60-Day Federal Register Notice

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resources include, but are not limited to
personnel and subject matter experts
(Pilots, Aircraft Dispatchers, etc.),
aircraft equipped with FANS 1/A,
Airline Operations Center/Flight
Operations Center flight planning and
dispatch applications, Electronic Flight
Bags hardware and software
applications, Aircraft Interface Devices,
A/G broadband internet services,
ground automation system applications,
commercial data management services,
and other capabilities that industry may
see beneficial to support the future ATM
environment. The Live Flight
Demonstration will provide a platform
to showcase the benefits of trajectory
sharing and synchronization and begin
to establish the policies and procedures
for their routine usage with the National
Airspace System.
Registration
Space at the FTB facility is limited
and therefore, attendance will be on a
first come first served basis. However, a
webcast will be provided for those that
cannot attend in person. To attend the
Industry Day (in person or via webcast),
participants must register via the
following link: https://
www.eventbrite.com/e/4dt-live-flightdemonstration-industry-day-tickets48876809854.
Issued in Washington, DC, on September
25, 2018.
Paul Fontaine,
Director, Portfolio Management & Technology
Development Office (ANG–C).
[FR Doc. 2018–21205 Filed 9–27–18; 8:45 am]
BILLING CODE 4910–13–P

DEPARTMENT OF THE TREASURY
Office of the Comptroller of the
Currency
FEDERAL RESERVE SYSTEM
FEDERAL DEPOSIT INSURANCE
CORPORATION
Proposed Agency Information
Collection Activities; Comment
Request
Office of the Comptroller of the
Currency (OCC), Treasury; Board of
Governors of the Federal Reserve
System (Board); and Federal Deposit
Insurance Corporation (FDIC).
ACTION: Joint notice and request for
comment.

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AGENCY:

In accordance with the
requirements of the Paperwork
Reduction Act of 1995 (PRA), the OCC,
the Board, and the FDIC (the agencies)

SUMMARY:

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may not conduct or sponsor, and a
respondent is not required to respond
to, an information collection unless it
displays a currently valid Office of
Management and Budget (OMB) control
number. The Federal Financial
Institutions Examination Council
(FFIEC), of which the agencies are
members, has approved the agencies’
publication for public comment of a
proposal to revise and extend the
Consolidated Reports of Condition and
Income for a Bank with Domestic and
Foreign Offices (FFIEC 031), the
Consolidated Reports of Condition and
Income for a Bank with Domestic
Offices Only (FFIEC 041), and the
Consolidated Reports of Condition and
Income for a Bank with Domestic
Offices Only and Total Assets Less Than
$1 Billion (FFIEC 051), which are
currently approved collections of
information. The Consolidated Reports
of Condition and Income are commonly
referred to as Call Reports. The FFIEC
has also approved the Board’s
publication for public comment, on
behalf of the agencies, of a proposal to
revise and extend the Report of Assets
and Liabilities of U.S. Branches and
Agencies of Foreign Banks (FFIEC 002)
and the Report of Assets and Liabilities
of a Non-U.S. Branch that is Managed or
Controlled by a U.S. Branch or Agency
of a Foreign (Non-U.S.) Bank (FFIEC
002S) as well as the agencies’
publication for public comment of
proposals to revise and extend the
Foreign Branch Report of Condition
(FFIEC 030), the Abbreviated Foreign
Branch Report of Condition (FFIEC
030S), and the Regulatory Capital
Reporting for Institutions Subject to the
Advanced Capital Adequacy Framework
(FFIEC 101), all of which are currently
approved collections of information.
The proposed revisions generally
address the revised accounting for credit
losses under the Financial Accounting
Standards Board’s (FASB) Accounting
Standards Update (ASU) No. 2016–13,
‘‘Financial Instruments—Credit Losses
(Topic 326): Measurement of Credit
Losses on Financial Instruments’’ (ASU
2016–13). This proposal also includes
reporting changes for regulatory capital
related to implementing the agencies’
recent notice of proposed rulemaking on
the implementation and capital
transition for the current expected credit
losses methodology (CECL).
In addition, this notice includes other
revisions to the Call Reports and the
FFIEC 101 resulting from two sections
of the Economic Growth, Regulatory
Relief, and Consumer Protection Act
(EGRRCPA), effective upon enactment
on May 24, 2018, that affect the
information reported in these reports

