending a shorter reporting form for two of the four quarters each
year.

12

Schedule RC-M
For the FFIEC 041, the agencies propose to consolidate items 2.b and 2.c, which provide
data on certain identifiable intangible assets, into a single item 2.c,15 and to consolidate other real
estate owned items 3.c and 3.f into a single item 3.c, as the agencies no longer need the current
level of detail in the Call Report that is provided in these separate items. As discussed earlier
under Schedule RC, the agencies are moving the goodwill amount formerly reported in Schedule
RC, item 10.a, to a recaptioned item 2.b on Schedule RC-M. The agencies also propose to
reduce the reporting frequency for items 9 (website transactional capability), 14.a (captive
insurance subsidiary assets), and 14.b (captive reinsurance subsidiary assets) from quarterly to
annual (December 31), as the agencies no longer need these data in the Call Report as frequently.
Schedule RC-N
For the FFIEC 041, the agencies propose to reduce the reporting frequency of
Memorandum items 7 and 8 on nonaccrual assets and Memorandum items 9.a and 9.b (columns
A through C) on purchased credit-impaired loans from quarterly to semiannual (June 30 and
December 31), as the agencies no longer need these data in the Call Report as frequently. In
connection with this proposed change, Memorandum items 7 and 8 would collect data on
additions to nonaccrual assets and nonaccrual asset sales, respectively, during the preceding six
months rather than the preceding quarter as at present. This proposal is consistent with industry
comments and feedback recommending a shorter reporting form for two of the four quarters each
year.
C. Revisions to the FFIEC 031
Scope Revision
The agencies propose to revise the scope of the FFIEC 031 to require all institutions with
consolidated total assets of $100 billion or more to file this form, regardless of whether an
institution has any foreign offices. The agencies are proposing this change because institutions
with consolidated total assets of $100 billion or more without foreign offices are considered to
have a similar degree of complexity in their activities as institutions of this size with foreign
offices that currently file the FFIEC 031.
Schedule RI
For the FFIEC 031, the agencies propose to change the reporting threshold for reporting
information on trading revenues in Memorandum items 8.a through 8.e. Currently, these items
are completed by institutions that reported average trading assets of $2 million or more for any
quarter of the preceding calendar year. The agencies propose to modify the reporting threshold
for Memorandum items 8.a through 8.e to instruct that these items be completed by institutions
that reported total trading assets of $10 million or more for any quarter of the preceding calendar
year, as the agencies no longer need this level of detail in the Call Report from institutions with
15

As explained in the description of the proposed revisions to Schedule RC of the FFIEC 041, existing item 2.b of
Schedule RC-M would be replaced by a revised item 2.b for reporting goodwill.

13

lower levels of trading assets. In addition, the agencies propose to reduce the reporting
frequency of Memorandum item 12 from quarterly to semiannual (June 30 and December 31), as
the agencies no longer need this data in the Call Report as frequently.
Schedule RI-D
For the FFIEC 031, the agencies propose to change the reporting threshold for
completing this schedule. Currently, this schedule is required to be completed by an institution
when its foreign office revenues, assets, or net income exceed 10 percent of consolidated total
revenues, total assets, or net income. The agencies propose to add an additional threshold that an
institution must have foreign office assets of $10 billion or more and also meet one of the three
10 percent tests before the schedule is required, as the agencies no longer need foreign office
income data in the Call Report from institutions with a lesser amount of foreign office assets.
Schedule RI-E
For the FFIEC 031, the agencies propose to remove the preprinted captions for items 1.f
and 1.h, as few institutions report having these components of other noninterest income in
amounts in excess of the existing reporting threshold for disclosing these components.16 The
remaining items 1.g and 1.i through 1.l would be renumbered as items 1.f through 1.j.
In addition, after reviewing the agencies’ data needs along with industry comments and
feedback requesting a higher threshold for disclosing components of other noninterest income
and other noninterest expense in Schedule RI-E, the agencies propose to increase the percentage
portion of the existing threshold for reporting other noninterest income components in items 1.a
through 1.j and other noninterest expense components in items 2.a through 2.p. The proposed
threshold for disclosing components of other noninterest income and other noninterest expense
would be amounts greater than $100,000 that exceed seven percent of Schedule RI, item 5.l, and
item 7.d, respectively.17 This percentage is currently three percent. Upon evaluating the impact
of each percentage threshold, the agencies determined that a percentage threshold of seven
percent would provide a meaningful reduction in reporting burden without a loss of data that
would be necessary for supervisory or other public policy purposes.
Schedule RC
For the FFIEC 031, the agencies propose to move the reporting of goodwill from existing
item 10.a on the balance sheet to Schedule RC-M, item 2.b (as discussed further below), and
combine existing items 10.a and 10.b on Schedule RC into a single item 10. This would
consolidate the reporting of goodwill and other intangible assets on Schedule RC into a single
balance sheet item for intangible assets. This proposed revision to Schedule RC was requested
by a commenter on the agencies’ August 2016 Call Report proposal to facilitate institutions’
16

If an institution has the component of other noninterest income currently disclosed in item 1.f or 1.h in an amount
in excess of the reporting threshold, it would itemize and describe this component in one of the subitems of item 1
without a preprinted caption.
17
The agencies increased the dollar portion of this reporting threshold from $25,000 to $100,000 effective
September 30, 2016.

14

reporting by making their Call Report processes more efficient and better focused.18 While the
agencies believe the reporting and disclosure of an institution’s goodwill detail is important, the
agencies are indifferent as to the location of the information in the Call Report.
Schedule RC-B
For the FFIEC 031, the agencies propose to consolidate the reporting of an institution’s
holdings of U.S. government agency obligations, which are currently reported in items 2.a and
2.b, into a single item 2, and to consolidate the reporting of structured financial product holdings,
which are currently reported in items 5.b.(1) through 5.b.(3), into a single item 5.b, as the
agencies no longer need the current level of detail in the Call Report for these holdings.
Institutions would still be required to report amortized cost and fair value information in columns
A through D for the proposed items 2 and 5.b. The agencies also propose to reduce the reporting
frequency of the data on sales and transfers of held-to-maturity securities reported in
Memorandum item 3 from quarterly to semiannual (June 30 and December 31), as the agencies
no longer need these data items as frequently in the Call Report. The agencies also propose to
add a reporting threshold of $10 billion or more in total assets before institutions must complete
Memorandum items 5.a though 6.g, columns A through D, as the agencies no longer need this
information in the Call Report from institutions under this proposed threshold.
Schedule RC-C, Part I
For the FFIEC 031, the agencies propose to reduce the reporting frequency of
Memorandum items 7.a, 7.b, 8.a, 8.b, 8.c, and 12.a through 12.d (columns A through C) from
quarterly to semiannual (June 30 and December 31), as the agencies no longer need these loan
data in the Call Report as frequently.
Schedule RC-D
For the FFIEC 031, the agencies propose to change the reporting threshold for the overall
schedule so that the schedule would be applicable to institutions with total trading assets of $10
million or more in any of the four preceding calendar quarters from the current threshold of $2
million or more in average trading assets over this same period. In addition, all institutions
meeting the FDIC’s definition of a large institution or a highly complex institution for deposit
insurance assessment purposes would be required to complete Schedule RC-D. The agencies are
proposing this reporting threshold change because they no longer need to collect the existing
detailed data in the Call Report from institutions with a lesser amount of trading assets that are
not large or highly complex institutions.
•
•
•

The agencies also propose to consolidate:
Structured financial products in items 5.a.(1) through 5.a.(3) into a single item 5.a;
Loan detail in current items 6.a.(1), 6.a.(2), 6.a.(4), and 6.a.(5) into a single new item
6.a.(2);
Certain residential loan detail in current items 6.a.(3)(a) through 6.a.(3)(b)(2) into a single

18

See 82 FR 2444 (January 9, 2017) for discussion of the comments received on the August 2016 Call Report
proposal.

15

•
•
•
•

new item 6.a.(1);
Consumer loan information in items 6.c.(1) through 6.c.(4) into a single item 6.c;
Loan detail in Memorandum items 1.a.(1), 1.a.(2), 1.a.(4), and 1.a.(5) into a single new
Memorandum item 1.a.(2);
Certain residential loan detail in Memorandum items 1.a.(3)(a) through 1.a.(3)(b)(2) into
a single new Memorandum item 1.a.(1); and
Consumer loan information in Memorandum items 1.c.(1) through 1.c.(4) into a single
new Memorandum item 1.c.

The agencies no longer need to collect the current level of detail in the Call Report from
those institutions that would be required to complete Schedule RC-D under its proposed revised
reporting threshold.
The agencies also propose to remove column B (domestic offices) for all items on
Schedule RC-D, except for items 12 and 15 on total trading assets and total trading liabilities in
domestic offices, respectively, which will be moved to Schedule RC-H, Selected Balance Sheet
Items for Domestic Offices. In addition, the agencies would replace the detailed data on loans
held for trading in domestic offices that is reported in items 6.a.(1) through 6.d, column B, of
Schedule RC-D with a single new item for total loans held for trading in domestic offices that
would be added to Schedule RC-H. The agencies propose these changes as they no longer need
separately reported data in the Call Report on assets and liabilities held for trading in domestic
offices other than for the three items on total trading assets, total trading liabilities, and total
loans held for trading in domestic offices that would be reported in Schedule RC-H. Institutions
would continue to report amounts in Schedule RC-D only for the consolidated entity, which they
currently report in column A.
In addition, the agencies propose to add a reporting threshold of $10 billion or more in
total trading assets before an institution would be required to complete Memorandum items 2.a
though 5.f and 7.a through 10, as the agencies no longer need this level of detail in the Call
Report from institutions with a lesser amount of trading assets. The agencies also propose to
remove Memorandum item 6, as the agencies no longer need this information.
Schedule RC-H
For the FFIEC 031, in connection with removing the separate detail for trading assets and
liabilities in domestic offices from Schedule RC-D, the agencies propose to retain and relocate
selected data items to Schedule RC-H, Selected Balance Sheet Items for Domestic Offices. As
noted above, the agencies propose relocating total trading assets and total trading liabilities in
domestic offices from Schedule RC-D, column B, items 12 and 15, to Schedule RC-H, new
items 19 and 20, respectively. Also, the agencies propose to aggregate all loans held for trading
in domestic offices currently reported on Schedule RC-D, column B, items 6.a through 6.d
(including all subitems), into a single new item, Schedule RC-H, item 21. These three items
would be completed by institutions that reported total trading assets of $10 million or more in
any of the four preceding calendar quarters and by all institutions meeting the FDIC’s definition
of a large or highly complex institution for deposit insurance assessment purposes. The agencies
believe relocating this data from Schedule RC-D to Schedule RC-H will improve efficiency by

16

consolidating additional domestic office information on Schedule RC-H.
Schedule RC-K
For the FFIEC 031, the agencies propose to add a reporting threshold for item 7 on
average trading assets. This item would only need to be completed by institutions with $10
million or more in total trading assets in any of the four preceding calendar quarters and by all
institutions meeting the FDIC’s definition of a “large institution” or a “highly complex
institution” for deposit insurance assessment purposes. This proposed new reporting threshold is
consistent with the proposed revised threshold for completing Schedule RC-D discussed above.
The agencies no longer need this information in the Call Report each quarter from institutions
with less than $10 million in trading assets that are not large or highly complex institutions.
Schedule RC-L
For the FFIEC 031, the agencies propose to consolidate items 1.a.(1) and 1.a.(2) into a
single item 1.a.(1), as the agencies no longer need the current level of detail for these types of
unused commitments. The agencies also propose to remove column B for items 16.a through
16.b.(8), and instead include these data on over-the-counter derivatives within column E for
derivatives with all other counterparties. The agencies no longer need the separate detail in the
Call Report provided by the disaggregated data on over-the-counter derivatives for monoline
financial guarantors in column B. The agencies also propose to reduce the reporting frequency
of items 1.b.(1), 1.b.(2), 11.a, and 11.b from quarterly to semiannual (June 30 and December 31),
as the agencies no longer need these data in the Call Report as frequently.
Schedule RC-M
For the FFIEC 031, the agencies propose to consolidate items 2.b and 2.c, which provide
data on certain intangible assets, into a single item 2.c,19 and to consolidate other real estate
owned items 3.c and 3.f into a single item 3.c, as the agencies no longer need the current level of
detail in the Call Report that is provided in these separate items. As discussed earlier under
Schedule RC, the agencies are moving the goodwill amount formerly reported in Schedule RC,
item 10.a, to a recaptioned item 2.b on Schedule RC M. The agencies also propose to reduce the
reporting frequency for items 9 (website transactional capability), 14.a (captive insurance
subsidiary assets), and 14.b (captive reinsurance subsidiary assets) from quarterly to annual
(December 31), as the agencies no longer need these data in the Call Report as frequently.
Schedule RC-N
For the FFIEC 031, the agencies propose to reduce the reporting frequency of
Memorandum items 7 and 8 on nonaccrual assets and Memorandum items 9.a and 9.b on
purchased credit-impaired loans from quarterly to semiannual (June 30 and December 31), as the
agencies no longer need these data in the Call Report as frequently. In connection with this
proposed change, Memorandum items 7 and 8 would collect data on additions to nonaccrual
19

As explained in the description of the proposed revisions to Schedule RC of the FFIEC 031, existing item 2.b of
Schedule RC-M would be replaced by a revised item 2.b for reporting goodwill.

17

assets and nonaccrual asset sales, respectively, during the preceding six months rather than the
preceding quarter as at present.
D. Additional Proposed Revisions to All Versions of the Call Report
Proposed Call Report Revisions to Address Changes in Accounting for Equity
Investments
In January 2016, the Financial Accounting Standards Board (FASB) issued ASU 201601, “Recognition and Measurement of Financial Assets and Financial Liabilities.” In its
summary of this ASU, the FASB described how one of the main provisions of the ASU differs
from current U.S. generally accepted accounting principles (GAAP) as follows:
The amendments in this Update supersede the guidance to classify equity securities with
readily determinable fair values into different categories (that is, trading or available-forsale) and require equity securities (including other ownership interests, such as
partnerships, unincorporated joint ventures, and limited liability companies) to be
measured at fair value with changes in the fair value recognized through net income. An
entity’s equity investments that are accounted for under the equity method of accounting
or result in consolidation of an investee are not included within the scope of this Update.
The FASB further stated in the summary that “an entity may choose to measure equity
investments that do not have readily determinable fair values at cost minus impairment, if any,
plus or minus changes resulting from observable price changes in orderly transactions for the
identical or a similar investment of the same issuer.”
Section 37(a) of the Federal Deposit Insurance Act (12 U.S.C. 1831n(a)) states that, in
general, the accounting principles applicable to the Call Report “shall be uniform and consistent
with generally accepted accounting principles.” The agencies are maintaining consistency with
U.S. GAAP by implementing the provisions of ASU 2016 01 in the Call Report in accordance
with the effective dates set forth in the ASU. For institutions that are public business entities, as
defined in U.S. GAAP, ASU 2016-01 is effective for fiscal years beginning after December 15,
2017, including interim periods within those fiscal years. For all other institutions, the ASU is
effective for fiscal years beginning after December 15, 2018, and interim periods within fiscal
years beginning after December 15, 2019.
One outcome of the change in accounting for equity investments under ASU 2016-01 is
the elimination of the concept of available-for-sale (AFS) equity securities, which are measured
at fair value on the balance sheet with changes in fair value recognized through other
comprehensive income. At present, the historical cost and fair value of AFS equity securities,
i.e., investments in mutual funds and other equity securities with readily determinable fair values
that are not held for trading, are reported in Call Report Schedule RC-B, item 7, columns C and
D, respectively. The total fair value of AFS securities, which includes both debt and equity
securities, is then carried forward to the Call Report balance sheet and reported in Schedule RC,
item 2.b. In the FFIEC 041 and FFIEC 031 Call Reports, the total fair value of AFS securities
reported in Schedule RC, item 2.b, also is reported in item 1, column A, of Schedule RC-Q,

18

Assets and Liabilities Measured at Fair Value on a Recurring Basis, by institutions required to
complete this schedule.20 These institutions then report in columns C, D, and E of item 1 a
breakdown of their AFS debt securities by the level in the fair value hierarchy within which the
fair value amounts of these securities fall (Level 1, 2, or 3). Any balance sheet netting
adjustments to these fair value amounts are reported in column B of item 1.
In addition, the total fair value of AFS securities is reported in Schedule RC-R, Part II,
for risk-weighting purposes under the agencies’ regulatory capital rules. This fair value amount
is reported in Schedule RC-R, Part II, item 2.b, column A, except for the fair value of those AFS
securities that qualify as securitization exposures, which is reported in Schedule RC-R, Part II,
item 9.b, column A. To the extent appropriate under the regulatory capital rules, adjustments to
the fair values reported in column A of items 2.b and 9.b are reported in column B. The adjusted
amount in item 2.b is then allocated to the appropriate risk-weight category in columns C
through N. The adjusted amount of AFS securitization exposures in item 9.b is reported by riskweight category in column Q or by risk-weighted asset amount in column T or U based on the
risk-weighting approach or approaches applied by an institution.
At present, the accumulated balance of the unrealized gains (losses) on AFS equity
securities, net of applicable income taxes, that have been recognized through other
comprehensive income is included in accumulated other comprehensive income (AOCI), which
is reported in the equity capital section of the Call Report balance sheet in Schedule RC, item
26.b. With the elimination of AFS equity securities on the effective date of ASU 2016-01, the
net unrealized gains (losses) on these securities that had been included in AOCI will be
reclassified (transferred) from AOCI into the retained earnings component of equity capital,
which is reported on the Call Report balance sheet in Schedule RC, item 26.a. After the effective
date, changes in the fair value of (i.e., the unrealized gains and losses on) an institution’s equity
securities that would have been classified as AFS had the previously applicable accounting
standards remained in effect will be recognized through net income rather than other
comprehensive income.
The effect of the elimination of AFS equity securities as a distinct asset category upon
institutions’ implementation of ASU 2016-01 carries over to the agencies’ regulatory capital
rules. Under these rules, institutions that are eligible to and have elected to make the AOCI optout election deduct net unrealized losses on AFS equity securities from common equity tier 1
capital and include 45 percent of pretax net unrealized gains on AFS equity securities in tier 2
capital. For purposes of reporting regulatory capital components and ratios in the Call Report,
the deduction of these net unrealized losses is currently effected through the combination of
Schedule RC-R, Part I, items 9.a, “LESS: Net unrealized gains (losses) on available-for-sale
securities,” and 9.b, “LESS: Net unrealized loss on available-for-sale preferred stock classified
as an equity security under GAAP and available-for-sale equity exposures.” The inclusion of 45
percent of pretax net unrealized gains in tier 2 capital currently occurs through the reporting of
this percentage of an institution’s gains in Schedule RC-R, Part I, item 31, “Unrealized gains on
20

Schedule RC-Q is to be completed by (1) institutions that had total assets of $500 million or more as of the
beginning of their fiscal year and (2) other institutions that either have elected to report financial instruments or
servicing assets and liabilities at fair value under a fair value option or are required to complete Schedule RC-D,
Trading Assets and Liabilities. Schedule RC-Q is not included in the FFIEC 051 Call Report.

