The OCC proposes to revise the FFIEC
101 to allow institutions subject to the advanced approaches rule
to estimate and report high volatility commercial real estate
(HVCRE) exposures on Schedules B and G of the FFIEC 101 in a manner
consistent with section 214 of the Economic Growth, Regulatory
Relief, and Consumer Protection Act (EGRRCPA). To avoid the
regulatory burden associated with applying different definitions
for HVCRE exposures within a single organization, the agencies
propose to allow an institution subject to the advanced approaches
rule to estimate and report HVCRE exposures on Schedules B and G of
the FFIEC 101 using the definition under section 214 effective for
the June 30, 2018, report date. Institutions may refine their
estimates in good faith as they obtain additional information, but
they will not be required to amend FFIEC 101 reports previously
filed for report dates on or after June 30, 2018, as these
estimates are adjusted. Alternatively, institutions may report
HVCRE exposures in a manner consistent with the current definition
contained in the agencies’ regulatory capital rules, until the
agencies take further action.
On behalf of this Federal agency, I certify that
the collection of information encompassed by this request complies
with 5 CFR 1320.9 and the related provisions of 5 CFR
1320.8(b)(3).
The following is a summary of the topics, regarding
the proposed collection of information, that the certification
covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a
benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control
number;
If you are unable to certify compliance with any of
these provisions, identify the item by leaving the box unchecked
and explain the reason in the Supporting Statement.