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and for which the agencies submitted
emergency review requests to OMB that
OMB has approved.
The proposed revisions related to
ASU 2016–13 would begin to take effect
March 31, 2019, for reports with
quarterly report dates and December 31,
2019, for reports with an annual report
date, with later effective dates for
certain respondents. At the end of the
comment period for this notice, the
comments received will be reviewed to
determine whether the FFIEC and the
agencies should modify the proposed
revisions to one or more of the
previously identified reports. As
required by the PRA, the agencies will
then publish a second Federal Register
notice for a 30-day comment period and
submit the final Call Reports, FFIEC
002, FFIEC 002S, FFIEC 030, FFIEC
030S, and FFIEC 101 to OMB for review
and approval.
DATES: Comments must be submitted on
or before November 27, 2018.
ADDRESSES: Interested parties are
invited to submit written comments to
any or all of the agencies. All comments,
which should refer to the ‘‘CECL and
EGRRCPA Reporting Revisions,’’ will be
shared among the agencies.
OCC: You may submit comments,
which should refer to ‘‘CECL and
EGRRCPA Reporting Revisions,’’ by any
of the following methods:
• Email: prainfo@occ.treas.gov.
• Mail: Legislative and Regulatory
Activities Division, Office of the
Comptroller of the Currency, 400 7th
Street SW, Suite 3E–218, Washington,
DC 20219.
All comments received, including
attachments and other supporting
materials, are part of the public record
and subject to public disclosure. Do not
include any information in your
comment or supporting materials that
you consider confidential or
inappropriate for public disclosure.
You may personally inspect and
photocopy comments at the OCC, 400
7th Street SW, Washington, DC 20219.
For security reasons, the OCC requires
that visitors make an appointment to
inspect comments. You may do so by
calling (202) 649–6700 or, for persons
who are deaf or hearing impaired, TTY,
(202) 649–5597. Upon arrival, visitors
will be required to present valid
government-issued photo identification
and submit to security screening in
order to inspect and photocopy
comments.
Board: You may submit comments,
which should refer to ‘‘CECL and
EGRRCPA Reporting Revisions,’’ by any
of the following methods:
• Agency Website: http://
www.federalreserve.gov. Follow the

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Federal Register / Vol. 83, No. 189 / Friday, September 28, 2018 / Notices
instructions for submitting comments at:
http://www.federalreserve.gov/
generalinfo/foia/ProposedRegs.cfm.
• Email: regs.comments@
federalreserve.gov. Include ‘‘CECL
Reporting Revisions’’ in the subject line
of the message.
• Fax: (202) 452–3819 or (202) 452–
3102.
• Mail: Ann E. Misback, Secretary,
Board of Governors of the Federal
Reserve System, 20th Street and
Constitution Avenue NW, Washington,
DC 20551.
All public comments are available
from the Board’s website at
www.federalreserve.gov/generalinfo/
foia/ProposedRegs.cfm as submitted,
unless modified for technical reasons.
Accordingly, your comments will not be
edited to remove any identifying or
contact information. Public comments
may also be viewed electronically or in
paper form in Room 3515, 1801 K Street
NW (between 18th and 19th Streets
NW), Washington, DC 20006 between
9:00 a.m. and 5:00 p.m. on weekdays.
FDIC: You may submit comments,
which should refer to ‘‘CECL and
EGRRCPA Reporting Revisions,’’ by any
of the following methods:
• Agency Website: https://
www.fdic.gov/regulations/laws/federal/.
Follow the instructions for submitting
comments on the FDIC’s website.
• Federal eRulemaking Portal:
https://www.regulations.gov. Follow the
instructions for submitting comments.
• Email: comments@FDIC.gov.
Include ‘‘CECL Reporting Revisions’’ in
the subject line of the message.
• Mail: Manuel E. Cabeza, Counsel,
Attn: Comments, Room MB–3007,
Federal Deposit Insurance Corporation,
550 17th Street NW, Washington, DC
20429.
• Hand Delivery: Comments may be
hand delivered to the guard station at
the rear of the 550 17th Street Building
(located on F Street) on business days
between 7:00 a.m. and 5:00 p.m.
Public Inspection: All comments
received will be posted without change
to https://www.fdic.gov/regulations/
laws/federal/ including any personal
information provided. Paper copies of
public comments may be requested from
the FDIC Public Information Center by
telephone at (877) 275–3342 or (703)
562–2200.
Additionally, commenters may send a
copy of their comments to the OMB
desk officer for the agencies by mail to
the Office of Information and Regulatory
Affairs, U.S. Office of Management and
Budget, New Executive Office Building,
Room 10235, 725 17th Street NW,
Washington, DC 20503; by fax to (202)