19

available-for-sale preferred stock classified as an equity security under GAAP and available-forsale equity exposures includable in tier 2 capital.” When ASU 2016-01 takes effect and the
classification of equity securities as AFS is eliminated for accounting and reporting purposes
under U.S. GAAP, the concept of unrealized gains and losses on AFS equity securities will
likewise cease to exist.
Another outcome of the change in accounting for equity investments under ASU 2016-01
is that equity securities and other equity investments without readily determinable fair values that
are within the scope of ASU 2016-01 and are not held for trading must be measured at fair value
through net income, rather than at cost (less impairment, if any), unless the measurement election
described above is applied to individual equity investments. In general, institutions currently
report their holdings of such equity securities without readily determinable fair values as a
category of other assets in Call Report Schedule RC-F, item 4. The total amount of an
institution’s other assets is reported on the Call Report balance sheet in Schedule RC, item 11.
At present, AFS equity securities and equity investments without readily determinable
fair values are included in the quarterly averages reported in Schedule RC K. Institutions report
the quarterly average for “All other securities” in item 4 of this schedule and this average reflects
AFS equity securities at historical cost. A quarterly average for total assets is reported in item 9
of Schedule RC-K. Among its uses, average total assets serves as the starting point for
determining the denominator for the tier 1 leverage ratio under the agencies’ regulatory capital
rules. The quarterly average for total assets currently reflects AFS equity securities at the lower
of cost or fair value and equity securities without readily determinable fair values at historical
cost. Finally, institutions with foreign offices report the fair value of their AFS equity securities
in domestic offices and the historical cost of their equity securities without readily determinable
fair values in domestic offices in Schedule RC-H, items 16 and 18, respectively, of the
FFIEC 031 Call Report. The domestic office holdings of these equity securities are components
of the AFS equity securities and equity securities without readily determinable fair values
reported on a consolidated basis in Schedule RC-B, item 7, and Schedule RC-F, item 4,
respectively.
The agencies have considered the changes to the accounting for equity investments under
ASU 2016-01 and the effect of these changes on the manner in which data on equity securities
and other equity investments is currently reported in the Call Report. The agencies also note
that, because of the different effective dates for ASU 2016-01 for public business entities and all
other entities, as well as the varying fiscal years across the population of institutions that file Call
Reports, the period over which institutions will be implementing this ASU ranges from the first
quarter of 2018 through the fourth quarter of 2020. December 31, 2020, will be the first quarterend Call Report date as of which all institutions would be required to prepare their Call Reports
in accordance with ASU 2016-01. As a result, the agencies are proposing revisions to the
reporting of information on equity securities and other equity investments in response to the
ASU that would be introduced in the Call Report effective March 31, 2018, but would not be
fully phased in until the Call Report for December 31, 2020. In developing these proposed Call
Report revisions, the agencies have followed the guiding principles for evaluating potential
additions and deletions of Call Report data items and other revisions to the Call Report identified
above. In following these principles, the agencies have sought to limit the number of data items

20

being added to the Call Report to address the changes in accounting for equity securities and
other equity investments.
The proposed Call Report revisions related to equity securities are as follows:
(1) To provide transparency to the effect of unrealized gains and losses on equity
securities not held for trading on an institution’s net income during the year-to-date reporting
period in Schedule RI, Income Statement, and to clearly distinguish these gains and losses from
the rest of an institution’s income (loss) from its continuing operations, Schedule RI, item 8,
would be revised effective March 31, 2018, by creating new items 8.a, “Income (loss) before
unrealized holding gains (losses) on equity securities not held for trading, applicable income
taxes, and discontinued operations,” and 8.b, “Unrealized holding gains (losses) on equity
securities not held for trading.” In addition to unrealized holding gains (losses) during the yearto-date reporting period on such equity securities with readily determinable fair values,
institutions also would report in proposed new item 8.b the year-to-date changes in the carrying
amounts of equity investments without readily determinable fair values not held for trading (i.e.,
unrealized holding gains (losses) for those measured at fair value through earnings; impairment,
if any, plus or minus changes resulting from observable price changes for those equity
investments for which this measurement election is made). Existing Schedule RI, item 8,
“Income (loss) before applicable income taxes and discontinued operations,” would be
renumbered as item 8.c, and would be the sum of items 8.a and 8.b. From March 31, 2018,
through September 30, 2020, the instructions for item 8.b and the reporting form for Schedule RI
would include guidance stating that item 8.b is to be completed only by institutions that have
adopted ASU 2016-01. Institutions that have not adopted ASU 2016-01 would leave item 8.b
blank when completing Schedule RI. Finally, from March 31, 2018, through September 30,
2020, the instructions for Schedule RI, item 6.b, “Realized gains (losses) on available-for-sale
securities,” and the reporting form for Schedule RI would include guidance stating that, for
institutions that have adopted ASU 2016-01, item 6.b includes realized gains (losses) only on
AFS debt securities. Effective December 31, 2020, the caption for item 6.b would be revised to
“Realized gains (losses) on available-for-sale debt securities.”
(2) On the FFIEC 031, certain institutions with foreign offices must complete Schedule
RI-D, Income from Foreign Offices. As stated in the instructions for Schedule RI-D, “[f]or the
most part, the income and expense items in Schedule RI-D mirror categories of income and
expense reported in Schedule RI.” However, Schedule RI-D collects much less detail on an
institution’s income and expense than Schedule RI. The instructions for Schedule RI would be
revised effective March 31, 2018, to indicate that, for institutions that have adopted ASU 201601, the amount of unrealized holding gains (losses) on equity securities not held for trading in
foreign offices that is included in Schedule RI, item 8.b, should be reported in Schedule RI-D,
item 5, “Realized gains (losses) on held-to-maturity and available-for-sale securities in foreign
offices.” Effective December 31, 2020, the caption for item 5 would be revised to “Realized
gains (losses) on held-to-maturity and available-for-sale debt securities and unrealized holding
gains (losses) on equity securities not held for trading in foreign offices.”
(3) In Schedule RC, Balance Sheet, a new item 2.c, “Equity securities with readily
determinable fair values not held for trading,” would be added effective March 31, 2018. From

21

March 31, 2018, through September 30, 2020, the instructions for item 2.c and the reporting
form for Schedule RC would include guidance stating that item 2.c is to be completed only by
institutions that have adopted ASU 2016-01. Institutions that have not adopted ASU 2016-01
would leave item 2.c blank. During this period, the instructions for Schedule RC, item 2.b,
“Available-for-sale securities,” would explain that institutions that have adopted ASU 2016 01
should include only debt securities in item 2.b. Effective December 31, 2020, the caption for
item 2.b would be revised to “Available-for-sale debt securities” and all institutions would report
their holdings of equity securities with readily determinable fair values not held for trading in
item 2.c.
(4) In Schedule RC-B, Securities, item 7, “Investments in mutual funds and other equity
securities with readily determinable fair values,” would be removed effective December 31,
2020. From March 31, 2018, through September 30, 2020, the instructions for item 7 and the
reporting form for Schedule RC-B would include guidance stating that item 7 is to be completed
only by institutions that have not adopted ASU 2016-01. Institutions that have adopted ASU
2016-01 would leave item 2.c blank.
(5) In Schedule RC-F, Other Assets, the caption for item 4 would be changed from
“Equity securities that DO NOT have readily determinable fair values” to “Equity investments
without readily determinable fair values” effective March 31, 2018. The types of equity
securities and other equity investments currently reported in item 4 would continue to be
reported in this item. However, after the effective date of ASU 2016-01 for an institution, the
securities the institution reports in item 4 would be measured in accordance with the ASU.
(6) In Schedule RC-H, Selected Balance Sheet Items for Domestic Offices, of the
FFIEC 031, item 16, “Investments in mutual funds and other equity securities with readily
determinable fair values,” would be removed effective December 31, 2020, and the caption for
item 17 would be changed from “Total held-to-maturity and available-for-sale securities (sum of
items 10 through 16)” to “Total held-to-maturity and available-for-sale debt securities (sum of
items 10 through 15).” From March 31, 2018, through September 30, 2020, the instructions for
item 16 and the reporting form for Schedule RC-H would include guidance stating that item 16 is
to be completed only by institutions that have not adopted ASU 2016-01. Institutions that have
adopted ASU 2016-01 would leave item 16 blank. In addition, effective March 31, 2018, item
18, “Equity securities that do not have readily determinable fair values,” would be replaced by
item 18.a, “Equity securities with readily determinable fair values,” and item 18.b, “Equity
investments without readily determinable fair values.” From March 31, 2018, through
September 30, 2020, the instructions for item 18.a and the reporting form for Schedule RC-H
would include guidance stating that item 18.a is to be completed only by institutions that have
adopted ASU 2016-01. Institutions that have not adopted ASU 2016-01 would leave item 18.a
blank. The types of equity securities and other equity investments without readily determinable
fair values that are currently reported in item 18 would be reported in item 18.b.
(7) In Schedule RC-K, Quarterly Averages, the caption for item 4, “All other securities,”
would be changed to “All other debt securities and equity securities with readily determinable
fair values not held for trading purposes” effective March 31, 2018. From March 31, 2018,
through September 30, 2020, the instructions for item 4 and the reporting form for Schedule RC-

22

K would include guidance indicating that, for institutions that have adopted ASU 2016-01, the
quarterly average for equity securities with readily determinable fair values should be based on
fair value and, for institutions that have not adopted ASU 2016-01, the quarterly average for such
equity securities (i.e., AFS equity securities) should be based on historical cost. Effective
December 31, 2020, this guidance would indicate that the quarterly average for equity securities
with readily determinable fair values not held for trading should be based on fair value, which
would apply to all institutions. In addition, for Schedule RC-K, item 9, “Total assets,” the
instructions for this item and the Schedule RC-K reporting form would include guidance from
March 31, 2018, through September 30, 2020, stating that, for purposes of reporting the quarterly
average for total assets:
• Institutions that have adopted ASU 2016-01 should reflect the quarterly average for
equity securities with readily determinable fair values at fair value and the quarterly
average for equity securities without readily determinable fair values at their balance
sheet carrying amounts (i.e., fair value or, if elected, cost minus impairment, if any, plus
or minus changes resulting from observable price changes), and
• Institutions that have not adopted ASU 2016-01 should reflect the quarterly average for
equity securities with readily determinable fair values at the lower of cost or fair value
and the quarterly average for equity securities without readily determinable fair values at
historical cost.
Then, effective December 31, 2020, the instructions for item 9 and the Schedule RC-K
reporting form would indicate that, for equity securities not held for trading, the quarterly
average for total assets should reflect such securities with readily determinable fair values at fair
value and those without readily determinable fair values at their balance sheet carrying amounts.
(8) In Schedule RC-Q on the FFIEC 041 and FFIEC 031, the caption for item 1,
“Available-for-sale securities,” would be changed to “Available-for-sale debt securities and
equity securities with readily determinable fair values not held for trading purposes” effective
March 31, 2018. From March 31, 2018, through September 30, 2020, the instructions for item 1
and the reporting form for Schedule RC-Q would include guidance stating that, for institutions
that have adopted ASU 2016-01, the amount reported in item 1, column A, must equal the sum
of Schedule RC, items 2.b and 2.c, and for institutions that have not adopted ASU 2016-01, the
amount reported in item 1, column A, must equal Schedule RC, item 2.b. Effective December
31, 2020, this guidance would indicate that the amount reported in item 1, column A, must equal
the sum of Schedule RC, items 2.b and 2.c.
(9) In Schedule RC-R, Part I, Regulatory Capital Components and Ratios, the
instructions for item 9.a and the Schedule RC-R reporting form would include guidance from
March 31, 2018, through September 30, 2020, stating that, for institutions that have not adopted
ASU 2016-01, item 9.a should include net unrealized gains (losses) on AFS debt and equity
securities and, for institutions that have adopted the ASU, item 9.a should include net unrealized
gains (losses) on AFS debt securities. During this same period, the instructions for item 9.b and
the Schedule RC-R reporting form would include guidance indicating that item 9.b is to be
completed only by institutions that have not adopted ASU 2016-01. Effective December 31,
2020, item 9.b would be removed and the caption for item 9.a would be revised to “LESS: Net
unrealized gains (losses) on available-for-sale debt securities.” In addition, from March 31,

23

2018, through September 30, 2020, the instructions for Schedule RC-R, Part I, item 31, and the
Schedule RC-R reporting form would include guidance indicating that item 31 is to be completed
only by institutions that have not adopted ASU 2016-01. During this period, institutions that
have adopted the ASU would leave item 31 blank. Then, effective December 31, 2020, item 31
would be removed from Schedule RC-R, Part I.
(10) In Schedule RC-R, Part II, Risk-Weighted Assets, revisions would be made to item
2 that correspond to those made to Schedule RC, item 2. A new item 2.c, “Equity securities with
readily determinable fair values not held for trading,” would be added to Schedule RC-R, Part II,
effective March 31, 2018. Applicable risk weights for new item 2.c would be 100 percent, 250
percent, 300 percent, and 600 percent; amounts also could be reported in columns R and S.
From March 31, 2018, through September 30, 2020, the instructions for item 2.c and the
reporting form for Schedule RC-R, Part II, would include guidance stating that item 2.c is to be
completed only by institutions that have adopted ASU 2016-01. During the same period, the
instructions for Schedule RC R, Part II, item 2.b, “Available-for-sale securities,” would explain
that institutions that have adopted ASU 2016-01 should include only debt securities in this item.
Effective December 31, 2020, the caption for item 2.b would be revised to “Available-for-sale
debt securities” and the 250 percent, 300 percent, and 600 percent risk weights plus columns R
and S would be removed from item 2.b.
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
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
available 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 Board to require these reports from all state member banks. The
obligation to respond is mandatory. Most of the information provided on the Call Reports is
publicly available. However, the following items are confidential: (1) the FDIC deposit

24

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, 14-15, and 18 on schedule RC-O. This
information can be exempt from disclosure under (b)(8) of the Freedom of Information Act
(FOIA) which specifically exempts from disclosure information “contained in or related to
examination, operating, or condition reports prepared by, on behalf of, or for the use of an
agency responsible for the regulation or supervision of financial institutions” (5 U.S.C. 552
(b)(8)).
It is possible to reverse engineer an institution’s Capital, Asset Quality, Management,
Earnings, Liquidity, and Sensitivity (CAMELS) rating based on the data reported under the
FDIC deposit insurance assessment data item and the prepaid deposit insurance assessments data
item. Thus, if this information is publicly available, it would be possible to determine the state
member bank’s CAMELS rating. Public release of this information could cause substantial harm
to an institution because, for example, if an institution has a poor CAMELS rating, it would
likely impact the institution’s pricing, overall marketplace ratings, and its ability to obtain
funding. Therefore, this information can be kept confidential under section (b)(4) (5 U.S.C.
552(b)(4)). The release of information regarding other data for deposit insurance and FICO
assessments reported in response to memorandum items 6-9, 14-15, and 18 on schedule RC-O
would likely cause substantial harm to the competitive position of the institution from whom the
information was obtained if it was released. Therefore, this information can also be kept
confidential under section (b)(4) (5 U.S.C. 552(b)(4)).
Consultation Outside the Agency and Discussion of Public Comments
On June 27, 2017, the agencies, under the auspices of the FFIEC, published an initial
notice in the Federal Register (82 FR 29147) requesting public comment for 60 days on the
extension, with revision, of the Call Reports. The comment period for this notice expired on
August 28, 2017. The agencies collectively received comments from 13 entities, including
banking organizations, bankers’ associations, and a government entity. General comments and
recommendations on the FFIEC 031, FFIEC 041, and FFIEC 051 Call Reports are included in
this section. The agencies provide information regarding comments on specific aspects of the
proposed revisions to the Call Reports in more detail below.
Comments on the Overall Proposal and the Burden-Reduction Initiative
Commenters expressed mixed opinions on the June 2017 notice and the agencies’ Call
Report burden-reduction initiatives to date. Seven commenters representing banking
organizations and bankers’ associations supported the effort put forth by the agencies. One
bankers’ association stated that it “appreciates the time and effort the FFIEC has devoted to
identifying opportunities to reduce the burdens associated with the Call Report requirements.”
The commenter went on to say that the removal or change in reporting frequency of line items or
increase to reporting thresholds “serves as needed clean-up of the Call Report.” Three banking
organizations also “appreciate” the agencies’ initiatives focused on reducing the burden
associated with the Call Reports. The government entity stated it uses certain data items in the

25

Call Report in preparing national economic reports, and encouraged the agencies to continue
collecting those items.
On the other hand, the majority of the comment letters asserted that the proposed
revisions to the Call Reports would provide no real savings in effort or cost for smaller
institutions and that the overall reduction in burden is of limited value to such institutions. One
of the banking organizations and two of the bankers’ associations further indicated that reducing
reporting frequency would provide only “limited relief.” These commenters noted that
regardless of whether cumulative data is reported every quarter or every six months, institutions
would still need to gather the data on a quarterly basis in order to produce the reported data on a
semiannual basis. Two bankers’ associations responded that combining data items also would
not provide any relief to institutions, because processes are already in place to gather the
information separately. One banking organization and one bankers’ association stated that the
proposed revisions would increase burden due to the system changes that would be necessary to
modify the processes currently in place, such as deactivating or reactivating each quarter the
reporting of data items that would change from a quarterly to a semiannual or annual reporting
frequency.
The agencies recognize that not all institutions would see an immediate and large
reduction in burden from the proposed revisions in the June 2017 notice. However, reducing the
frequency of collection for certain data items or consolidating existing data items into fewer data
items would result in institutions spending less time completing the Call Report since there
would be fewer items to review prior to each quarterly submission. Also, an institution would
have fewer instructions to review to determine whether it has reportable (nonzero) amounts. To
the extent that an institution currently tracks granular data items that are proposed to be
consolidated, there may be limited burden relief from consolidating the items. However,
institutions that currently track data at an aggregate level and then must allocate that amount to
the existing subcategories every quarter would see additional burden relief. Accordingly, these
changes represent meaningful Call Report burden relief to institutions that do not engage in
complex activities.
Furthermore, as previously mentioned, internal surveys of users of Call Report data at
FFIEC member entities, including staff of the agencies, were one of the significant actions under
the FFIEC’s community bank Call Report burden-reduction initiative. The survey responses
have been the foundation for the statutorily mandated review of the existing Call Report data
items that the agencies have been conducting over the course of the burden-reduction initiative.
After completing this review, the statute directs the agencies to “reduce or eliminate any
requirement to file information or schedules . . . (other than information or schedules that are
otherwise required by law)” if the agencies determine that “the continued collection of such
information or schedules is no longer necessary or appropriate.” The findings from the agencies’
review revealed that certain information is no longer needed from some or all institutions, either
on a quarterly basis or at all, and that the current level of detail is no longer needed from some or
all institutions in certain Call Report schedules. Accordingly, for those Call Report data items
for which the results of the statutorily mandated review have triggered these conclusions, the
agencies are removing, consolidating, or reducing the reporting frequency of, or creating a new
or increased reporting threshold for, the affected Call Report data items notwithstanding any