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395–6974; or by email to oira_
submission@omb.eop.gov.
For
further information about the proposed
revisions to the information collections
discussed in this notice, please contact
any of the agency staff whose names
appear below. In addition, copies of the
reporting forms for the reports within
the scope of this notice can be obtained
at the FFIEC’s website (https://
www.ffiec.gov/ffiec_report_forms.htm).
OCC: Kevin Korzeniewski, Counsel,
(202) 649–5490, or for persons who are
hearing impaired, TTY, (202) 649–5597,
Legislative and Regulatory Activities
Division, Office of the Comptroller of
the Currency, 400 7th Street SW,
Washington, DC 20219.
Board: Nuha Elmaghrabi, Federal
Reserve Board Clearance Officer, (202)
452–3884, Office of the Chief Data
Officer, Board of Governors of the
Federal Reserve System, 20th and C
Streets NW, Washington, DC 20551.
Telecommunications Device for the Deaf
(TDD) users may call (202) 263–4869.
FDIC: Manuel E. Cabeza, Counsel,
(202) 898–3767, Legal Division, Federal
Deposit Insurance Corporation, 550 17th
Street NW, Washington, DC 20429.
SUPPLEMENTARY INFORMATION:
FOR FURTHER INFORMATION CONTACT:

I. Background
A. ASU 2016–13, ‘‘Financial
Instruments—Credit Losses (Topic 326):
Measurement of Credit Losses on
Financial Instruments’’
In June 2016, the FASB issued ASU
2016–13, which introduced CECL for
estimating allowances for credit losses
and added Topic 326, Credit Losses, to
the Accounting Standards Codification
(ASC). The new credit losses standard
changes several aspects of existing U.S.
generally accepted accounting
principles (U.S. GAAP) as follows:
• Introduction of a new credit loss
methodology.
The new accounting standard
developed by the FASB has been
designed to replace the existing
incurred loss methodology in U.S.
GAAP. Under CECL, the allowance for
credit losses is an estimate of the
expected credit losses on financial
assets measured at amortized cost,
which is measured using relevant
information about past events, including
historical credit loss experience on
financial assets with similar risk
characteristics, current conditions, and
reasonable and supportable forecasts
that affect the collectability of the
remaining cash flows over the
contractual term of the financial assets.
In concept, an allowance will be created
upon the origination or acquisition of a

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financial asset measured at amortized
cost. At subsequent reporting dates, the
allowance will be reassessed for a level
that is appropriate as determined in
accordance with CECL. The allowance
for credit losses under CECL is a
valuation account, measured as the
difference between the financial assets’
amortized cost basis and the amount
expected to be collected on the financial
assets, i.e., lifetime expected credit
losses.
• Reduction in the number of credit
impairment models.
Impairment measurement under
existing U.S. GAAP has often been
considered complex because it
encompasses five credit impairment
models for different financial assets.1 In
contrast, CECL introduces a single
measurement objective to be applied to
all financial assets measured at
amortized cost, including loans heldfor-investment (HFI) and held-tomaturity (HTM) debt securities. CECL
does not, however, specify a single
method for measuring expected credit
losses; rather, it allows any reasonable
approach, as long as the estimate of
expected credit losses achieves the
objective of the FASB’s new accounting
standard. Under the existing incurred
loss methodology, institutions use
various methods, including historical
loss rate methods, roll-rate methods,
and discounted cash flow methods, to
estimate credit losses. CECL allows the
continued use of these methods;
however, certain changes to these
methods will need to be made in order
to estimate lifetime expected credit
losses.
• Purchased credit-deteriorated (PCD)
financial assets.
CECL introduces the concept of PCD
financial assets, which replaces
purchased credit-impaired (PCI) assets
under existing U.S. GAAP. The
differences in the PCD criteria compared
to the existing PCI criteria will result in
more purchased loans HFI, HTM debt
securities, and available-for-sale (AFS)
debt securities being accounted for as
PCD financial assets. In contrast to the
existing accounting for PCI assets, the
new standard requires the estimate of
expected credit losses embedded in the
purchase price of PCD assets to be
estimated and separately recognized as
an allowance as of the date of
1 Current U.S. GAAP includes five different credit
impairment models for instruments within the
scope of CECL: ASC Subtopic 310–10, ReceivablesOverall; ASC Subtopic 450–20, Contingencies-Loss
Contingencies; ASC Subtopic 310–30, ReceivablesLoans and Debt Securities Acquired with
Deteriorated Credit Quality; ASC Subtopic 320–10,
Investments-Debt and Equity Securities—Overall;
and ASC Subtopic 325–40, Investments-OtherBeneficial Interests in Securitized Financial Assets.

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acquisition. This is accomplished by
grossing up the purchase price by the
amount of expected credit losses at
acquisition, rather than being reported
as a credit loss expense. As a result, as
of the acquisition date, the amortized
cost basis of a PCD financial asset is
equal to the principal balance of the
asset less the non-credit discount, rather
than equal to the purchase price as is
currently recorded for PCI loans.
• AFS debt securities.
The new accounting standard also
modifies the existing accounting
practices for impairment on AFS debt
securities. Under this new standard,
institutions will recognize a credit loss
on an AFS debt security through an
allowance for credit losses, rather than
a direct write-down as is required by
current U.S. GAAP. The recognized
credit loss is limited to the amount by
which the amortized cost of the security
exceeds fair value. A write-down of an
AFS debt security’s amortized cost basis
to fair value, with any incremental
impairment reported in earnings, would
be required only if the fair value of an
AFS debt security is less than its
amortized cost basis and either (1) the
institution intends to sell the debt
security, or (2) it is more likely than not
that the institution will be required to
sell the security before recovery of its
amortized cost basis.
Although the measurement of credit
loss allowances is changing under
CECL, the FASB’s new accounting
standard does not address when a
financial asset should be placed in
nonaccrual status. Therefore,
institutions should continue to apply

the agencies’ nonaccrual policies that
are currently in place. In addition, the
FASB retained the existing write-off
guidance in U.S. GAAP, which requires
an institution to write off a financial
asset in the period the asset is deemed
uncollectible.
Institutions 2 must apply ASU 2016–
13 in their Call Report, FFIEC 002,3
FFIEC 002S, FFIEC 030, FFIEC 030S,
and FFIEC 101 submissions in
accordance with the effective dates set
forth in the ASU, if an institution is
required to file such form. For
institutions that are public business
entities (PBE) and also are Securities
and Exchange Commission (SEC) filers,
as both terms are defined in U.S. GAAP,
the new credit losses standard is
effective for fiscal years beginning after
December 15, 2019, including interim
periods within those fiscal years. Thus,
for an SEC filer that has a calendar year
fiscal year, the standard is effective
January 1, 2020, and the institution
must first apply the new credit losses
standard in its Call Report, FFIEC 002,4
FFIEC 002S, FFIEC 030, and FFIEC 101
for the quarter ended March 31, 2020
(and in its FFIEC 030S for December 31,
2020), if the institution is required to
file these forms.
For a PBE that is not an SEC filer, the
credit losses standard is effective for
fiscal years beginning after December
15, 2020, including interim periods
within those fiscal years. Thus, for a
PBE that is not an SEC filer and has a
calendar year fiscal year, the standard is
effective January 1, 2021, and the
institution must first apply the new
credit losses standard in its Call Report,

FFIEC 002,5 FFIEC 002S, FFIEC 030,
and FFIEC 101 for the quarter ended
March 31, 2021 (and in its FFIEC 030S
for December 31, 2021), if the institution
is required to file these forms.
For an institution that is not a PBE,
the credit losses standard is effective for
fiscal years beginning after December
15, 2020, and for interim period
financial statements for fiscal years
beginning after December 15, 2021.6
Thus, an institution with a calendar
year fiscal year that is not a PBE must
first apply the new credit losses
standard in its Call Report, FFIEC 002,7
FFIEC 002S, FFIEC 030, FFIEC 030S,
and FFIEC 101 for December 31, 2021,
if the institution is required to file these
forms.8 However, such an institution
would include the ASU 2016–13 credit
loss provisions for the entire year ended
December 31, 2021, in the income
statement in its Call Report for year-end
2021. The institution would also
recognize in its year-end 2021 Call
Report a cumulative-effect adjustment to
the beginning balance of retained
earnings as of January 1, 2021, resulting
from the adoption of the new standard
as of the beginning of the 2021 fiscal
year.
For regulatory reporting purposes,
early application of the new credit
losses standard will be permitted for all
institutions for fiscal years beginning
after December 15, 2018, including
interim periods within those fiscal
years.
The following table provides a
summary of the effective dates for ASU
2016–13.