26

system changes that institutions would need to make in response to these reporting changes.
Finally, in an effort to address the concerns of institutions relating to the proposed
reductions in frequency from quarterly to semiannual, the agencies note that the FFIEC’s Central
Data Repository (CDR)21 allows institutions to submit data quarterly, even if the data items are
only required to be reported semiannually or annually. This will permit institutions to choose to
avoid any perceived burden needed to reduce the reporting frequency from the quarterly
frequency required in the existing Call Report.
General Recommendations from Commenters
Three commenters suggested the agencies adopt a “short-form” Call Report to be filed
for at least two quarters of the year. The short-form Call Report recommended by two of these
commenters would consist only of an institution’s balance sheet, income statement, and
statement of changes in equity capital. The institution would file a full Call Report including all
supporting schedules in the second and fourth quarters, and the short-form Call Report in the first
and third quarters. The third commenter recommended including a limited number of additional
schedules in the first and third quarters to report more detailed information on loans and
regulatory capital, with additional schedules filed in the second and fourth quarters.
While the agencies understand the commenters’ desire for a short-form Call Report, the
agencies did not adopt this suggestion for the reasons noted in response to the comment letters
received on the August 2016 proposal for a streamlined Call Report for small institutions.22
Most notably, in addition to the basic financial statements, the most streamlined quarterly report
possible must also include data items required by law or regulation, along with quarterly data
necessary for adequate supervision by the agencies. Furthermore, the agencies leverage a
significant amount of the data reported quarterly in the more detailed general and supplemental
Call Report schedules when conducting off-site monitoring and determining the scope and
frequency of on-site examinations. Limiting the information collected on these schedules to
semiannual could significantly impair the agencies’ supervisory planning and review processes
and potentially lead to a less efficient use of supervisory resources.
One commenter recommended that the FFIEC establish an industry advisory committee
to develop advice and guidance on the Call Report and establish a regular forum to address
technical questions and new changes to the Call Report. In response, the agencies plan to
continue to offer outreach in connection with significant revisions to the Call Report, as they did
with the adoption of the revised Schedule RC-R, Regulatory Capital, and with the
implementation of the FFIEC 051. The agencies also receive and respond to a number of
questions from individual institutions each quarter. Issues that could affect multiple institutions
are often addressed through the Call Report Supplemental Instructions published quarterly or
updates to the Call Report instruction book published as needed. Consistent with the PRA, the
agencies also offer an opportunity for members of the banking industry to comment on proposed
21

The CDR is a secure, shared application for collecting, managing, validating, and distributing data reported in the
Call Report and the FDIC’s annual Summary of Deposits survey (OMB No. 3064-0061). The CDR also processes
and distributes the Uniform Bank Performance Report.
22
See 82 FR 2444 (January 9, 2017).

27

changes to the Call Report or to make any additional suggestions for improving, streamlining, or
clarifying the Call Report.
One commenter recommended that the agencies align the proposed revisions in the Call
Report with revisions to the FR Y-9C report for holding companies.23 The commenter stated that
having differences in reporting between the Call Report and FR Y-9C can create burden for
reporting firms. The agencies agree that aligning proposed revisions in the Call Report with
proposed revisions to comparable data items collected in the consolidated FR Y-9C report would
reduce burden for reporting holding companies. The Board will take this comment into
consideration when it develops proposed revisions to the FR Y-9C report.
One commenter recommended that the agencies increase the asset-size threshold for
filing the FFIEC 051 Call Report from the current $1 billion to at least $10 billion, indexed for
inflation. Raising the threshold to $10 billion or higher at this time could result in a significant
loss of data necessary for supervisory or other purposes from institutions with assets above $1
billion. Therefore, while the agencies are not adopting this recommendation at this time, the
agencies are continuing to evaluate the appropriate scope and criteria for expanding the number
of institutions eligible to file the FFIEC 051.
The agencies received three comment letters from banking organizations that highlighted
the burden required for their institutions to prepare Schedule RC-R, Regulatory Capital.
Reporting on Schedule RC-R is directly tied to the requirements in the agencies’ regulatory
capital rules.24
The agencies recently issued a proposal for modifications to simplify the regulatory
capital rules.25 To the extent changes contained in that proposal are adopted in a final rule, the
agencies would incorporate those simplifications into Schedule RC-R.
One commenter stated that Schedule RC-C, Part II, is particularly burdensome to
complete and should be eliminated. The agencies previously reduced the frequency of this
schedule from quarterly to semiannual for institutions filing the FFIEC 051.26 However, the
agencies cannot eliminate this schedule because the submission of information on small business
and small farm loans is specifically required by statute.27 Appendix A to the agencies’ January
2017 Federal Register notice (82 FR 2444) provides information about how the agencies use the
data reported in Schedule RC-C, Part II.
Specific Comments on the Proposed Call Report Revisions
A. Scope Revision
The agencies proposed to revise the scope of the FFIEC 031 Call Report to require all
23
24
25
26
27

Consolidated Financial Statements for Holding Companies, OMB No. 7100-0128.
See 12 CFR part 3 (OCC); 12 CFR part 217 (Board); 12 CFR part 324 (FDIC).
See 82 FR 49984 (October 27, 2017).
See 82 FR 2444 (January 9, 2017).
See section 122 of the Federal Deposit Insurance Corporation Improvement Act of 1991, Public Law 102-242.

28

institutions with consolidated total assets of $100 billion or more to file this form, regardless of
whether an institution has any foreign offices. The agencies proposed this change because
institutions with consolidated total assets of $100 billion or more without foreign offices are
considered to have a similar degree of complexity in their activities as institutions of this size
with foreign offices that currently file the FFIEC 031.
The agencies received two comments opposing the proposed scope revision.
One bankers’ association stated that the proposal could be viewed as creating three Call Reports
for larger banks, which could create a problem if the reports evolve and do not remain aligned in
the future. Another bankers’ association opposed the agencies’ use of a size-based threshold
alone (i.e., $100 billion or more in assets) to revise the scope of the FFIEC 031, rather than
looking at the business model and risk profile of an institution.
The agencies are proceeding with the proposed scope revision of the FFIEC 031 to
include all institutions with foreign offices and all institutions with consolidated total assets of
$100 billion or more. The agencies note that this revision would affect only five institutions, as
the majority of institutions with assets of $100 billion or more also have foreign offices and
currently file the FFIEC 031. Currently, the FFIEC 031 and FFIEC 041 collect the same
information on an institution’s domestic office activities. When preparing the FFIEC 031,
institutions with no foreign offices would not need to report items that request information on
foreign offices, including the entirety of Schedules RI-D; RC-E, Part II; and RC-I; nor would
they need to complete Schedule RC-H, which collects certain domestic office data. These
institutions also would report the same amounts for “domestic offices” and “consolidated bank”
in other schedules that request this breakout, which would not require these institutions to
compile additional information. In addition, there is currently a single set of Call Report
instructions for both the FFIEC 031 and FFIEC 041, which helps promote consistency in
reporting between those versions of the Call Report and should reduce the burden of a transition
for the affected institutions. As noted in the June 2017 notice, the agencies consider all
institutions with $100 billion or more in total assets to be of similar complexity. Institutions of
this size typically have similar business activities and risk profiles for their domestic operations,
and the agencies’ examiners review these domestic operations in a similar manner. Receiving
information from all institutions in this size category on the same Call Report form will improve
the agencies’ ability to perform comparisons among these institutions’ domestic operations. This
proposed scope revision also has enabled the agencies to propose removing items from, or
consolidating a significant number of items in, the FFIEC 041 form,28 as the agencies believe
these items are no longer necessary based on the business activities and risk profiles of
institutions with domestic offices only and consolidated total assets less than $100 billion.
B. Burden-Reducing Revisions
The agencies received two comments from banking organizations on the proposed
revisions to Schedule RI-E to reduce the reporting frequency of the data items for significant
components of “other noninterest income” and “other noninterest expense” from quarterly to
annual in the FFIEC 051 and increase the percentage threshold for reporting individual
components in all three versions of the Call Report. One commenter noted this revision would
28

See 82 FR 51908 (November 8, 2017).

29

actually reduce burden in preparing the reports. The other commenter stated that his
organization does not meet the existing thresholds to separately report noninterest income and
expense components on that schedule, so the reporting burden would not change.
After considering these specific comments, as well as the comments received on the
overall proposal and the burden-reduction initiative that were discussed above, the agencies will
proceed with the proposed burden-reducing changes to Schedule RI-E, along with all other
burden-reducing changes to Call Report schedules proposed in the June 2017 notice. The
agencies recognize that not every proposed change will reduce burden for every institution.
However, the agencies believe that the proposed changes will reduce burden in the Call Reports
as a whole, which is also reflected in a reduction in the estimated burden hours per quarter for
the Call Reports.
C. Instructional Revision for the Reporting of Assets as “Past Due”
Under the current Call Report instructions, closed-end installment loans, amortizing loans
secured by real estate, and other loans and lease financing receivables with payments scheduled
monthly are to be reported as past due in Schedule RC-N, Past Due and Nonaccrual Loans,
Leases, and Other Assets, when the borrower is in arrears two or more monthly payments. This
means that a loan is to be reported as past due if two monthly payments have not been received
by the close of business on the due date of the second monthly payment. Similarly, the Call
Report instructions provide that open-end credit such as credit cards, check credit, and other
revolving credit plans are to be reported as past due when the customer has not made the
minimum payment for two or more billing cycles. The instructions also provide that, at an
institution’s option, loans and leases with payments scheduled monthly may be reported as past
due when one scheduled payment is due and unpaid for 30 days or more.
The agencies note there is an existing widely used industry standard, known as the
Mortgage Bankers Association (MBA) method, which provides that loans with payments
scheduled monthly become 30 days past due if a monthly payment is not received by the end of
the day immediately preceding the loan’s next due date. The agencies understand that the MBA
method is used by most major mortgage data repositories, including the three major credit
bureaus and two major mortgage loan data processing service bureaus used by institutions. The
MBA method is also used by reporting forums such as the MBA, McDash Analytics, and the
OCC Mortgage Metrics Reports.
Therefore, to promote the use of a consistent standard in the industry and reduce the
burden for certain institutions calculating past-due loans under two methods (i.e., one method for
Call Report purposes and a different method for other reporting purposes), the agencies proposed
in the June 2017 notice to modify the definition of “past due” for regulatory reporting purposes
that is currently contained in the general instructions of Schedule RC-N to align with the MBA
method. Specifically, under that proposal, closed-end installment loans, amortizing loans
secured by real estate, and other loans and lease financing receivables with payments scheduled
monthly, as well as open-end credit such as credit cards, check credit, and other revolving credit
plans with payments scheduled monthly, would be reported as past due in Schedule RC-N if a
payment is not received by the end of the day immediately preceding the loan’s next payment

30

due date.
The agencies received comments from two bankers’ associations and three banking
organizations regarding the proposed instructional revision to the definition of “past due.” These
commenters generally opposed the proposed revision. All commenters cited increased burden
related to operational difficulties to implement the change as well as concerns about how this
definitional change would flow through to or affect other reporting requirements. Operational
challenges cited by commenters include substantial processing system changes; the need to
modify contracts with third-party vendors, loan securitization agreements, and other legal
agreements; communication issues with loan servicing customers; and coordination issues with
third-party vendors to implement the proposed revision. Other related reporting concerns
include possible restatements of audited financial statements and filings with the Securities and
Exchange Commission; the effect on the calculation of the allowance for loan and lease losses;
the impact on the risk weighting associated with delinquent and nonaccrual loans as reported on
Schedule RC-R, Regulatory Capital; the use of performing loans as inputs for stress testing and
recovery and resolution planning purposes; the impact on liquidity reporting; and the impact on
the calculation of surcharge scores assessed to global systemically important banks (G-SIBs).
Additionally, one bankers’ association stated that the proposed instructional change would
remove the current reporting flexibility for institutions to use a combination of actual-day count,
the MBA method, and the current Call Report method based on the institutions’ particular
portfolios.
Based on the issues raised in the comments received on the proposed instructional
revision to the definition of past due, the agencies are giving further consideration to this
proposal, including its effect on and relationship to other regulatory reporting requirements.
Accordingly, the agencies are not proceeding with this proposed instructional revision and the
existing instructions for the definition of past due will remain in effect.
D. Proposed Call Report Revisions to Address Changes in Accounting for Equity
Investments
In January 2016, the Financial Accounting Standards Board (FASB) issued Accounting
Standards Update (ASU) No. 2016-01, “Recognition and Measurement of Financial Assets and
Financial Liabilities.” As one of its main provisions, the ASU requires certain investments in
equity securities (including other ownership interests, such as interests in partnerships,
unincorporated joint ventures, and limited liability companies) to be measured at fair value with
changes in fair value recognized in net income (fair value through net income).
Section 37(a) of the Federal Deposit Insurance Act (12 U.S.C. 1831n(a)) states that, in
general, the accounting principles applicable to the Call Report “shall be uniform and consistent
with generally accepted accounting principles.” The agencies are maintaining consistency with
U.S. GAAP by implementing the provisions of ASU 2016-01 in the Call Report in accordance
with the effective dates set forth in the ASU. For institutions that are public business entities, as
defined in U.S. GAAP, ASU 2016-01 is effective for fiscal years beginning after December 15,
2017, including interim periods within those fiscal years. For all other institutions, the ASU is
effective for fiscal years beginning after December 15, 2018, and interim periods within fiscal

31

years beginning after December 15, 2019.
Based on their consideration of the changes in the accounting for equity investments
under ASU 2016-01 and the effect of these changes on the manner in which data on equity
securities and other equity investments are currently reported in the Call Report, the agencies
proposed to revise the reporting of information on equity securities and other equity investments
in Call Report Schedules RI, Income Statement; RI-D, Income from Foreign Offices (on the
FFIEC 031); RC, Balance Sheet; RC-B, Securities; RC-F, Other Assets; RC-H, Selected Balance
Sheet Items for Domestic Offices (on the FFIEC 031); RC-K, Quarterly Averages; RC-Q, Assets
and Liabilities Measured at Fair Value on a Recurring Basis (on the FFIEC 041 and FFIEC 031);
and RC-R, Regulatory Capital.29
In developing the proposed revisions to these Call Report schedules, the agencies sought
to limit the number of data items being added to the Call Report to address the changes in
accounting for equity securities and other equity investments.
Furthermore, because of the different effective dates for ASU 2016-01 for public
business entities and all other entities, as well as the varying fiscal years across the population of
institutions that file Call Reports, the period over which institutions will be implementing this
ASU ranges from the first quarter of 2018 through the fourth quarter of 2020. As a result, the
agencies proposed to introduce the revisions to the reporting of information on equity securities
and other equity investments in response to the ASU in the Call Report effective March 31,
2018.
The agencies received comments from two banking organizations and two bankers’
associations addressing the proposed Call Report revisions related to equity securities. Both
bankers’ associations expressed general support for the proposed changes to reporting of
information on equity securities and other equity investments. However, for an institution that
has adopted the new accounting standard, the associations sought clarification of the appropriate
categorization on the proposed revised Call Report balance sheet (Schedule RC) of equity
securities with readily determinable fair values that are bought and sold on a regular basis, but
are not held with the intention of trading as this term is defined in the agencies’ market risk
rules.30 The agencies note that, for purposes of categorizing assets and liabilities on the Call
Report balance sheet, they do not apply the trading definition in the market risk rules. Rather,
the Call Report instructions state that:
Trading activities typically include (a) regularly underwriting or dealing in securities;
interest rate, foreign exchange rate, commodity, equity, and credit derivative contracts;
other financial instruments; and other assets for resale, (b) acquiring or taking positions in
such items principally for the purpose of selling in the near term or otherwise with the
intent to resell in order to profit from short-term price movements, and (c) acquiring or
taking positions in such items as an accommodation to customers or for other trading
29

See 82 FR 29158-29159 (June 27, 2017) for complete descriptions of the proposed revisions to these schedules.
The market risk rules define a “trading position” as a position held “for the purpose of short-term resale or with
the intent of benefiting from actual or expected short-term price movements, or to lock in arbitrage profits.” See 12
CFR 3.202 (OCC), 12 CFR 217.202 (Board), and 12 CFR 324.202 (FDIC).
30

32

purposes.31
Thus, when an institution’s holdings of equity securities with readily determinable fair values fall
within the scope of the preceding description of trading activities, the equity securities should be
reported as trading assets in Schedule RC, item 5. Otherwise, the equity securities should be
reported in new item 2.c, “Equity securities with readily determinable fair values not held for
trading.” The agencies will modify the Call Report instructions to make this distinction more
clear.
One banking organization noted that the proposal aligns the Call Report with the new
accounting standard for equity investments, but it requested clarification of the balance sheet
categorization of money market mutual funds following the adoption of the accounting standard.
This organization observed that the Securities and Exchange Commission’s rules permit such
funds to be categorized as cash equivalents in financial statements filed with the Commission if
appropriate criteria are met. The organization asked whether the agencies intended to permit a
similar categorization for Call Report purposes. The Call Report does not recognize cash
equivalents as part of “Cash and balances due from depository institutions,” as described in the
instructions for Schedule RC, item 1. Thus, for Call Report purposes, an institution that has
adopted ASU 2016-01 should report its investments in money market mutual funds with readily
determinable fair values, which are considered equity securities for accounting purposes,32 in
new Schedule RC, item 2.c, provided these investments are not held for trading (as discussed
above). The agencies also will revise the Call Report instructions to clarify the reporting of
money market mutual funds as equity securities, not as cash.
The other banking organization supported the proposed changes to the income statement
for reporting unrealized holding gains (losses) on equity securities not held for trading, but
recommended excluding unrealized gains on equity securities from tier 1 capital for regulatory
capital purposes as is currently the case under today’s accounting standards. The manner in
which unrealized gains on equity securities are reported for regulatory capital purposes in Call
Report Schedule RC-R depends entirely on how these unrealized gains are treated under the
agencies’ regulatory capital rules. After an institution adopts ASU 2016-01, unrealized gains on
the institution’s investments in equity securities with readily determinable fair values not held for
trading will be recognized in net income and, hence, retained earnings. Because retained
earnings is a common equity tier 1 (CET1) capital element under the agencies’ regulatory capital
rules, the operation of these rules will automatically result in the inclusion of all unrealized gains
on such equity securities in CET1 capital after an institution’s adoption of ASU 2016-01.
Continuing to exclude unrealized gains on equity securities with readily determinable fair values
not held for trading from CET1 capital after the adoption of ASU 2016-01 would require
revisions to the agencies’ regulatory capital rules and is outside the scope of the proposed equity
securities reporting changes in the Call Report.
This banking organization also recommended retaining the existing regulatory framework
governing investments in stock set forth in section 362.3 of the FDIC’s regulations (12 CFR
See the instructions for Schedule RC, item 5, “Trading assets,” the General Instructions for Schedule RC-D,
Trading Assets and Liabilities, and the Glossary entry for “Trading Account” in the Call Report instructions.
32
See FASB Accounting Standards Codification paragraph 321-10-55-7.
31