EFFECTIVE DATES FOR ASU 2016–13
Regulatory report
effective date *

U.S. GAAP effective date
PBEs That Are SEC Filers ..............
Other PBEs (Non-SEC Filers) ........
Non-PBEs ........................................
Early Application .............................

Fiscal years beginning after 12/15/2019, including interim periods
within those fiscal years.
Fiscal years beginning after 12/15/2020, including interim periods
within those fiscal years.
Fiscal years beginning after 12/15/2020, and interim periods for fiscal
years beginning after 12/15/2021 9.
Early application permitted for fiscal years beginning after 12/15/
2018, including interim periods within those fiscal years.

3/31/2020.
3/31/2021.
12/31/2021.10
First calendar quarter-end after effective date of early application
of the ASU.

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* For institutions with calendar fiscal year-ends and reports with quarterly report dates.

2 Institutions include banks, savings associations,
holding companies, U.S. branches and agencies of
foreign banks, and foreign branches of U.S. banks
and U.S. savings associations.
3 As stated in the instructions for the FFIEC 002,
U.S. branches and agencies of foreign banks may
choose to, but are not required to, maintain credit
loss allowances on an office level.
4 See footnote 3.

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5 See

footnote 3.
August 20, 2018, the FASB issued a
proposed ASU that would amend the transition and
effective date provisions in ASU 2016–13 for
entities that are not PBEs (non-PBEs) so that the
credit losses standard would be effective for nonPBEs for fiscal years beginning after December 15,
2021, including interim periods within those fiscal
years.
7 See footnote 3.
6 On

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8 If the FASB issues a final Accounting Standards
Update amending the transition and effective date
provisions in ASU 2016–13 as described in footnote
6, a non-PBE with a calendar year fiscal year would
first apply the new credit losses standard in its
reports for March 31, 2022, if an institution is
required to file these report forms.
9 See footnote 6.
10 See footnote 8.

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Federal Register / Vol. 83, No. 189 / Friday, September 28, 2018 / Notices
For additional information on key
elements of the new accounting
standard and initial supervisory views
with respect to measurement methods,
use of vendors, portfolio segmentation,
data needs, qualitative adjustments, and
allowance processes, refer to the
agencies’ Joint Statement on the New
Accounting Standard on Financial
Instruments—Credit Losses issued on
June 17, 2016, and Frequently Asked
Questions on the New Accounting
Standard on Financial Instruments—
Credit Losses (CECL FAQs), which were
last updated on September 6, 2017.11
B. EGRRCPA
On May 24, 2018, EGRRCPA amended
various statutes administered by the
agencies and affected regulations issued
by the agencies.12 Two of the
amendments made by EGRRCPA, as
described below, took effect on the day
of EGRRCPA’s enactment and impact
institutions’ regulatory reports. In
response to emergency review requests,
the agencies received approval from
OMB to revise the reporting of
information in the Call Reports on
certain high volatility commercial real
estate (HVCRE) exposures and
reciprocal deposits and in the FFIEC
101 report on certain HVCRE exposures
for the June 30, 2018, report date. As a
result of OMB’s emergency approval of
revisions to the information collections
affected by the above statutory changes,
the expiration date of these collections
has been revised to February 28, 2019.
The agencies are now undertaking the
regular PRA process for revising and
extending these information collections
for three years as described in this
notice.

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• HVCRE Exposures
Section 214 of EGRRCPA adds a new
Section 51 to the Federal Deposit
Insurance Act (FDI Act) governing the
risk-based capital requirements for
certain acquisition, development, or
construction (ADC) loans. EGRRCPA
provides that, effective upon enactment,
the agencies may only require a
depository institution to assign a
heightened risk weight to an HVCRE
exposure if such exposure is an
‘‘HVCRE ADC Loan,’’ as defined in
Section 214 of EGRRCPA. Accordingly,
a depository institution is permitted to
use the definition of HVCRE ADC Loan
11 The CECL FAQs and a related link to the joint
statement can be found on the following agency
websites: Board: https://www.federalreserve.gov/
supervisionreg/srletters/sr1708a1.pdf; FDIC: https://
www.fdic.gov/news/news/financial/2017/fil170
41a.pdf; OCC: https://www.occ.gov/topics/bankoperations/accounting/cecl/cecl-faqs.html.
12 Public Law 115–174, 132 Stat. 1296 (2018).