33

362.3) and the related information on equity securities currently reported in Call Report Schedule
RC-B, Securities. More specifically, under section 362.3(a) of the FDIC’s regulations, an
insured state bank may not “directly or indirectly acquire or retain as principal any equity
investment of a type that is not permissible for a national bank.” However, this regulation
provides for the grandfathering of certain investments in equity securities by insured state banks
if certain conditions are met, including approval by the FDIC. The equity investments that are
authorized to be grandfathered are common and preferred stock listed on a national securities
exchange and shares of an investment company registered under the Investment Company Act of
1940.33 However, the FDIC’s regulations provide that an insured state bank’s aggregate
investment in these authorized investments “shall in no event exceed, when made, 100 percent of
the bank’s tier one capital” and that “[t]he lower of the bank’s cost as determined in accordance
with call report instructions or the market value” of the authorized investments “shall be used to
determine compliance.”34 At present, the cost basis and fair value of an insured state bank’s
grandfathered equity investments are included in the amounts reported in available-for-sale
columns C and D, respectively, of Call Report Schedule RC-B, item 7, “Investments in mutual
funds and other equity securities with readily determinable fair values.” These two Schedule
RC-B items currently serve as the starting point for assessing compliance with the limit on
grandfathered equity investments at those insured state banks that have received FDIC approval
to hold such investments. However, in their June 2017 proposal, the agencies proposed to
remove item 7, columns C and D, from Schedule RC-B effective December 31, 2020. From
March 31, 2018, through September 30, 2020, institutions that have adopted ASU 2016-01
would leave Schedule RC-B, item 7, columns C and D, blank.35 The fair value of the
“Investments in mutual funds and other equity securities with readily determinable fair values”
that these institutions had reported in Schedule RC-B, item 7, column D, before adopting ASU
2016-01 would instead be reported in new item 2.c, “Equity securities with readily determinable
fair values not held for trading,” on Schedule RC, Balance Sheet. However, under the June 2017
proposal, the cost of the equity securities reported in Schedule RC-B, item 7, column C, until an
institution’s adoption of ASU 2016-01 would no longer be reported after the institution’s
adoption of this new accounting standard because the standard eliminates the existing concept of
available-for-sale equity securities. Thus, the banking organization that commented on the issue
of grandfathered equity investments recommended the retention of the Call Report data items
used to measure compliance with the aggregate investment limit in these authorized investments.
After considering this banking organization’s recommendation as well as the provisions
of section 362.3(a) of the FDIC’s regulations, the agencies agree that, after its adoption of ASU
2016-01, an insured state bank that has been approved to hold authorized investments should
continue to report the cost of their holdings of equity securities with readily determinable fair
values not held for trading, which such an institution currently reports as available-for-sale
securities in column C of Schedule RC-B, item 7. The continued collection of this cost
information from insured state banks with grandfathered equity investments serves a long-term
regulatory purpose by aiding the supervisory staffs of the agencies that supervise these insured
state banks in performing their ongoing assessments of compliance with the aggregate limit on
33

See 12 CFR 362.3(a)(2)(iii)(A).
See 12 CFR 362.3(a)(2)(iii)(C).
35
During this period, only those institutions that have not yet adopted ASU 2016-01 would complete Schedule RCB, item 7, columns C and D.
34

34

such investments. Accordingly, in place of Schedule RC-B, item 7, column C, which would no
longer be applicable to institutions after their adoption of ASU 2016-01, and which would
ultimately be removed effective December 31, 2020, the agencies would add a new item 4, “Cost
of equity securities with readily determinable fair values not held for trading,” to Schedule RCM effective March 31, 2018. The new Schedule RC-M item would be completed only by
insured state banks that have adopted ASU 2016-01 and have been approved to hold
grandfathered equity investments. All other institutions would leave new Schedule RC-M, item
4, blank. The equity securities for which the cost would be reported in Schedule RC-M, item 4,
would be the same equity securities for which institutions that have adopted ASU 2016-01 would
report the fair value in new Schedule RC, item 2.c.
In addition, as previously mentioned, the agencies also received three comments from
banking organizations regarding the burden associated with Schedule RC-R, Regulatory Capital,
which is one of the schedules for which several revisions related to equity securities were
proposed. In this regard, a proposed change to this schedule was to add a new item 2.c, “Equity
securities with readily determinable fair values not held for trading,” to Schedule RC-R, Part II,
Risk-Weighted Assets, effective March 31, 2018. As proposed, this new item would be
completed only by institutions that had adopted ASU 2016-01 and, for such institutions,
Schedule RC-R, Part II, item 2.b, “Available-for-sale securities,” should include only debt
securities. Effective December 31, 2020, which is the quarter-end report date as of which all
institutions would be required to have adopted ASU 2016-01, the caption for item 2.b would be
revised to “Available-for-sale debt securities.” These proposed revisions correspond to the
changes the agencies proposed to make to the categories of securities reported on Schedule RC,
Balance Sheet.
The commenters who addressed Schedule RC-R recommended simplifying and
shortening the schedule to reduce burden. After considering the concerns expressed by
commenters about the burden of Schedule RC-R in relation to the proposed revisions to this
schedule for equity securities, the agencies have decided against adding a new item 2.c to Part II
of Schedule RC-R. Instead, the agencies would retain the existing risk-weighting reporting
process under which those equity securities with readily determinable fair values and debt
securities currently categorized as available-for-sale securities are reported together in item 2.b
of Schedule RC-R, Part II. To clarify the scope of item 2.b for institutions that have and have
not adopted ASU 2016-01, the agencies would change the caption for item 2.b to “Available-forsale debt securities and equity securities with readily determinable fair values not held for
trading” effective March 31, 2018.
All the other revisions to the reporting of information on equity securities and other
equity investments proposed by the agencies in response to the changes in the accounting
requirements for these types of assets would be implemented as proposed and would take effect
beginning as of March 31, 2018.36
Timing
The effective date for the implementation of the revisions to the FFIEC 031, FFIEC 041,
36

See 82 FR 29147, 29156-29159.

35

and FFIEC 051 to address the change in accounting for equity investments would be
March 31, 2018. However, the effective date for the implementation of all other revisions
described in this notice would be June 30, 2018.
The agencies originally proposed to implement the revisions proposed in the June 2017
notice, as well as those they expected to propose based on their evaluation of the responses to the
third and final portion of user surveys, as of March 31, 2018. However, on November 8, 2017,
the agencies proposed that the effective date for the latter set of changes would be the June 30,
2018, report date.37 Commenters on the June 2017 and prior Call Report notices have described
the burden associated with implementing frequent revisions to the Call Report. Therefore, the
agencies are delaying the burden-reducing revisions in this proposal until June 30, 2018, to align
with the target implementation of the burden-reducing Call Report revisions published on
November 8, 2017. This way, institutions will only need to adjust their reporting processes for
one combined set of revisions effective for the June 30, 2018, Call Report rather than separate
sets of revisions in March and June 2018. However, ASU 2016-01 is effective for public
business entities for fiscal years beginning after December 15, 2017, including interim periods
within those fiscal years. This necessitates that the proposed equity securities reporting revisions
be implemented in the Call Report in the first quarter of 2018 so that institutions required to, or
electing to, adopt the new accounting standard at that time are able to report in accordance with
that standard in the March 31, 2018, Call Report.
When implementing the burden-reducing Call Report revisions as of the June 30, 2018,
report date, institutions may provide reasonable estimates for any new or revised Call Report
data item initially required to be reported as of that date for which the requested information is
not readily available. In addition, as of the March 31, 2018, report date or a subsequent report
date as of which an institution is required to, or early elects to, initially report in accordance with
ASU 2016-01, the institution may provide reasonable estimates for any new or revised Call
Report data item affected by the equity securities reporting changes for which the requested
information is not readily available. The specific wording of the captions for the new or revised
Call Report data items discussed in this proposal and the numbering of these data items is subject
to change.
On January 8, 2018, the agencies published a final notice in the Federal Register
(83 FR 939).
Estimate of Respondent Burden
The current annual reporting burden for the Call Report is estimated to be 177,768 hours
and would decrease to 170,690 hours as shown in the following table. The average estimated
hours per response for Board Call Report filers would decrease from 54.00 hours to 51.85 hours
due to the proposed changes. The proposed burden-reducing revisions to the Call Reports are the
result of an ongoing effort by the agencies to reduce the burden associated with their preparation
and filing and achieve burden reductions by the removal or consolidation of numerous items, the
raising of certain reporting thresholds, and a reduction in reporting frequency for certain items.

37

See 82 FR 51908 (November 8, 2017).

36

The proposed revisions to the reporting of equity investments are consistent with changes in the
accounting standards applicable to such investments.
The estimated average burden hours collectively reflect the estimates for the FFIEC 031,
the FFIEC 041, and the FFIEC 051 reports. When the estimates are calculated by type of report
across the agencies, the estimated average burden hours per quarter are 123.06 (FFIEC 031),
57.71 (FFIEC 041), and 39.38 (FFIEC 051). The burden hours for the currently approved
reports are 128.05 (FFIEC 031), 74.88 (FFIEC 041), and 44.94 (FFIEC 051), so the revisions in
this notice would represent a reduction in estimated average burden hours per quarter by 4.99
(FFIEC 031), 17.17 (FFIEC 041), and 5.56 (FFIEC 051). The estimated burden per response for
the quarterly filings of the Call Report is an average that varies by agency because of differences
in the composition of the institutions under each agency’s supervision (e.g., size distribution of
institutions, types of activities in which they are engaged, and existence of foreign offices).
These reporting requirements represent 1.6 percent of the total Federal Reserve paperwork
burden.
Number of
respondents38

Annual
frequency

Estimated
average hours
per response

Estimated
annual burden
hours

Current

823

4

54.00

177,768

Proposed

823

4

51.85

170,690

FFIEC 031,
FFIEC 041, and
FFIEC 051

Change

(7,078)

The current total annual cost to state member banks is estimated to be $9,759,463 and
with the proposed revisions would decrease to $9,370,881.39 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.
Sensitive Questions
This collection of information contains no questions of a sensitive nature, as defined by
OMB guidelines.

38

Of these respondents, 552 are considered small entities as defined by the Small Business Administration (i.e.,
entities with $550 million or less in total assets) www.sba.gov/contracting/getting-started-contractor/make-sure-youmeet-sba-size-standards/table-small-business-size-standards.
39
Total cost to the public was estimated using the following formula: percent of staff time, multiplied by annual
burden hours, multiplied by hourly rates (30% Office & Administrative Support at $18, 45% Financial Managers at
$67, 15% Lawyers at $67, and 10% Chief Executives at $93). 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 2016, published March 31, 2017 www.bls.gov/news.release/ocwage.t01.htm. Occupations are defined using
the BLS Occupational Classification System, www.bls.gov/soc/.

37

Estimate of Cost to the Federal Reserve System
The cost to the Federal Reserve System for collecting and processing the FFIEC 031,
FFIEC 041, and FFIEC 051 is estimated to be $2,280,455 per year.

38

Appendix A
Summary of the FFIEC Member Entities’ Uses of the Data Items in the
Call Report Schedules in the Portion of the User Surveys Evaluated in the Development of
This Proposal
Schedule RI-D (Income from Foreign Offices) (FFIEC 031 only)
Schedule RI-D collects data on income from foreign offices. Collectively, the data are
used in country and currency risk analyses to monitor the level, trend, quality and sustainability
of the income component of foreign offices. These data help support a variety of examination
activities that include, but are not limited to, earnings and yield analysis, asset securitizations,
core assessment, price risk, and trading. Quarterly data also improve the off-site monitoring of
trading and asset management activities. Data on investment banking, advisory, brokerage, and
underwriting fees and commissions are used to track the global asset management activities of
institutions with foreign offices. The global presence of these activities adds to the complexity
of the asset management business conducted by financial institutions and this information is
continually monitored to detect potential shifts in business models. It also serves as one
component of measurement of the degree of global interconnectedness and systemic risk.
Schedule RI-E (Explanations)
Schedule RI-E collects explanations for items that significantly contribute to the total
amounts reported for other noninterest income and other noninterest expense. Since other
noninterest income makes up almost half of total noninterest income and other noninterest
expense makes up approximately 40 percent of noninterest expense on an aggregate basis for all
filers of the Call Report, data on the composition of each of these income statement data items is
essential to understanding what is driving the level of and changes over time in these data items
at individual institutions. The stratification of the information in this schedule allows for
identification of potential unusual sources of changes in earnings that affect trend analyses. This
information is particularly important for identifying losses of an unusual or nonrecurring nature
when an institution is in a stressed condition, which was evident during the recent financial
crisis. This stratified noninterest income and expense information continues to be critical in
understanding the causes of swings in an institution’s profitability.
Schedule RI-E also collects descriptive information on discontinued operations,
significant adjustments to the allowance for loan and lease losses (ALLL), accounting changes
and error corrections, and certain capital transactions with stockholders. These data items
provide the agencies and their examiners better insight on factors driving changes in net income
and the ALLL (due to sources other than provisions, charge-offs, and recoveries), along with
nonrecurring types of changes in institutions’ equity capital.
The detailed breakdown of components of other noninterest income in excess of the
Schedule RI-E reporting threshold is essential to the Consumer Financial Protection Bureau’s
(CFPB) understanding of the viability of institutions’ offerings of consumer services regulated
by the CFPB. This information provides unique insights into institutions’ reliance on key
revenue streams that can impact consumer access to and the availability of services. These

39

streams include bank and credit card interchange, income and fees from automated teller
machines, and institution-described components of other noninterest income. This information
also helps the CFPB monitor trends in the consumer marketplace. Similarly, the detailed
breakdown of other noninterest expense facilitates the CFPB’s ability to conduct statutorilyrequired cost analyses for rulemakings and other policy endeavors.
Schedule RC-B (Securities)
Information collected on Schedule RC-B is essential for assessment of liquidity risk,
market risk, interest rate risk, and credit risk. Specifically, information on held-to-maturity,
available-for-sale, and pledged securities is critical for analysis of the institution’s ability to
manage short-term financial obligations without negatively impacting capital or income
(liquidity risk), and risk of loss due to market movements (market risk). Maturity and repricing
information on debt securities collected in the Memorandum items on Schedule RC-B, together
with the maturity and repricing information collected in other schedules for other types of assets
and liabilities, is critical for the assessment of the risk to an institution from changes in interest
rates (interest rate risk), and also contributes to the evaluation of liquidity. Thus, the maturity
and repricing information collected throughout the Call Report also aids in evaluating the
strategies institutions take to mitigate liquidity and interest rate risks. Liquidity and interest rate
risk indicators that are calculated by agency models from an institution’s Call Report data and
exceed specified parameters or change significantly between examinations are red flags that call
for timely examiner off-site review.
In this regard, the reported amount of debt securities with a remaining maturity of one
year or less is a key input into the calculation of an institution’s short-term assets that, when
analyzed in conjunction with non-core funding data, can indicate the extent to which the
institution is relying on short-term funding to fund longer-term assets, which presents an
exposure to liquidity risk. Further, liquidity risk inputs into agency models that vary by type of
security provide examiners the ability to customize and apply liquidity stress tests. Extensive
back testing has shown that the liquidity risk inputs for securities contain substantial forwardlooking information by which to ascertain the likelihood that an institution would be able to
avoid significant liquidity problems in a stressed environment.
As another example, agency models that consider both the amortized cost and fair value
of held-to-maturity and available-for-sale securities reported in Schedule RC-B are used for offsite monitoring of interest rate risk to identify individual institutions that may be significantly
exposed to rising interest rates. Individual types of securities from Schedule RC-B are grouped
into major categories for purposes of performing duration-based analyses of potential investment
portfolio depreciation for both severe and more moderate interest rate increases. The Schedule
RC-B data for these groupings of securities, together with Call Report data for other types of
balance sheet assets and liabilities, also serve as inputs to quarterly duration-based estimates of
potential changes in fair values for the overall balance sheet in response to various forecasted
interest rate changes. Outlier institutions identified by these models are the subject of prompt
supervisory follow-up to address their interest rate risk exposure.
The institution’s risk profile in these areas is considered during pre-examination planning

40

to determine the appropriate scoping and staffing for examinations. For example, the quarterly
reporting of the Call Report information on held-to-maturity and available-for-sale securities also
aids in the identification of low-risk areas prior to on-site examinations, allowing the agencies to
improve the allocation of their supervisory resources and increase the efficiency of supervisory
assessments, which reduces the scope of examinations in these areas, thereby reducing regulatory
burden.
Information on the amortized cost and fair value of the securities portfolio allows for
measurement of depreciation/appreciation, which is important for assessing the potential impact
that unrealized gains and losses may have on earnings and liquidity. Unrealized gains and losses
on available-for-sale equity securities and, for certain institutions, unrealized gains and losses on
available-for-sale debt securities are an integral input into regulatory capital calculations.
Furthermore, because the amount of unrealized gains and losses on both held-to-maturity and
available-for-sale debt securities is an indicator of risk in the debt securities portfolio, it also is a
key factor in examiners’ qualitative assessments of capital adequacy.
Data showing significant depreciation in specific types of securities not issued or
guaranteed by the U.S. government or its agencies can signal an institution’s failure to properly
evaluate the existence of other-than-temporary impairments arising from credit losses and other
factors. Similarly, data on year-to-date sales and transfers of held-to-maturity securities is a
basis for off-site or on-site follow-up by examiners to determine whether the reasons for these
transactions are acceptable under U.S. GAAP or have resulted in the tainting of this securities
portfolio. In addition, the reporting of debt securities by security type is important to identify
concentrations in higher risk types of investments, which may have greater liquidity and/or credit
risk than other types of securities. Information on investments in securities issued by states and
political subdivisions in the United States is used by many state regulatory agencies as a starting
point for monitoring compliance with certain state municipal investment regulations. The
amortized cost and fair value of held-to-maturity and available-for-sale debt securities,
respectively, for certain types of securities as well as the fair value of all U.S. Treasury and U.S.
Government agency securities are used in the risk-based premium deposit insurance pricing
methodology for large institutions and highly complex institutions.
Schedule RC-D (Trading Assets and Liabilities) (FFIEC 031 and FFIEC 041 only)
Schedule RC-D collects information on trading activity from institutions with more than
a limited amount of trading assets in recent quarters. Trading assets are segmented into detailed
securities and loan categories. Trading liabilities separately cover liability for short positions and
other trading liabilities. The schedule’s Memorandum items request additional information,
including the unpaid principal balance of loans and the fair value of structured financial products
and asset-backed securities held for trading purposes.
The information contained in Schedule RC-D is used to assess the overall composition of
the institution’s trading portfolio and also provides detailed information to evaluate the liquidity,
credit, and interest rate risk within the trading portfolio, which impacts the overall risk profile of
the institution. Data on the types of trading assets held by an institution – such as U.S. Treasury
securities versus structured financial products versus commercial and industrial loans, for