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in place of the existing definition of
HVCRE loan when reporting HVCRE
exposures held for sale, held for
investment, and held for trading on
Schedule RC–R, Regulatory Capital, Part
II, Risk-Weighted Assets, in the Call
Reports, as well as on Schedule B and
Schedule G in the FFIEC 101 for
institutions required to file that form.

Board
OMB Control No.: 7100–0036.
Estimated Number of Respondents:
808 state member banks.
Estimated Average Burden per
Response: 49.87 burden hours per
quarter to file.
Estimated Total Annual Burden:
161,180 burden hours to file.

• Reciprocal Deposits

FDIC
OMB Control No.: 3064–0052.
Estimated Number of Respondents:
3,596 insured state nonmember banks
and state savings associations.
Estimated Average Burden per
Response: 43.85 burden hours per
quarter to file.
Estimated Total Annual Burden:
630,738 burden hours to file.
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 121.74
(FFIEC 031), 55.57 (FFIEC 041), and
38.59 (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
banks and savings associations under
each agency’s supervision (e.g., size
distribution of such institutions, types
of activities in which they are engaged,
and existence of foreign offices).
Type of Review: Extension and
revision of currently approved
collections.

Section 29 of the FDI Act (12 U.S.C.
1831f), as amended by Section 202 of
EGRRCPA, excepts a capped amount of
reciprocal deposits from treatment as
brokered deposits for qualifying
institutions, effective upon enactment.
The current Call Report instructions,
consistent with the law prior to the
enactment of EGRRCPA, treat all
reciprocal deposits as brokered deposits.
When reporting in the Call Report,
institutions should apply the newly
defined terms and other provisions of
Section 202 to determine whether they
and their reciprocal deposits are eligible
for the statutory exclusion and report as
brokered deposits in Schedule RC–E,
and reciprocal brokered deposits in
Schedule RC–O, only those reciprocal
deposits that are considered brokered
deposits under the new law.
II. Affected Reports and Specific
Revisions
A. Call Reports
The agencies propose to extend for
three years, with revision, the FFIEC
031, FFIEC 041, and FFIEC 051 Call
Reports.
Report Title: Consolidated Reports of
Condition and Income (Call Report).
Form Numbers: FFIEC 031 (for banks
and savings associations with domestic
and foreign offices), FFIEC 041 (for
banks and savings associations with
domestic offices only),13 and FFIEC 051
(for banks and savings associations with
domestic offices only and total assets
less than $1 billion).
Frequency of Response: Quarterly.
Affected Public: Business or other forprofit.
OCC
OMB Control No.: 1557–0081.
Estimated Number of Respondents:
1,252 national banks and federal savings
associations.
Estimated Average Burden per
Response: 45.98 burden hours per
quarter to file.
Estimated Total Annual Burden:
230,268 burden hours to file.
13 Banks and savings associations with domestic
offices only and total consolidated assets of $100
billion or more file the FFIEC 031 report rather than
the FFIEC 041 report.

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General Description of Reports
The Call Report information
collections are mandatory: 12 U.S.C. 161
(for national banks), 12 U.S.C. 324 (for
state member banks), 12 U.S.C. 1817 (for
insured state nonmember commercial
and savings banks), and 12 U.S.C. 1464
(for federal and state savings
associations). At present, except for
selected data items and text, these
information collections are not given
confidential treatment.
Abstract
Banks and savings associations
submit Call Report data to the agencies
each quarter for the agencies’ use in
monitoring the condition, performance,
and risk profile of individual
institutions and the industry as a whole.
Call Report data serve a regulatory or
public policy purpose by assisting the
agencies in fulfilling their shared
missions of ensuring the safety and
soundness of financial institutions and
the financial system and protecting
consumer financial rights, as well as