41

example – serve as a barometer of the relative levels of these risks in the trading portfolio.
Regarding liquidity risk, the higher the level of more liquid assets an institution has within its
trading portfolio, the more financial flexibility it has if faced with uncertainties or unfavorable
market conditions. If an institution has a low level of liquid assets within its trading portfolio,
this impacts its ability to rapidly adjust its holdings in response to adverse market movements.
Information on the volume and composition of trading assets and how it has changed over recent
quarters also can provide insight into an institution’s trading strategies and its views on market
trends. The assessment of trading portfolio composition and risks enters into pre-examination
planning to determine the appropriate scoping and staffing for examinations of institutions
engaged in trading activities.
Furthermore, data on securities and loans held for trading are combined with data on
securities and loans held for investment, as reported in Schedule RC-B and Schedule RC-C, Part
I, to benchmark weekly loan and security data collected by the Board from a sample of both
small and large institutions. These weekly data are used to estimate weekly measures of
extension of credit for the banking sector as a whole to provide a more timely input for purposes
of monitoring the macroeconomy.
Information on mortgage-backed securities and mortgage loans held for trading assisted
the CFPB’s efforts to develop required estimates for various Title XIV mortgage reform
rulemakings under the Dodd-Frank Wall Street Reform and Consumer Protection Act (Pub. L.
111-203). Going forward, data items from this schedule and Schedules RC-B and RC-C, Part I,
are critical for continuous monitoring of the mortgage market. The CFPB uses these items to
understand the intricacies of the mortgage market that are essential to assessing institutional
participation in regulated consumer financial services markets and to assess regulatory impact
associated with recent and proposed policies, as required by that agency’s statutory mandate.
Schedule RC-K (Quarterly Averages)
Average quarterly asset and liability information is essential to the ability of the FFIEC
member entities to more appropriately evaluate the performance of individual institutions.
Quarterly average data from Schedule RC-K also provide important information at the industry
level for policy review at FFIEC member entities.
The average data reported in Schedule RC-K are used in conjunction with income and
expense information from Schedule RI to calculate yields and costs for the corresponding
categories of assets and liabilities. These ratios are presented in the Uniform Bank Performance
Report (UBPR) where they are used as a tool by examiners, both on- and off-site, to monitor and
evaluate trends related to an institution’s earnings and capital. These ratios also help the
agencies identify trends across the banking industry. Important ratios derived from quarterly
average data include, but are not limited to, earnings ratios (e.g., return on average assets,
overhead ratio, and net interest margin) and the leverage capital ratio.
The granularity of the data in Schedule RC-K assists in analyzing performance within a
bank’s asset and liability portfolios. Quarterly average balances allow for better analyses of
trends in the composition of an institution’s assets and liabilities than is possible from

42

comparisons of quarter-end data, which may be affected by fluctuations related to seasonality or
abnormal levels of activity at period-end. The detailed average data used to calculate the yield
on specific types of interest-earning assets helps examination teams understand the impact of
credit quality on the earnings performance of particular loan portfolios. Where an institution’s
yields on particular types of loans exceed those of its peers, this warrants examiner scrutiny to
determine whether this outcome is a result of the institution’s origination or purchase of lower
credit quality loans. In addition, the data on the cost of funds by funding type is important in
assessing the funding mix at the institution level for oversight purposes. Higher costs for
particular types of deposits or other liabilities compared to these costs at an institution’s peers
also warrants examiner review to determine whether the institution is making greater use of more
volatile non-core funding sources. The yield on interest-earning assets and cost of funds also
gives insight into the effectiveness of an institution’s plans and initiatives related to asset/liability
mix, liquidity, and interest rate risk strategies and their resulting impact on earnings. These
performance ratios are essential to the consideration of an institution’s earnings during preexamination planning to determine the appropriate scoping of this area, particularly because
earnings is evaluated and rated as part of the CAMELS rating system.40
Schedule RC-L (Derivatives and Off-Balance-Sheet Items)
Schedule RC-L provides data on off-balance sheet assets and liabilities as well as
derivatives contracts. The quarterly reporting of all off-balance sheet items in the Call Report is
required by law (12 USC 1831n(a)(3)(C)). The most recent financial crisis emphasized the
importance of identifying and monitoring significant exposures arising from any contingent or
off-balance sheet liabilities and the effect of these exposures on an institution’s overall risk
profile. The granular data on components of off-balance sheet items, as well as derivatives data,
assist the banking agencies in ensuring the safety and soundness of financial institutions through
both off-site and on-site monitoring of a variety of potential risks. These risks include, but are
not limited to, liquidity risk, credit risk, interest rate risk, and foreign exchange risk. The data on
Schedule RC-L also is essential for the examination scoping process, which begins during preexamination planning. The data offer insight into outliers and exceptions, which provide
information to examiners on areas on which to focus during their on-site examinations.
The data on Schedule RC-L on the FFIEC 031 and FFIEC 041 are useful in determining
an institution’s potential exposure to losses from derivatives activities. It is also useful in
identifying the extent to which an institution may be engaging in hedging strategies that will
affect its future earnings prospects. An excessive and/or inappropriate credit derivative position
could have a substantial and immediate detrimental impact to an institution’s liquidity, interest
rate risk, earnings, or capital adequacy. For institutions with material volumes of derivatives as
reported on Schedule RC-L, examiners can assess whether the institution’s management has the
appropriate expertise and policies in place to manage and control the risks associated with its
derivatives activities and whether the institution’s capital levels are commensurate with its risk
exposure. This is particularly true with respect to interest rate derivatives, which are the most
widely held derivatives, and are commonly used in the management of interest rate risk.
40

CAMELS is an acronym that represents the ratings from six essential components of an institution’s financial
condition and operations: capital adequacy, asset quality, management, earnings, liquidity, and sensitivity to market
risk. These components represent the primary areas evaluated by examiners during examinations of institutions.

43

Schedule RC-L provides a granular perspective about the types of interest rate contracts an
institution has entered into, which helps an examiner focus on assessing how effectively
management uses the various types of interest rate contracts in its derivatives portfolio to hedge
its exposure to interest rate risk. Also, examiners investigate fluctuations in the fair values of an
institution’s holdings of derivatives to determine if there are changes in the institution’s risk
appetite as set by the board of directors and implemented by management.
The unused commitments information on Schedule RC-L is essential to examiners,
especially during periods of financial distress when borrowers rely increasingly on drawing
down their lines of credit and unused commitments as a source of funding. The unused
commitments data enable examiners to identify whether growth in unused commitments over
time is at a manageable level and permit assessments of the potential impact, if such
commitments are funded, on the credit quality of the related loan categories, as well as on the
liquidity and on the capital position of an institution. Also, institutions may have a concentration
in a particular loan category, which may not be readily apparent from balance sheet data until
unused commitments to borrowers in this category are actually funded, which dictates that
examiners consider the reported amounts on unused commitments by loan category to ensure
they identify and assess the concentration risk. Financial and performance standby letters of
credit also present liquidity and credit risk considerations for examiners, which also may be
greater during periods of financial distress when the counterparties may be more likely to fail to
perform as required under the terms of the underlying contract.
The derivatives information on Schedule RC-L is also one of the primary sources that
feeds into a derivatives quarterly report that is used to report on bank trading and derivatives
activities. This public report issued by the OCC helps the banking agencies’ on-site examiners at
the largest banks to continuously evaluate the credit, market, operational, reputation, and
compliance risks of bank derivatives activities.
Schedule RC-M (Memoranda)
Schedule RC-M collects various types of information. Section 7(k) of the Federal
Deposit Insurance Act (12 U.S.C. 1817(k)) authorizes the federal banking agencies to require the
reporting and public disclosure of information concerning extensions of credit by an institution
to its executive officers and principal shareholders and their related interests. The Board’s
Regulation O (12 CFR 215), which has been made applicable to all institutions, imposes an
aggregate lending limit on extensions of credit to insiders (executive officers, directors, principal
shareholders, and their related interests) and, in general, requires an institution to make available
the names of its executive officers and principal shareholders to whom the institution had
outstanding as of the end of the latest previous quarter aggregate extensions of credit that, when
aggregated with all other outstanding extensions of credit to such person and their related
interests, equaled or exceeded the lesser of 5 percent of capital and unimpaired surplus or
$500,000. The data collected in Schedule RC-M on extensions of credit to the reporting
institution’s insiders generally align with these requirements and assist the agencies in
monitoring compliance with the insider lending regulations between examinations and
determining whether supervisory follow-up is warranted when material increases in insider
lending are identified.

44

Because identifiable intangible assets are deducted from regulatory capital or are subject
to regulatory capital limits and deducted amounts are not risk weighted, the reporting of these
amounts aids in validating an institution’s regulatory capital calculations in Schedule RC-R. In
addition to their treatment under the regulatory capital rules, mortgage servicing assets in
particular are complex in nature and present liquidity risk and interest rate risk and their value is
affected by the credit risk of the underlying serviced assets. Mortgage servicing assets also
contribute to the level of an institution’s mortgage prepayment exposure. When the level of this
exposure rises above a specified benchmark at an individual institution, this exposure may
warrant additional attention by examiners between examinations and necessitate greater scrutiny
of management’s prepayment assumptions in its own interest rate risk model during
examinations or visitations.
The components of other real estate owned are needed to monitor asset quality trends at
individual institutions and industry-wide, including when coupled with the past due and
nonaccrual data for loans secured by the same type of property from Schedule RC-N. The
component information may provide insight into the market conditions affecting the segments of
the real estate market in the institution’s trade area, including possible deteriorating conditions.
Maturity and repricing information on other borrowed money, together with the maturity
and repricing information collected in other schedules for other types of assets and liabilities, is
needed to evaluate liquidity and interest rate risk to the institution, and to aid in evaluating the
strategies institutions take to mitigate these risks. Liquidity and interest rate risk indicators that
are calculated by agency models from an institution’s Call Report data and exceed specified
parameters or change significantly between examinations are red flags that call for timely
examiner attention. Data on certain secured liabilities also are used in the assessment of
institutions’ liquidity positions. Increases in the relative volume of secured versus unsecured
liabilities may signal that an institution is encountering difficulties in rolling over unsecured
borrowings due to deterioration in its condition, which would call for supervisory follow-up
when identified between examinations
Information on mutual funds and annuities, bank websites with transactional capability,
certain trustee and custodial activities, and captive insurance subsidiaries, is used to identify
institutions engaged in these activities, some of which are not typical activities for community
banks. If an institution begins to report that it engages in one or more of these activities or
reports a significant increase in assets tied to an activity between examinations, this may indicate
the need for examiner follow-up to assess the institution’s expertise and management of these
activities. An institution’s involvement in these activities may also affect the staffing and
scoping of examinations, particularly for activities for which compliance with applicable laws
and regulations must be evaluated during examinations. The reporting of an institution’s internet
websites and trade names supports the FDIC’s ability to serve as an information resource for
insured institutions by responding to inquiries from the public with the most current information
concerning the insured status of the institution behind an internet website or a physical branch
office that uses a trade name.
For Qualified Thrift Lenders (QTL) subject to 12 U.S.C. 1467a(c), reporting of QTL test
information assists the agencies in timely identifying thrift institutions that need to take action to

45

remain in compliance, or that fail to comply and become subject to certain restrictions.
International remittance transfers data by type are needed annually to monitor compliance with
regulatory requirements (12 CFR 1005.30, et seq.). Different types of transfers pose different
consumer protection concerns and information of transfer activity aids in the monitoring of the
evolution of this market, and how institutions diversify remittance offerings beyond wire
transfers.
Schedule RC-R (Regulatory Capital)
Schedule RC-R collects information about an institution’s capital. Part I (Regulatory
Capital Components and Ratios) collects information about the types and amounts of capital
instruments and the leverage and risk-based capital ratios. Part II (Risk-Weighted Assets)
collects additional information about types of assets on an institution’s balance sheet and certain
off-balance sheet items to use in computing the risk-based capital ratios.
Each federal banking agency is required to establish a leverage limit and risk-based
capital requirement for insured depository institutions under 12 U.S.C. 1831o and to monitor
compliance with those requirements. The agencies implemented the capital requirements in their
regulatory capital rules (12 CFR part 3 for OCC; 12 CFR part 217 for the Board; 12 CFR part
324 for the FDIC) and the compliance requirements in their prompt corrective action rules (12
CFR part 6 for OCC; 12 CFR part 208, Subpart D for the Board; 12 CFR 324, Subpart H for the
FDIC). The capital rules recognize three types of capital instruments: CET-1, Additional Tier 1,
and Tier 2 capital. The total of each type on Schedule RC-R, Part I, includes all potential
adjustments to each component as allowed under the capital rules. The capital rules also provide
for a calculation of risk-weighted assets, which consists of assigning a risk-weight to every asset
on an institution’s balance sheet that is not deducted from capital, as well as to certain offbalance sheet items. Schedule RC-R, Part II, includes all of the fields necessary to properly
calculate an institution’s risk-weighted asset amount. Finally, the results of the calculation of
capital instrument amounts and risk-weighted assets are used to calculate risk-based and leverage
capital ratios on Schedule RC-R, Part I. The agencies need to be able to monitor compliance
with the capital rules and prompt corrective action provisions no less frequently than quarterly.
In addition to using the resulting capital ratios to determine an institution’s status under
12 U.S.C. 1831o and the banking agencies’ prompt corrective action regulations, the FFIEC
member entities use the regulatory capital information for other purposes. The calculation of
Tier 1 capital at quarter-end flows into the amount of average tangible equity for the calendar
quarter that institutions report in Schedule RC-O, which is used in the measurement of
institutions’ assessment bases for deposit insurance purposes. The Tier 1 leverage ratio is one of
the inputs into the calculation of deposit insurance assessment rates for small institutions and
Tier 1 capital is a commonly used input when calculating these rates for large and highly
complex institutions. Capital adequacy is rated in an institution’s on-site examination as the C of
the CAMELS component ratings, and the information provided on Schedule RC-R helps
examiners evaluate and rate that component. It is also used in the off-site monitoring process,
and is important in reviewing the risk profile and viability of a financial institution. For
example, the ratio of risk-weighted assets to unweighted assets has been found to provide an
informative forward-looking signal regarding an institution’s risk posture. The information

46

provided on Schedule RC-R also is used in deciding whether to approve an 18-month
examination cycle for a specific institution and in reviewing merger applications.
Information on specific sub-components of regulatory capital is useful as well. For
example, the amounts of unrealized gains and losses on securities that flow into regulatory
capital provide an indication of an institution’s interest rate and market risk. Information on the
risk weighting of assets and off-balance sheet items provides insight into management’s risk
tolerance and the institution’s risk to the deposit insurance fund. The risk-weighted asset
composition information and risk-based capital ratios that flow into the UBPR are helpful to
examiners when reviewing Reports of Examination and to establish a peer group average for
comparison when evaluating changes in these items. The risk-weighted asset composition
information also assists examiners in evaluating the reasons for changes in total risk-weighted
assets over time at individual institutions. The derivatives exposure items reported in the
Memoranda section of Schedule RC-R, Part II, provide a key insight into the notional principal
amounts of both cleared and over-the-counter derivatives in the banking system, in addition to
being inputs into the calculation for risk-weighted assets.

47

Appendix B
FFIEC 051: To be completed by banks with domestic offices only and total assets less than
$1 billion
Data Items Removed, Other Impacts to Data Items, Data Items with a Reduction in
Frequency of Collection, or Data Items with an
Increase in Reporting Threshold

Data Items Removed
Schedule
RI

Item
5.d.(1)

RI

5.d.(2)

RI
RI

5.d.(3)
5.d.(4)

RI

5.d.(5)

RI
RI

5.g
M1

RI-B,
Part II

M4

RI-E

1.f

RI-E
RC

1.h
10.a

Item Name
Fees and commissions from securities
brokerage
Investment banking, advisory, and
underwriting fees and commissions
Note: Items 5.d.(1) and 5.d.(2) of Schedule
RI will be combined into one data item.
Fees and commissions from annuity sales
Underwriting income from insurance and
reinsurance activities
Income from other insurance activities
Note: Items 5.d.(3), 5.d.(4), and 5.d.(5) of
Schedule RI will be combined into one
data item.
Net securitization income
Interest expense incurred to carry taxexempt securities, loans, and leases
acquired after August 7, 1986, that is not
deductible for federal income tax purposes
Amount of allowance for post-acquisition
credit losses on purchased credit-impaired
loans accounted for in accordance with
FASB ASC 310-30 (former AICPA
Statement of Position 03-3)
Net change in the fair values of financial
instruments accounted for under a fair
value option
Gains on bargain purchases
Goodwill
Note: Schedule RC, item 10.a will be
moved to Schedule RC-M, new item 2.b.
48

MDRM Number
RIADC886
RIADC888

RIADC887
RIADC386
RIADC387

RIADB493
RIAD4513

RIADC781

RIADF229

RIADJ447
RCON3163

Schedule
RC

Item
10.b

RC-B

2.a

RC-B

2.b

Item Name
Other intangible assets (from Schedule
RC-M)
Note: Items 10.a and 10.b of Schedule RC
will be combined into one data item.
U.S. Government agency obligations
(exclude mortgage-backed securities):
Issued by U.S. Government agencies
(Columns A through D)
U.S. Government agency obligations
(exclude mortgage-backed securities):
Issued by U.S. Government-sponsored
agencies (Columns A through D)
Note: Items 2.a and 2.b of Schedule RC-B
will be combined into one data item
(Columns A through D).
Structured financial products: Cash
(Columns A through D)

RC-B

5.b.(1)

RC-B

5.b.(2)

Structured financial products: Synthetic
(Columns A through D)

RC-B

5.b.(3)

Structured financial products: Hybrid
(Columns A through D)

RC-B

M6.a

RC-B

M6.b

RC-B

M6.c

RC-B

M6.d

Note: Items 5.b.(1), 5.b.(2), and 5.b.(3) of
Schedule RC-B will be combined into one
line item (Columns A through D).
Structured financial products by underlying
collateral or reference assets: Trust
preferred securities issued by financial
institutions (Columns A through D)
Structured financial products by underlying
collateral or reference assets: Trust
preferred securities issued by real estate
investment trusts (Columns A through D)
Structured financial products by underlying
collateral or reference assets: Corporate
and similar loans (Columns A through D)

MDRM Number
RCON0426

RCON1289,
RCON1290,
RCON1291,
RCON1293
RCON1294,
RCON1295,
RCON1297,
RCON1298

RCONG336,
RCONG337,
RCONG338,
RCONG339
RCONG340,
RCONG341,
RCONG342,
RCONG343
RCONG344,
RCONG345,
RCONG346,
RCONG347

RCONG348,
RCONG349,
RCONG350,
RCONG351
RCONG352,
RCONG353,
RCONG354,
RCONG355
RCONG356,
RCONG357,
RCONG358,
RCONG359
Structured financial products by underlying RCONG360,
collateral or reference assets: 1–4 family
RCONG361,

49

Schedule

Item

RC-B

M6.e

RC-B

M6.f

RC-B

M6.g

RC-K
RC-L
RC-L
RC-L

7
1.b.(1)
1.b.(2)
1.d

RC-M

2.b

RC-M

3.f

Item Name
residential MBS issued or guaranteed by
U.S. Government-sponsored enterprises
(GSEs) (Columns A through D)
Structured financial products by underlying
collateral or reference assets: 1–4 family
residential MBS not issued or guaranteed
by GSEs (Columns A through D)
Structured financial products by underlying
collateral or reference assets: Diversified
(mixed) pools of structured financial
products (Columns A through D)
Structured financial products by underlying
collateral or reference assets: Other
collateral or reference assets (Columns A
through D)
Trading assets
Unused consumer credit card lines
Other unused credit card lines
Unused commitments: Securities
underwriting
Purchased credit card relationships and
nonmortgage servicing assets

MDRM Number
RCONG362,
RCONG363
RCONG364,
RCONG365,
RCONG366,
RCONG367
RCONG368,
RCONG369,
RCONG370,
RCONG371
RCONG372,
RCONG373,
RCONG374,
RCONG375
RCON3401
RCONJ455
RCONJ456
RCON3817
RCONB026

Note: Amounts reported in item 2.b will
be included in item 2.c, All other
identifiable intangible assets.
Foreclosed properties from “GNMA loans” RCONC979
Note: Amounts reported in item 3.f will be
included in item 3.c, Other real estate
owned: 1—4 family residential properties.

Other Impacts to Data Items
Schedu Item
le
RI
5.d.(1)
(New)

RI

5.d.(2)

Item Name

MDRM Number

Fees and commissions from securities
brokerage, investment banking, advisory,
and underwriting activities

To be determined
(TBD)

Note: Items 5.d.(1) and 5.d.(2) of Schedule
RI removed above will be combined into
this data item.
Income from insurance activities (includes
50

TBD

(New)

RC

RC-B

RC-B

RC-M

10 (New)

2 (New)

5.b (New)

2.b (Remapping)

underwriting income from insurance and
reinsurance activities)
Note: Items 5.d.(3), 5.d.(4), and 5.d.(5) of
Schedule RI removed above will be
combined into this data item.
Intangible assets (from Schedule RC-M)
Note: Items 10.a and 10.b of Schedule RC
removed above will be combined into this
data item.
U.S. Government agency and sponsored
agency obligations (exclude mortgagebacked securities (Columns A through D)
Note: Items 2.a and 2.b of Schedule RC-B
removed above will be combined into this
data item (Columns A through D).
Structured financial products (Columns A
through D)
Note: Items 5.b.(1), 5.b.(2), and 5.b.(3) of
Schedule RC-B removed above will be
combined into this line item (Columns A
through D).
Goodwill
Note: Schedule RC, item 10.a will be
moved to Schedule RC-M, new item 2.b.,
and the phrase “other than goodwill” will
be removed from the caption for Schedule
RC-M, item 2.

51

RCON2143

TBD (4 MDRMs)

TBD (4 MDRMs)

RCON3163

Data Items with a Reduction in Frequency of Collection
Semiannual Reporting (June 30 and December 31)
Schedule
RC-B

Item
M3

RC-C,
Part I

M7.a

RC-C,
Part I

M7.b

RC-C,
Part I

M8.a

RC-C,
Part I

M12

RC-L

11.a

RC-L

11.b

RC-N

M7

RC-N

RC-N

Item Name
Amortized cost of held-to-maturity
securities sold or transferred to availablefor-sale or trading securities during the
calendar year-to-date
Purchased credit-impaired loans held for
investment accounted for in accordance
with FASB ASC 310-30: Outstanding
balance
Purchased credit-impaired loans held for
investment accounted for in accordance
with FASB ASC 310-30: Amount included
in Schedule RC-C, Part I, items 1 through
9
Total amount of closed-end loans with
negative amortization features secured by
1–4 family residential properties
Loans (not subject to the requirements of
FASB ASC 310-30 (former AICPA
Statement of Position 03-3)) and leases
held for investment that were acquired in
business combinations with acquisition
dates in the current calendar year (Columns
A through C)
Year-to-date merchant credit card sales
volume: Sales for which the reporting bank
is the acquiring bank
Year-to-date merchant credit card sales
volume: Sales for which the reporting bank
is the agent bank with risk
Additions to nonaccrual assets during the
quarter

MDRM Number
RCON1778

RCONC779

RCONC780

RCONF230

RCONGW45,
RCONGW46,
RCONGW47

RCONC223

RCONC224

RCONC410

M8

Note: This caption would be revised to
“Additions to nonaccrual assets during the
last 6 months.”
Nonaccrual assets sold during the quarter

RCONC411

M9.a

Note: This caption would be revised to
“Nonaccrual assets sold during the last 6
months.”
Purchased credit-impaired loans accounted

RCONL183,

52

Schedule

Item

RC-N

M9.b

Item Name
for in accordance with FASB ASC 310-30
(former AICPA Statement of Position 033): Outstanding balance (Columns A
through C)
Purchased credit-impaired loans accounted
for in accordance with FASB ASC 310-30
(former AICPA Statement of Position 033): Amount included in Schedule RC-N,
items 1 through 7, above (Columns A
through C)

MDRM Number
RCONL184,
RCONL185

RCONL186,
RCONL187,
RCONL188

Annual Reporting (December 31)
Schedule
RI-E

Item
1.a
through
1.l

Item Name
Other noninterest income (from Schedule
RI, item 5.l)

RI-E

2.a
through
2.p

Other noninterest expense (from Schedule
RI, item 7.d)

53

MDRM Number
RIADC013,
RIADC014,
RIADC016,
RIAD4042,
RIADC015,
RIADF555,
RIADT047,
RIAD4461,
RIAD4462,
RIAD4463
RIADC017,
RIAD0497,
RIAD4136,
RIADC018,
RIAD8403,
RIAD4141,
RIAD4146,
RIADF556,
RIADF557,
RIADF558,
RIADF559,
RIADY923,
RIADY924,
RIAD4464,
RIAD4467,
RIAD4468

Data Items with an Increase in Reporting Threshold
To be completed by banks with components of other noninterest income in amounts greater
than $100,000 that exceed 7 percent of Schedule RI, item 5.l
Schedule Item
Item Name
MDRM Number
RI-E
1.a through Other noninterest income (from Schedule RIADC013,
1.l
RI, item 5.l)
RIADC014,
RIADC016,
RIAD4042,
RIADC015,
RIADF555,
RIADT047,
RIAD4461,
RIAD4462,
RIAD4463
To be completed by banks with components of other noninterest expense in amounts greater
than $100,000 that exceed 7 percent of Schedule RI, item 7.d
Schedule Item
Item Name
MDRM Number
RI-E
2.a through Other noninterest expense (from
RIADC017,
2.p
Schedule RI, item 7.d)
RIAD0497,
RIAD4136,
RIADC018,
RIAD8403,
RIAD4141,
RIAD4146,
RIADF556,
RIADF557,
RIADF558,
RIADF559,
RIADY923,
RIADY924,
RIAD4464,
RIAD4467,
RIAD4468

54

Appendix C
FFIEC 041: To be completed by banks with domestic offices only and consolidated total
assets less than $100 billion

Data Items Removed, Other Impacts to Data Items, Data Items with a Reduction in
Frequency of Collection, or Data Items with an
Increase in Reporting Threshold

Data Items Removed
Schedule Item
RI
M8.a
RI

M8.b

RI

M8.c

RI

M8.d

RI

M8.e

RI

M8.f.(1)

RI

M8.f.(2)

RI

M8.g.(1)

RI

M8.g.(2)

RI

M8.h

Item Name
Trading revenue from interest rate
exposures
Trading revenue from foreign
exchange exposures
Trading revenue from equity
security and index exposures
Trading revenue from commodity
and other exposures
Trading revenue from credit
exposures
Impact on trading revenue of
changes in the creditworthiness of
the bank’s derivatives counterparties
on the bank’s derivative assets:
Gross credit valuation adjustment
(CVA)
Impact on trading revenue of
changes in the creditworthiness of
the bank’s derivatives counterparties
on the bank’s derivative assets:
CVA hedge
Impact on trading revenue of
changes in the creditworthiness of
the bank on the bank’s derivative
liabilities: Gross debit valuation
adjustment (DVA)
Impact on trading revenue of
changes in the creditworthiness of
the bank on the bank’s derivative
liabilities: DVA hedge
Gross trading revenue before
including positive or negative net

55

MDRM Number
RIAD8757
RIAD8758
RIAD8759
RIAD8760
RIADF186
RIADFT36

RIADFT37

RIADFT38

RIADFT39

RIADFT40

Schedule Item

Item Name
CVA and net DVA

MDRM Number

RI-E

1.f

RIADF229

RI-E
RC

1.h
10.a

Net change in the fair values of
financial instruments accounted for
under a fair value option
Gains on bargain purchases
Goodwill

RC

10.b

RC-B

2.a

RC-B

2.b

Note: Schedule RC, item 10.a will
be moved to Schedule RC-M, new
item 2.b.
Other intangible assets (from
Schedule RC-M)
Note: Items 10.a and 10.b of
Schedule RC will be combined into
one data item.
U.S. Government agency obligations
(exclude mortgage-backed
securities): Issued by U.S.
Government agencies (Columns A
through D)
U.S. Government agency obligations
(exclude mortgage-backed
securities): Issued by U.S.
Government-sponsored agencies
(Columns A through D)
Note: Items 2.a and 2.b of Schedule
RC-B will be combined into one
data item (Columns A through D).
Structured financial products: Cash
(Columns A through D)

RC-B

5.b.(1)

RC-B

5.b.(2)

Structured financial products:
Synthetic (Columns A through D)

RC-B

5.b.(3)

Structured financial products:
Hybrid (Columns A through D)
Note: Items 5.b.(1), 5.b.(2), and
5.b.(3) of Schedule RC-B will be
combined into one data item.
56

RIADJ447
RCON3163

RCON0426

RCON1289,
RCON1290,
RCON1291, RCON1293

RCON1294,
RCON1295,
RCON1297, RCON1298

RCONG336,
RCONG337,
RCONG338,
RCONG339
RCONG340,
RCONG341,
RCONG342,
RCONG343
RCONG344,
RCONG345,
RCONG346,
RCONG347

Schedule Item
RC-D
5.a.(1)
RC-D
5.a.(2)
RC-D

5.a.(3)

RC-D

6.a.(1)

RC-D
RC-D

6.a.(2)
6.a.(3)(a)

RC-D

6.a.(3)(b)(1)

RC-D

6.a.(3)(b)(2)

RC-D

6.a.(4)

RC-D

6.a.(5)

RC-D

6.c.(1)

RC-D

6.c.(2)

RC-D

6.c.(3)

Item Name
Structured financial products: Cash
Structured financial products:
Synthetic
Structured financial products:
Hybrid
Note: Items 5.a.(1), 5.a.(2), and
5.a.(3) of Schedule RC-D will be
combined into one data item.
Construction, land development, and
other land loans
Loans secured by farmland
Revolving, open-end loans secured
by 1–4 family residential properties
and extended under lines of credit
Closed-end loans secured by 1–4
family residential properties:
Secured by first liens
Closed-end loans secured by 1–4
family residential properties:
Secured by junior liens
Loans secured by multifamily (5 or
more) residential properties
Loans secured by nonfarm
nonresidential properties

MDRM Number
RCONG383
RCONG384
RCONG385

RCONF604
RCONF605
RCONF606

RCONF607

RCONF611

RCONF612
RCONF613

Note: Items 6.a.(1), 6.a.(2),
6.a.(3)(a), 6.a.(3)(b)(1), 6.a.(3)(b)(2),
6.a.(4), and 6.a.(5) of Schedule RCD will be replaced by two data
items: (1) Loans secured by 1—4
family residential properties, and (2)
All other loans secured by real
estate.
Loans to individuals for household,
RCONF615
family, and other personal
expenditures: Credit cards
Loans to individuals for household,
RCONF616
family, and other personal
expenditures: Other revolving credit
plans
Loans to individuals for household,
RCONK199
family, and other personal
expenditures: Automobile loans

57

Schedule Item
RC-D
6.c.(4)

RC-D

RC-D

RC-D

RC-D

RC-D

RC-D

RC-D

Item Name
Loans to individuals for household,
family, and other personal
expenditures: Other consumer loans

Note: Items 6.c.(1), 6.c.(2), 6.c.(3),
and 6.c.(4) of Schedule RC-D will
be combined into one data item.
M1.a.(1)
Unpaid principal balance of loans
measured at fair value: Construction,
land development, and other land
loans
M1.a.(2)
Unpaid principal balance of loans
measured at fair value: Loans
secured by farmland
M1.a.(3)(a)
Unpaid principal balance of loans
measured at fair value: Revolving,
open-end loans secured by 1–4
family residential properties and
extended under lines of credit
M1.a.(3)(b)(1) Unpaid principal balance of loans
measured at fair value: Closed-end
loans secured by 1–4 family
residential properties: Secured by
first liens
M1.a.(3)(b)(2) Unpaid principal balance of loans
measured at fair value: Closed-end
loans secured by 1–4 family
residential properties: Secured by
junior liens
M1.a.(4)
Unpaid principal balance of loans
measured at fair value: Loans
secured by multifamily (5 or more)
residential properties
M1.a.(5)
Unpaid principal balance of loans
measured at fair value: Loans
secured by nonfarm nonresidential
properties
Note: Items M1.a.(1), M1.a.(2),
M1.a.(3)(a), M1.a.(3)(b)(1),
M1.a.(3)(b)(2), M1.a.(4), and
M1.a.(5) of Schedule RC-D will be
replaced by two data items: (1)
Unpaid principal balance of loans
measured at fair value: Loans

58

MDRM Number
RCONK210

RCONF625

RCONF626

RCONF627

RCONF628

RCONF629

RCONF630

RCONF631

Schedule Item

RC-D

M1.c.(1)

RC-D

M1.c.(2)

RC-D

M1.c.(3)

RC-D

M1.c.(4)

RC-D

M2.a

RC-D

M2.b

RC-D

M3.a

RC-D

M3.b

RC-D

M3.c

Item Name
secured by 1—4 family residential
properties, and (2) Unpaid principal
balance of loans measured at fair
value: All other loans secured by
real estate.
Unpaid principal balance of loans
measured at fair value: Loans to
individuals for household, family,
and other personal expenditures:
Credit cards
Unpaid principal balance of loans
measured at fair value: Loans to
individuals for household, family,
and other personal expenditures:
Other revolving credit plans
Unpaid principal balance of loans
measured at fair value: Loans to
individuals for household, family,
and other personal expenditures:
Automobile loans
Unpaid principal balance of loans
measured at fair value: Loans to
individuals for household, family,
and other personal expenditures:
Other consumer loans
Note: Items M1.c.(1), M1.c.(2),
M1.c.(3), and M1.c.(4) of Schedule
RC-D will be combined into one
data item.
Loans measured at fair value that are
past due 90 days or more: Fair value
Loans measured at fair value that are
past due 90 days or more: Unpaid
principal balance
Structured financial products by
underlying collateral or reference
assets: Trust preferred securities
issued by financial institutions
Structured financial products by
underlying collateral or reference
assets: Trust preferred securities
issued by real estate investment
trusts
Structured financial products by

59

MDRM Number

RCONF633

RCONF634

RCONK200

RCONK211

RCONF639
RCONF640

RCONG299

RCONG332

RCONG333

Schedule Item

RC-D

M3.d

RC-D

M3.e

RC-D

M3.f

RC-D

M3.g

RC-D

M4.a

RC-D

M4.b

RC-D

M5.a

RC-D

M5.b

RC-D

M5.c

RC-D

M5.d

RC-D

M5.e

RC-D
RC-D

M5.f
M6

RC-D

M7.a

RC-D
RC-D
RC-D

M7.b
M8
M9

Item Name
underlying collateral or reference
assets: Corporate and similar loans
Structured financial products by
underlying collateral or reference
assets: 1–4 family residential MBS
issued or guaranteed by U.S.
Government-sponsored enterprises
(GSEs)
Structured financial products by
underlying collateral or reference
assets: 1–4 family residential MBS
not issued or guaranteed by GSEs
Structured financial products by
underlying collateral or reference
assets: Diversified (mixed) pools of
structured financial products
Structured financial products by
underlying collateral or reference
assets: Other collateral or reference
assets
Pledged trading assets: Pledged
securities
Pledged trading assets: Pledged
loans
Asset-backed securities: Credit card
receivables
Asset-backed securities: Home
equity lines
Asset-backed securities: Automobile
loans
Asset-backed securities: Other
consumer loans
Asset-backed securities: Commercial
and industrial loans
Asset-backed securities: Other
Retained beneficial interests in
securitizations
Equity securities: Readily
determinable fair values
Equity securities: Other
Loans pending securitization
Other trading assets

RC-D

M10

Other trading liabilities

60

MDRM Number

RCONG334

RCONG335

RCONG651

RCONG652

RCONG387
RCONG388
RCONF643
RCONF644
RCONF645
RCONF646
RCONF647
RCONF648
RCONF651
RCONF652
RCONF653
RCONF654
RCONF655,
RCONF656, RCONF657
RCONF658,

Schedule Item

Item Name

MDRM Number
RCONF659, RCONF660
RCONJ477

RC-L

1.a.(1)

RC-L

1.a.(2)

Unused commitments for Home
Equity Conversion Mortgage
(HECM) reverse mortgages
outstanding that are held for
investment
Unused commitments for proprietary RCONJ478
reverse mortgages outstanding that
are held for investment
Note: Items 1.a.(1) and 1.a.(2) of
Schedule RC-L will be combined
into one data item.
Spot foreign exchange contracts
Over-the-counter derivatives: Net
current credit exposure (Columns B,
C, and D)
Over-the-counter derivatives: Fair
value of collateral: Cash—U.S.
dollar (Columns B, C, and D)
Over-the-counter derivatives: Fair
value of collateral: Cash—Other
currencies (Columns B, C, and D)
Over-the-counter derivatives: Fair
value of collateral: U.S. Treasury
securities (Columns B, C, and D)
Over-the-counter derivatives: Fair
value of collateral: U.S. Government
agency and U.S. Governmentsponsored agency debt securities
(Columns A, B, C, D, and E)
Over-the-counter derivatives: Fair
value of collateral: Corporate bonds
(Columns A, B, C, D, and E)

RC-L
RC-L

8
16.a

RC-L

16.b.(1)

RC-L

16.b.(2)

RC-L

16.b.(3)

RC-L

16.b.(4)

RC-L

16.b.(5)

RC-L

16.b.(6)

Over-the-counter derivatives: Fair
value of collateral: Equity securities
(Columns A, B, C, D, and E)

RC-L

16.b.(7)

Over-the-counter derivatives: Fair
value of collateral: All other
collateral (Columns B, C, and D)

61

RCON8765
RCONG419,
RCONG420,
RCONG421
RCONG424,
RCONG425,
RCONG426
RCONG429,
RCONG430,
RCONG431
RCONG434,
RCONG435,
RCONG436
RCONG438,
RCONG439,
RCONG440,
RCONG441,
RCONG442
RCONG443,
RCONG444,
RCONG445,
RCONG446,
RCONG447
RCONG448,
RCONG449,
RCONG450,
RCONG451,
RCONG452
RCONG454,
RCONG455
RCONG456

Schedule Item

RC-L

RC-M

RC-M

16.b.(8)

2.b

3.f

Item Name
Note: Amounts reported in items
16.b.(4), 16.b.(5), and 16.b.(6),
Columns A and E, will be included
in item 16.b.(7), Columns A and E.
Over-the-counter derivatives: Fair
value of collateral: Total fair value
of collateral (Columns B, C, and D)
Note: Amounts reported in items
16.a, 16.b.(1), 16.b.(2), 16.b.(3),
16.b.(4), 16.b.(5), 16.b.(6), and
16.b.(7), Columns B, C, and D, will
be included in items 16.a, 16.b.(1),
16.b.(2), 16.b.(3), and 16.b.(7),
Column E.
Purchased credit card relationships
and nonmortgage servicing assets
Note: Amounts reported in item 2.b
will be included in item 2.c, All
other identifiable intangible assets.
Foreclosed properties from “GNMA
loans”

MDRM Number

RCONG459,
RCONG460
RCONG461

RCONB026

RCONC979

Note: Amounts reported in item 3.f
will be included in item 3.c, Other
real estate owned: 1—4 family
residential properties.

Other Impacts to Data Items
Schedule Item
RC
10 (New)

Item Name
Intangible assets

MDRM Number
RCON2143

RC-B

Note: Items 10.a and 10.b of Schedule RC
will be combined into this data item.
U.S. Government agency and sponsored
agency obligations (exclude mortgagebacked securities (Columns A through D)

TBD (4 MDRMs)

RC-B

2 (New)

5.b (New)

Note: Items 2.a and 2.b of Schedule RC-B
removed above will be combined into this
data item (Columns A through D).
Structured financial products (Columns A

62

TBD (4 MDRMs)

through D)

RC-D

RC-D

RC-D

RC-D

RC-D

RC-D

5.a (New)

Note: Items 5.b.(1), 5.b.(2), and 5.b.(3) of
Schedule RC-B removed above will be
combined into this data item (Columns A
through D).
Structured financial products

6.a.(1)
(New)

Note: Items 5.a.(1), 5.a.(2), and 5.a.(3) of
Schedule RC-D removed above will be
combined into this data item.
Loans secured by 1–4 family residential
properties

6.a.(2)
(New)

6.c (New)

M1.a.(1)
(New)

M1.a.(2)
(New)

Note: Items 6.a.(3)(a), 6.a.(3)(b)(1), and
6.a.(3)(b)(2) of Schedule RC-D removed
above will be combined into this data
item.
All other loans secured by real estate
Note: Items 6.a.(1), 6.a.(2), 6.a.(4), and
6.a.(5) of Schedule RC-D removed above
will be combined into this data item.
Loans to individuals for household,
family and other personal expenditures
(i.e., consumer loans) (includes purchased
paper)
Note: Items 6.c.(1), 6.c.(2), 6.c.(3), and
6.c.(4) of Schedule RC-D removed above
will be combined into this data item.
Unpaid principal balance of loans
measured at fair value: Loans secured by
1–4 family residential properties
Note: Items M1.a.(3)(a), M1.a.(3)(b)(1),
and M1.a.(3)(b)(2) of Schedule RC-D
removed above will be combined into this
data item.
Unpaid principal balance of loans
measured at fair value: All other loans
secured by real estate
Note: Items M1.a.(1), M1.a.(2), M1.a.(4),
and M1.a.(5) of Schedule RC-D removed
above will be combined into this data

63

TBD

TBD

TBD

TBD

TBD

TBD

RC-D

RC-L

RC-M

M1.c
(New)

1.a.(1)
(New)

2.b (Remapping)

item.
Unpaid principal balance of loans
measured at fair value: Loans to
individuals for household, family, and
other personal expenditures
Note: Items M1.c.(1), M1.c.(2), M1.c.(3),
and M1.c.(4) of Schedule RC-D removed
above will be combined into this data
item.
Unused commitments for reverse
mortgages outstanding that are held for
investment
Note: Items 1.a.(1) and 1.a.(2) of
Schedule RC-L removed above will be
combined into this data item.
Goodwill

TBD

TBD

RCON3163

Note: Schedule RC, item 10.a will be
moved to Schedule RC-M, new item 2.b.,
and the phrase “other than goodwill” will
be removed from the caption for Schedule
RC-M, item 2.

Data Items with a Reduction in Frequency of Collection

Semiannual Reporting (June 30 and December 31)
Schedule Item
RI
M12

RC-B

M3

RC-C,
Part I

M7.a

RC-C,
Part I

M7.b

Item Name
Noncash income from negative
amortization on closed-end loans secured
by 1–4 family
residential properties
Amortized cost of held-to-maturity
securities sold or transferred to availablefor-sale or trading securities during the
calendar year-to-date
Purchased credit-impaired loans held for
investment accounted for in accordance
with FASB ASC 310-30: Outstanding
balance
Purchased credit-impaired loans held for
investment accounted for in accordance

64

MDRM Number
RIADF228

RCON1778

RCONC779

RCONC780

Schedule Item

RC-C,
Part I

M8.a

RC-C,
Part I

M8.b

RC-C,
Part I

M8.c

RC-C,
Part I

M12.a

RC-C,
Part I

M12.b

RC-C,
Part I

M12.c

RC-C,
Part I

M12.d

Item Name
with FASB ASC 310-30: Amount
included in Schedule RC-C, Part I, items
1 through 9
Total amount of closed-end loans with
negative amortization features secured by
1–4 family residential properties
Total maximum remaining amount of
negative amortization contractually
permitted on
closed-end loans secured by 1–4 family
residential properties
Total amount of negative amortization on
closed-end loans secured by 1–4 family
residential
properties included in the amount
reported in Memorandum item 8.a above
Loans (not subject to the requirements of
FASB ASC 310-30 (former AICPA
Statement of Position 03-3)) and leases
held for investment that were acquired in
business combinations with acquisition
dates in the current calendar year: Loans
secured by real estate (Columns A
through C)
Loans (not subject to the requirements of
FASB ASC 310-30 (former AICPA
Statement of Position 03-3)) and leases
held for investment that were acquired in
business combinations with acquisition
dates in the current calendar year:
Commercial and industrial loans
(Columns A through C)
Loans (not subject to the requirements of
FASB ASC 310-30 (former AICPA
Statement of Position 03-3)) and leases
held for investment that were acquired in
business combinations with acquisition
dates in the current calendar year: Loans
to individuals for household, family, and
other personal expenditures (Columns A
through C)
Loans (not subject to the requirements of
FASB ASC 310-30 (former AICPA
Statement of Position 03-3)) and leases
held for investment that were acquired in

65

MDRM Number

RCONF230

RCONF231

RCONF232

RCONG091,
RCONG092,
RCONG093

RCONG094,
RCONG095,
RCONG096

RCONG097,
RCONG098,
RCONG099

RCONG100,
RCONG101,
RCONG102

Schedule Item

RC-L
RC-L
RC-L

1.b.(1)
1.b.(2)
11.a

RC-L

11.b

RC-N

M7

RC-N

M8

RC-N

M9.a

RC-N

M9.b

Item Name
business combinations with acquisition
dates in the current calendar year: All
other loans and all leases (Columns A
through C)
Unused consumer credit card lines
Other unused credit card lines
Year-to-date merchant credit card sales
volume: Sales for which the reporting
bank is the acquiring bank
Year-to-date merchant credit card sales
volume: Sales for which the reporting
bank is the agent bank with risk
Additions to nonaccrual assets during the
quarter

MDRM Number

RCONJ455
RCONJ456
RCONC223

RCONC224

RCONC410

Note: This caption would be revised to
“Additions to nonaccrual assets during the
last 6 months.”
Nonaccrual assets sold during the quarter RCONC411
Note: This caption would be revised to
“Nonaccrual assets sold during the last 6
months.”
Purchased credit-impaired loans
accounted for in accordance with FASB
ASC 310-30 (former AICPA Statement of
Position 03-3): Outstanding balance
(Columns A through C)
Purchased credit-impaired loans
accounted for in accordance with FASB
ASC 310-30 (former AICPA Statement of
Position 03-3): Amount included in
Schedule RC-N, items 1 through 7, above
(Columns A through C)

RCONL183,
RCONL184,
RCONL185

RCONL186,
RCONL187,
RCONL188

Annual Reporting (December)
Schedule Item
RC-M
9

RC-M

14.a

Item Name
Do any of the bank’s Internet websites
have transactional capability, i.e., allow
the bank’s customers to execute
transactions on their accounts through the
website?
Total assets of captive insurance
66

MDRM Number
RCON4088

RCONK193

Schedule Item
RC-M

14.b

Item Name
subsidiaries
Total assets of captive reinsurance
subsidiaries

MDRM Number
RCONK194

Data Items with an Increase in Reporting Threshold
Schedule RC-D is to be completed by banks that reported total trading assets of $10 million
or more in any of the four preceding calendar quarters and all banks meeting the FDIC’s
definition of a large or highly complex institution for deposit insurance assessment
purposes.
To be completed by banks with $10 billion or more in total assets
Schedule Item
Item Name
RC-B
M5.a
Asset-backed securities: Credit card
receivables (Columns A, B, C, and D)

RC-B

M5.b

Asset-backed securities: Home equity
lines (Columns A, B, C, and D)

RC-B

M5.c

Asset-backed securities: Automobile
loans (Columns A, B, C, and D)

RC-B

M5.d

Asset-backed securities: Other consumer
loans (Columns A, B, C, and D)

RC-B

M5.e

Asset-backed securities: Commercial and
industrial loans (Columns A, B, C, and
D)

RC-B

M5.f

Asset-backed securities: Other (Columns
A, B, C, and D)

RC-B

M6.a

RC-B

M6.b

Structured financial products by
underlying collateral or reference assets:
Trust preferred securities issued by
financial institutions (Columns A through
D)
Structured financial products by
underlying collateral or reference assets:
67

MDRM Number
RCONB838,
RCONB839,
RCONB840,
RCONB841
RCONB842,
RCONB843,
RCONB844,
RCONB845
RCONB846,
RCONB847,
RCONB848,
RCONB849
RCONB850,
RCONB851,
RCONB852,
RCONB853
RCONB854,
RCONB855,
RCONB856,
RCONB857
RCONB858,
RCONB859,
RCONB860,
RCONB861
RCONG348,
RCONG349,
RCONG350,
RCONG351
RCONG352,
RCONG353,

RC-B

M6.c

RC-B

M6.d

RC-B

M6.e

RC-B

M6.f

RC-B

M6.g

Trust preferred securities issued by real
estate investment trusts (Columns A
through D)
Structured financial products by
underlying collateral or reference assets:
Corporate and similar loans (Columns A
through D)
Structured financial products by
underlying collateral or reference assets:
1–4 family residential MBS issued or
guaranteed by U.S. Governmentsponsored enterprises (GSEs) (Columns
A through D)
Structured financial products by
underlying collateral or reference assets:
1–4 family residential MBS not issued or
guaranteed by GSEs (Columns A through
D)
Structured financial products by
underlying collateral or reference assets:
Diversified (mixed) pools of structured
financial products (Columns A through
D)
Structured financial products by
underlying collateral or reference assets:
Other collateral or reference assets
(Columns A through D)

RCONG354,
RCONG355
RCONG356,
RCONG357,
RCONG358,
RCONG359
RCONG360,
RCONG361,
RCONG362,
RCONG363

RCONG364,
RCONG365,
RCONG366,
RCONG367
RCONG368,
RCONG369,
RCONG370,
RCONG371
RCONG372,
RCONG373,
RCONG374,
RCONG375

To be completed by banks with components of other noninterest income in amounts greater
than $100,000 that exceed 7 percent of Schedule RI, item 5.l
Schedule Item
Item Name
MDRM Number
RI-E
1.a through Other noninterest income (from Schedule RIADC013,
1.l
RI, item 5.l)
RIADC014,
RIADC016,
RIAD4042,
RIADC015,
RIADF555,
RIADT047,
RIAD4461,
RIAD4462,
RIAD4463

68

To be completed by banks with components of other noninterest expense in amounts greater
than $100,000 that exceed 7 percent of Schedule RI, item 7.d
Schedule Item
Item Name
MDRM Number
RI-E
2.a through Other noninterest expense (from
RIADC017,
2.p
Schedule RI, item 7.d)
RIAD0497,
RIAD4136,
RIADC018,
RIAD8403,
RIAD4141,
RIAD4146,
RIADF556,
RIADF557,
RIADF558,
RIADF559,
RIADY923,
RIADY924,
RIAD4464,
RIAD4467,
RIAD4468

To be completed by banks with total trading assets of $10 million or more in any of the four
preceding calendar quarters and all banks meeting the FDIC’s definition of a large or highly
complex institution for deposit insurance assessment purposes.
Schedule Item
Item Name
MDRM Number
RC-K
7
Trading assets
RCON3401

69

Appendix D
FFIEC 031: To be completed by banks with domestic and foreign offices and banks with
domestic offices only and consolidated total assets of $100 billion or more

Data Items Removed, Other Impacts to Data Items, Data Items with a Reduction in
Frequency of Collection,
or Data Items with an Increase in Reporting Threshold

Data Items Removed
Schedule Item
RI-E
1.f

RI-E
RC

RC

1.h
10.a

Item Name
Net change in the fair values of financial
instruments accounted for under a fair
value option
Gains on bargain purchases
Goodwill

10.b

Note: Schedule RC, item 10.a will be
moved to Schedule RC-M, new item 2.b.
Other intangible assets

RCFD0426

Note: Items 10.a and 10.b of Schedule
RC will be combined into one data item.
U.S. Government agency obligations
(exclude mortgage-backed securities):
Issued by U.S. Government agencies
(Columns A through D)
U.S. Government agency obligations
(exclude mortgage-backed securities):
Issued by U.S. Government-sponsored
agencies (Columns A through D)

RCFD1289,
RCFD1290,
RCFD1291,
RCFD1293
RCFD1294,
RCFD1295,
RCFD1297,
RCFD1298

RC-B

2.a

RC-B

2.b

Note: Items 2.a and 2.b of Schedule RCB will be combined into one data item.
Structured financial products: Cash
(Columns A through D)

RC-B

5.b.(1)

RC-B

5.b.(2)

Structured financial products: Synthetic
(Columns A through D)

RC-B

5.b.(3)

Structured financial products: Hybrid
70

MDRM Number
RIADF229

RIADJ447
RCFD3163

RCFDG336,
RCFDG337,
RCFDG338,
RCFDG339
RCFDG340,
RCFDG341,
RCFDG342,
RCFDG343
RCFDG344,

Schedule Item

RC-D

All data
items
reported in
Column B,
“Domestic
offices”

Item Name
(Columns A through D)
Note: Items 5.b.(1), 5.b.(2), and 5.b.(3) of
Schedule RC-B will be combined into
one data item.
Column B, “Domestic offices”
Note: Data items 6.a.(1) through 6.a.(5),
Column B, will be combined into two
data items to be collected for the
consolidated bank in Column A, which
will replace data item 6.a, Column A. In
addition, data items M1.a.(1) through
M1.a.(5), Column B, will be combined
into two data items to be collected for the
consolidated bank in Column A, which
will replace data item M.1.a, Column A.
Data items 12 and 15, Column B, will be
moved to Schedule RC-H, new items 19
and 20. Data items 6.a.(1) through 6.d,
Column B, will be combined into one
data item and moved to Schedule RC-H,
new item 21.

71

MDRM Number
RCFDG345,
RCFDG346,
RCFDG347

RCON3531,
RCON3532,
RCON3533,
RCONG379,
RCONG380,
RCONG381,
RCONK197,
RCONK198,
RCONG383,
RCONG384,
RCONG385,
RCONG386,
RCONF604,
RCONF605,
RCONF606,
RCONF607,
RCONF611,
RCONF612,
RCONF613,
RCONF614,
RCONF615,
RCONF616,
RCONK199,
RCONK210,
RCONF618,
RCON3541,
RCON3543,
RCON3545,
RCON3546,
RCONF624,
RCON3547,
RCON3548,
RCONF625,
RCONF626,
RCONF627,
RCONF628,
RCONF629,
RCONF630,
RCONF631,
RCONF632,

Schedule Item

Item Name

MDRM Number
RCONF633,
RCONF634,
RCONK200,
RCONK211,
RCONF636,
RCONF639,
RCONF640,
RCONG299,
RCONG332,
RCONG333,
RCONG334,
RCONG335,
RCONG651,
RCONG652,
RCONG387,
RCONG388

RC-D

5.a.(1)

RCFDG383

RC-D

5.a.(2)

RC-D

5.a.(3)

Structured financial products: Cash
(Column A)
Structured financial products: Synthetic
(Column A)
Structured financial products: Hybrid
(Column A)

RC-D
RC-D

6.a
6.c.(1)

RC-D

6.c.(2)

RC-D

6.c.(3)

RC-D

6.c.(4)

Note: Items 5.a.(1), 5.a.(2), and 5.a.(3) of
Schedule RC-D, Column A, will be
combined into one data item.
Loans secured by real estate (Column A)
Loans to individuals for household,
family, and other personal expenditures:
Credit cards (Column A)
Loans to individuals for household,
family, and other personal expenditures:
Other revolving credit plans (Column A)
Loans to individuals for household,
family, and other personal expenditures:
Automobile loans (Column A)
Loans to individuals for household,
family, and other personal expenditures:
72

RCFDG384
RCFDG385

RCFDF610
RCFDF615

RCFDF616

RCFDK199

RCFDK210

Schedule Item

RC-D

M1.a

RC-D

M1.c.(1)

RC-D

M1.c.(2)

RC-D

M1.c.(3)

RC-D

M1.c.(4)

RC-D

M6

RC-L

1.a.(1)

RC-L

1.a.(2)

Item Name
Other consumer loans
Note: Items 6.c.(1), 6.c.(2), 6.c.(3), and
6.c.(4) of Schedule RC-D, Column A,
will be combined into one data item.
Unpaid principal balance of loans
measured at fair value: Loans secured by
real estate (Column A)
Unpaid principal balance of loans
measured at fair value: Loans to
individuals for household, family, and
other personal expenditures: Credit cards
(Column A)
Unpaid principal balance of loans
measured at fair value: Loans to
individuals for household, family, and
other personal expenditures: Other
revolving credit plans (Column A)
Unpaid principal balance of loans
measured at fair value: Loans to
individuals for household, family, and
other personal expenditures: Automobile
loans (Column A)
Unpaid principal balance of loans
measured at fair value: Loans to
individuals for household, family, and
other personal expenditures: Other
consumer loans (Column A)
Note: Items M1.c.(1), M1.c.(2), M1.c.(3),
and M1.c.(4) of Schedule RC-D, Column
A, will be combined into one data item.
Retained beneficial interests in
securitizations
Unused commitments for Home Equity
Conversion Mortgage (HECM) reverse
mortgages outstanding that are held for
investment
Unused commitments for proprietary
reverse mortgages outstanding that are
held for investment
Note: Items 1.a.(1) and 1.a.(2) of
Schedule RC-L will be combined into
one data item.

73

MDRM Number

RCFDF790

RCFDF633

RCFDF634

RCFDK200

RCFDK211

RCFDF651
RCONJ477

RCONJ478

Schedule Item
RC-L
16.a
RC-L

16.b.(1)

RC-L

16.b.(2)

RC-L

16.b.(3)

RC-L

16.b.(4)

RC-L

16.b.(5)

RC-L

16.b.(6)

RC-L

16.b.(7)

RC-L

16.b.(8)

RC-M

RC-M

2.b

3.f

Item Name
Over-the-counter derivatives: Net
current credit exposure (Column B)
Over-the-counter derivatives: Fair value
of collateral: Cash—U.S. dollar (Column
B)
Over-the-counter derivatives: Fair value
of collateral: Cash—Other currencies
(Column B)
Over-the-counter derivatives: Fair value
of collateral: U.S. Treasury securities
(Column B)
Over-the-counter derivatives: Fair value
of collateral: U.S. Government agency
and U.S. Government-sponsored agency
debt securities (Column B)
Over-the-counter derivatives: Fair value
of collateral: Corporate bonds (Column
B)
Over-the-counter derivatives: Fair value
of collateral: Equity securities (Column
B)
Over-the-counter derivatives: Fair value
of collateral: All other collateral (Column
B)
Over-the-counter derivatives: Fair value
of collateral: Total fair value of collateral
(Column B)
Note: Amounts reported in items 16.a,
16.b.(1), 16.b.(2), 16.b.(3), 16.b.(4),
16.b.(5), 16.b.(6), 16.b.(7), and 16.b.(8),
Column B, will be included in items 16.a,
16.b.(1), 16.b.(2), 16.b.(3), 16.b.(4),
16.b.(5), 16.b.(6), 16.b.(7), and 16.b.(8),
Column E.
Purchased credit card relationships and
nonmortgage servicing assets
Note: Amounts reported in item 2.b will
be included in item 2.c, All other
identifiable intangible assets.
Foreclosed properties from “GNMA
loans”
Note: Amounts reported in item 3.f will

74

MDRM Number
RCFDG419
RCFDG424

RCFDG429

RCFDG434

RCFDG439

RCFDG444

RCFDG449

RCFDG454

RCFDG459

RCFDB026

RCONC979

Schedule Item

Item Name
be included in item 3.c, Other real estate
owned: 1—4 family residential
properties.

MDRM Number

Other Impacts to Data Items
Schedule Item
RC
10 (New)

RC-B

RC-B

RC-D

RC-D

RC-D

2 (New)

5.b (New)

Item Name
Intangible assets

MDRM Number
RCFD2143

Note: Items 10.a and 10.b of Schedule RC
will be combined into this data item.
U.S. Government agency and sponsored
agency obligations (exclude mortgagebacked securities) (Columns A through
D)
Note: Items 2.a and 2.b of Schedule RC-B
removed above will be combined into this
data item (Columns A through D).
Structured financial products (Columns A
through D)

5.a (New)

Note: Items 5.b.(1), 5.b.(2), and 5.b.(3) of
Schedule RC-B removed above will be
combined into this data item (Columns A
through D).
Structured financial products

6.a.(1)
(New)

Note: Items 5.a.(1), 5.a.(2), and 5.a.(3) of
Schedule RC-D, Column A, removed
above will be combined into this data
item.
Loans secured by 1—4 family residential
properties

6.a.(2)
(New)

Note: Items 6.a.(3)(a), 6.a.(3)(b)(1), and
6.a.(3)(b)(2) of Schedule RC-D, Column
B, removed above will be combined into
this data item for the consolidated bank in
Column A, which will partially replace
item 6.a, Column A.
All other loans secured by real estate

75

TBD (4 MDRMs)

TBD (4 MDRMs)

TBD

TBD

TBD

RC-D

RC-D

RC-D

RC-D

6.c (New)

M1.a.(1)
(New)

M1.a.(2)
(New)

M1.c
(New)

Note: Items 6.a.(1), 6.a.(2), 6.a.(4), and
6.a.(5) of Schedule RC-D, Column B,
removed above will be combined into this
data item for the consolidated bank in
Column A, which will partially replace
item 6.a, Column A.
Loans to individuals for household,
family and other personal expenditures
(i.e., consumer loans) (includes purchased
paper)
Note: Items 6.c.(1), 6.c.(2), 6.c.(3), and
6.c.(4) of Schedule RC-D removed above
will be combined into this data item.
Unpaid principal balance of loans
measured at fair value: Loans secured by
1—4 family residential properties
Note: Items M1.a.(3)(a), M1.a.(3)(b)(1),
and M1.a.(3)(b)(2) of Schedule RC-D,
Column B, removed above will be
combined into this data item for the
consolidated bank in Column A, which
will partially replace item M.1.a, Column
A.
Unpaid principal balance of loans
measured at fair value: All other loans
secured by real estate
Note: Items M1.a.(1), M1.a.(2), M1.a.(4),
and M1.a.(5) of Schedule RC-D, Column
B, removed above will be combined into
this data item for the consolidated bank in
Column A, which will partially replace
item M.1.a, Column A.
Unpaid principal balance of loans
measured at fair value: Loans to
individuals for household, family, and
other personal expenditures (i.e.,
consumer loans) (includes purchased
paper)
Note: Items M1.c.(1), M1.c.(2), M1.c.(3),
and M1.c.(4) of Schedule RC-D, Column
A, removed above will be combined into
this data item.

76

TBD

TBD

TBD

TBD

RC-H

RC-H

RC-H

RC-L

RC-M

19 (Remapping)

20 (Remapping)

21 (New)

1.a (New)

2.b (Remapping)

Total trading assets

RCON3545

Note: Schedule RC-D, item 12, Column
B, will be moved to Schedule RC-H, item
19. The proposed threshold change
applicable to Schedule RC-D applies to
this item.
Total trading liabilities

RCON3548

Note: Schedule RC-D, item 15, Column
B, will be moved to Schedule RC-H, item
20. The proposed threshold change
applicable to Schedule RC-D applies to
this item.
Total loans held for trading

TBD

Note: The proposed threshold change
applicable to Schedule RC-D applies to
this item.
Unused commitments for reverse
mortgages outstanding that are held for
investment
Note: Items 1.a.(1) and 1.a.(2) of
Schedule RC-L removed above will be
combined into this data item.
Goodwill

TBD

RCFD3163

Note: Schedule RC, item 10.a will be
moved to Schedule RC-M, new item 2.b.,
and the phrase “other than goodwill” will
be removed from the caption for Schedule
RC-M, item 2.

Data Items with a Reduction in Frequency of Collection

Semiannual Reporting (June 30 and December 31)
Schedule Item
RI
M12

Item Name
Noncash income from negative
amortization on closed-end loans secured
by 1–4 family
residential properties

77

MDRM Number
RIADF228

Schedule Item
RC-B
M3

RC-C,
Part I

M7.a

RC-C,
Part I

M7.b

RC-C,
Part I

M8.a

RC-C,
Part I

M8.b

RC-C,
Part I

M8.c

RC-C,
Part I

M12.a

RC-C,
Part I

M12.b

RC-C,
Part I

M12.c

Item Name
Amortized cost of held-to-maturity
securities sold or transferred to availablefor-sale or trading securities during the
calendar year-to-date
Purchased credit-impaired loans held for
investment accounted for in accordance
with FASB ASC 310-30: Outstanding
balance
Purchased credit-impaired loans held for
investment accounted for in accordance
with FASB ASC 310-30: Amount
included in Schedule RC-C, Part I, items
1 through 9
Total amount of closed-end loans with
negative amortization features secured by
1–4 family residential properties
Total maximum remaining amount of
negative amortization contractually
permitted on
closed-end loans secured by 1–4 family
residential properties
Total amount of negative amortization on
closed-end loans secured by 1–4 family
residential
properties included in the amount
reported in Memorandum item 8.a above
Loans (not subject to the requirements of
FASB ASC 310-30 (former AICPA
Statement of Position 03-3)) and leases
held for investment that were acquired in
business combinations with acquisition
dates in the current calendar year: Loans
secured by real estate (Columns A
through C)
Loans (not subject to the requirements of
FASB ASC 310-30 (former AICPA
Statement of Position 03-3)) and leases
held for investment that were acquired in
business combinations with acquisition
dates in the current calendar year:
Commercial and industrial loans
(Columns A through C)
Loans (not subject to the requirements of
FASB ASC 310-30 (former AICPA
Statement of Position 03-3)) and leases

78

MDRM Number
RCFD1778

RCFDC779

RCFDC780

RCONF230

RCONF231

RCONF232

RCFDG091,
RCFDG092,
RCFDG093

RCFDG094,
RCFDG095,
RCFDG096

RCFDG097,
RCFDG098,
RCFDG099

Schedule Item

RC-C,
Part I

M12.d

RC-L
RC-L
RC-L

1.b.(1)
1.b.(2)
11.a

RC-L

11.b

RC-N

M7

RC-N

M8

RC-N

M9.a

RC-N

M9.b

Item Name
held for investment that were acquired in
business combinations with acquisition
dates in the current calendar year: Loans
to individuals for household, family, and
other personal expenditures (Columns A
through C)
Loans (not subject to the requirements of
FASB ASC 310-30 (former AICPA
Statement of Position 03-3)) and leases
held for investment that were acquired in
business combinations with acquisition
dates in the current calendar year: All
other loans and all leases (Columns A
through C)
Unused consumer credit card lines
Other unused credit card lines
Year-to-date merchant credit card sales
volume: Sales for which the reporting
bank is the acquiring bank
Year-to-date merchant credit card sales
volume: Sales for which the reporting
bank is the agent bank with risk
Additions to nonaccrual assets during the
quarter

MDRM Number

RCFDG100,
RCFDG101,
RCFDG102

RCFDJ455
RCFDJ456
RCFDC223

RCFDC224

RCFDC410

Note: This caption would be revised to
“Additions to nonaccrual assets during the
last 6 months.”
Nonaccrual assets sold during the quarter RCFDC411
Note: This caption would be revised to
“Nonaccrual assets sold during the last 6
months.”
Purchased credit-impaired loans
accounted for in accordance with FASB
ASC 310-30 (former AICPA Statement of
Position 03-3): Outstanding balance
(Columns A through C)
Purchased credit-impaired loans
accounted for in accordance with FASB
ASC 310-30 (former AICPA Statement of
Position 03-3): Amount included in
Schedule RC-N, items 1 through 7, above
(Columns A through C)

79

RCFDL183,
RCFDL184,
RCFDL185

RCFDL186,
RCFDL187,
RCFDL188

Annual Reporting (December)
Schedule Item
RC-M
9

RC-M

14.a

RC-M

14.b

Item Name
Do any of the bank’s Internet websites
have transactional capability, i.e., allow
the bank’s customers to execute
transactions on their accounts through the
website?
Total assets of captive insurance
subsidiaries
Total assets of captive reinsurance
subsidiaries

80

MDRM Number
RCFD4088

RCFDK193
RCFDK194

Data Items with an Increase in Reporting Threshold:

Schedule RI-D is to be completed by banks with foreign offices (including Edge or
Agreement subsidiaries and International Banking Facilities) and $10 billion or more in
total assets where foreign office revenues, assets, or net income exceed 10 percent of
consolidated total revenues, total assets, or net income.
Schedule RC-D is to be completed by banks that reported total trading assets of $10 million
or more in any of the four preceding calendar quarters and all banks meeting the FDIC’s
definition of a large or highly complex institution for deposit insurance assessment
purposes.
To be completed by banks with $10 billion or more in total assets
Schedule Item
Item Name
RC-B
M5.a
Asset-backed securities: Credit card
receivables (Columns A, B, C, and D)

RC-B

M5.b

Asset-backed securities: Home equity
lines (Columns A, B, C, and D)

RC-B

M5.c

Asset-backed securities: Automobile
loans (Columns A, B, C, and D)

RC-B

M5.d

Asset-backed securities: Other consumer
loans (Columns A, B, C, and D)

RC-B

M5.e

Asset-backed securities: Commercial and
industrial loans (Columns A, B, C, and
D)

RC-B

M5.f

Asset-backed securities: Other (Columns
A, B, C, and D)

RC-B

M6.a

RC-B

M6.b

Structured financial products by
underlying collateral or reference assets:
Trust preferred securities issued by
financial institutions (Columns A through
D)
Structured financial products by
underlying collateral or reference assets:

81

MDRM Number
RCFDB838,
RCFDB839,
RCFDB840,
RCFDB841
RCFDB842,
RCFDB843,
RCFDB844,
RCFDB845
RCFDB846,
RCFDB847,
RCFDB848,
RCFDB849
RCFDB850,
RCFDB851,
RCFDB852,
RCFDB853
RCFDB854,
RCFDB855,
RCFDB856,
RCFDB857
RCFDB858,
RCFDB859,
RCFDB860,
RCFDB861
RCFDG348,
RCFDG349,
RCFDG350,
RCFDG351
RCFDG352,
RCFDG353,

RC-B

M6.c

RC-B

M6.d

RC-B

M6.e

RC-B

M6.f

RC-B

M6.g

Trust preferred securities issued by real
estate investment trusts (Columns A
through D)
Structured financial products by
underlying collateral or reference assets:
Corporate and similar loans (Columns A
through D)
Structured financial products by
underlying collateral or reference assets:
1–4 family residential MBS issued or
guaranteed by U.S. Governmentsponsored enterprises (GSEs) (Columns
A through D)
Structured financial products by
underlying collateral or reference assets:
1–4 family residential MBS not issued or
guaranteed by GSEs (Columns A through
D)
Structured financial products by
underlying collateral or reference assets:
Diversified (mixed) pools of structured
financial products (Columns A through
D)
Structured financial products by
underlying collateral or reference assets:
Other collateral or reference assets
(Columns A through D)

RCFDG354,
RCFDG355
RCFDG356,
RCFDG357,
RCFDG358,
RCFDG359
RCFDG360,
RCFDG361,
RCFDG362,
RCFDG363

RCFDG364,
RCFDG365,
RCFDG366,
RCFDG367
RCFDG368,
RCFDG369,
RCFDG370,
RCFDG371
RCFDG372,
RCFDG373,
RCFDG374,
RCFDG375

To be completed by banks with $10 billion or more in total trading assets
Schedule Item
Item Name
MDRM Number
RC-D
M2.a
Loans measured at fair value that are past RCFDF639
due 90 days or more: Fair value (Column
A)
RC-D
M2.b
Loans measured at fair value that are past RCFDF640
due 90 days or more: Unpaid principal
balance (Column A)
RC-D
M3.a
Structured financial products by
RCFDG299
underlying collateral or reference assets:
Trust preferred securities issued by
financial institutions (Column A)
RC-D
M3.b
Structured financial products by
RCFDG332
underlying collateral or reference assets:
Trust preferred securities issued by real
estate investment trusts (Column A)
RC-D
M3.c
Structured financial products by
RCFDG333

82

RC-D

M3.d

RC-D

M3.e

RC-D

M3.f

RC-D

M3.g

RC-D

M4.a

RC-D

M4.b

RC-D

M5.a

RC-D

M5.b

RC-D

M5.c

RC-D

M5.d

RC-D

M5.e

RC-D
RC-D

M5.f
M7.a

RC-D
RC-D
RC-D

M7.b
M8
M9

underlying collateral or reference assets:
Corporate and similar loans (Column A)
Structured financial products by
underlying collateral or reference assets:
1–4 family residential MBS issued or
guaranteed by U.S. Governmentsponsored enterprises (GSEs) (Column
A)
Structured financial products by
underlying collateral or reference assets:
1–4 family residential MBS not issued or
guaranteed by GSEs (Column A)
Structured financial products by
underlying collateral or reference assets:
Diversified (mixed) pools of structured
financial products (Column A)
Structured financial products by
underlying collateral or reference assets:
Other collateral or reference assets
(Column A)
Pledged trading assets: Pledged securities
(Column A)
Pledged trading assets: Pledged loans
(Column A)
Asset-backed securities: Credit card
receivables
Asset-backed securities: Home equity
lines
Asset-backed securities: Automobile
loans
Asset-backed securities: Other consumer
loans
Asset-backed securities: Commercial and
industrial loans
Asset-backed securities: Other
Equity securities: Readily determinable
fair values
Equity securities: Other
Loans pending securitization
Other trading assets

RC-D

M10

Other trading liabilities

83

RCFDG334

RCFDG335

RCFDG651

RCFDG652

RCFDG387
RCFDG388
RCFDF643
RCFDF644
RCFDF645
RCFDF646
RCFDF647
RCFDF648
RCFDF652
RCFDF653
RCFDF654
RCFDF655,
RCFDF656,
RCFDF657
RCFDF658,
RCFDF659,
RCFDF660

To be completed by banks with total trading assets of $10 million or more for any quarter of
the preceding calendar year
Schedule Item
Item Name
MDRM Number
RI
M8.a
Trading revenue: Interest rate exposures RIAD8757
RI
M8.b
Trading revenue: Foreign exchange
RIAD8758
exposures
RI
M8.c
Trading revenue: Equity security and
RIAD8759
index exposures
RI
M8.d
Trading revenue: Commodity and other
RIAD8760
exposures
RI
M8.e
Trading revenue: Credit exposures
RIADF186

To be completed by banks with components of other noninterest income in amounts greater
than $100,000 that exceed 7 percent of Schedule RI, item 5.l
Schedule Item
Item Name
MDRM Number
RI-E
1.a through Other noninterest income (from Schedule RIADC013,
1.l
RI, item 5.l)
RIADC014,
RIADC016,
RIAD4042,
RIADC015,
RIADF555,
RIADT047,
RIAD4461,
RIAD4462,
RIAD4463

To be completed by banks with components of other noninterest expense in amounts greater
than $100,000 that exceed 7 percent of Schedule RI, item 7.d
Schedule Item
Item Name
MDRM Number
RI-E
2.a through Other noninterest expense (from
RIADC017,
2.p
Schedule RI, item 7.d)
RIAD0497,
RIAD4136,
RIADC018,
RIAD8403,
RIAD4141,
RIAD4146,
RIADF556,
RIADF557,
RIADF558,
RIADF559,
RIADY923,
RIADY924,
RIAD4464,

84

Schedule Item

Item Name

MDRM Number
RIAD4467,
RIAD4468

To be completed by banks with total trading assets of $10 million or more in any of the four
preceding calendar quarters and all banks meeting the FDIC’s definition of a large or highly
complex institution for deposit insurance assessment purposes.
Schedule Item
Item Name
MDRM Number
RC-K
7
Trading assets
RCFD3401

85