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agency-specific missions affecting
national and state-chartered institutions,
such as conducting monetary policy,
ensuring financial stability, and
administering federal deposit insurance.
Call Reports are the source of the most
current statistical data available for
identifying areas of focus for on-site and
off-site examinations. Among other
purposes, the agencies use Call Report
data in evaluating institutions’ corporate
applications, including, in particular,
interstate merger and acquisition
applications for which the agencies are
required by law to determine whether
the resulting institution would control
more than 10 percent of the total
amount of deposits of insured
depository institutions in the United
States. Call Report data also are used to
calculate institutions’ deposit insurance
and Financing Corporation assessments
and national banks’ and federal savings
associations’ semiannual assessment
fees.
B. FFIEC 002 and 002S
The Board proposes to extend for
three years, with revision, on behalf of
the agencies the FFIEC 002 and FFIEC
002S reports.
Report Titles: Report of Assets and
Liabilities of U.S. Branches and
Agencies of Foreign Banks; Report of
Assets and Liabilities of a Non-U.S.
Branch that is Managed or Controlled by
a U.S. Branch or Agency of a Foreign
(Non-U.S.) Bank.
Form Numbers: FFIEC 002; FFIEC
002S.
OMB control number: 7100–0032.
Frequency of Response: Quarterly.
Affected Public: Business or other forprofit.
Respondents: All state-chartered or
federally-licensed U.S. branches and
agencies of foreign banking
organizations, and all non-U.S. branches
managed or controlled by a U.S. branch
or agency of a foreign banking
organization.
Estimated Number of Respondents:
FFIEC 002—209; FFIEC 002S—38.
Estimated Average Burden per
Response: FFIEC 002—23.87 hours;
FFIEC 002S—6.0 hours.
Estimated Total Annual Burden:
FFEIC 002—19,955 hours; FFIEC 002S—
912 hours.
Type of Review: Extension and
revision of currently approved
collections.
General Description of Reports
These information collections are
mandatory (12 U.S.C. 3105(c)(2),
1817(a)(1) and (3), and 3102(b)). Except
for select sensitive items, the FFIEC 002
is not given confidential treatment; the

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FFIEC 002S is given confidential
treatment (5 U.S.C. 552(b)(4) and (8)).
Abstract
On a quarterly basis, all U.S. branches
and agencies of foreign banks are
required to file the FFIEC 002, which is
a detailed report of condition with a
variety of supporting schedules. This
information is used to fulfill the
supervisory and regulatory requirements
of the International Banking Act of
1978. The data are also used to augment
the bank credit, loan, and deposit
information needed for monetary policy
and other public policy purposes. The
FFIEC 002S is a supplement to the
FFIEC 002 that collects information on
assets and liabilities of any non-U.S.
branch that is managed or controlled by
a U.S. branch or agency of the foreign
bank. A non-U.S. branch is managed or
controlled by a U.S. branch or agency if
a majority of the responsibility for
business decisions, including but not
limited to decisions with regard to
lending or asset management or funding
or liability management, or the
responsibility for recordkeeping with
respect to assets or liabilities for that
foreign branch, resides at the U.S.
branch or agency. A separate FFIEC
002S must be completed for each
managed or controlled non-U.S. branch.
The FFIEC 002S must be filed quarterly
along with the U.S. branch or agency’s
FFIEC 002. The data from both reports
are used for (1) monitoring deposit and
credit transactions of U.S. residents; (2)
monitoring the impact of policy
changes; (3) analyzing structural issues
concerning foreign bank activity in U.S.
markets; (4) understanding flows of
banking funds and indebtedness of
developing countries in connection with
data collected by the International
Monetary Fund and the Bank for
International Settlements that are used
in economic analysis; and (5) assisting
in the supervision of U.S. offices of
foreign banks. The Federal Reserve
System collects and processes these
reports on behalf of all three agencies.
C. FFIEC 030 and 030S
The agencies propose to extend for
three years, with revision, the FFIEC
030 and FFIEC 030S reports.
Report Title: Foreign Branch Report of
Condition.
Form Numbers: FFIEC 030 and FFIEC
030S.
Frequency of Response: Annually,
and quarterly for significant branches.
Affected Public: Business or other for
profit.
OCC
OMB Number: 1557–0099.

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Estimated Number of Respondents:
199 annual branch respondents (FFIEC
030); 57 quarterly branch respondents
(FFIEC 030); 30 annual branch
respondents (FFIEC 030S).
Estimated Average Time per
Response: 3.4 burden hours (FFIEC
030); 0.5 burden hours (FFIEC 030S).
Estimated Total Annual Burden:
1,467 burden hours.
Board
OMB Number: 7100–0071.
Estimated Number of Respondents: 14
annual branch respondents (FFIEC 030);
24 quarterly branch respondents (FFIEC
030); 11 annual branch respondents
(FFIEC 030S).
Estimated Average Time per
Response: 3.4 burden hours (FFIEC
030); 0.5 burden hours (FFIEC 030S).
Estimated Total Annual Burden: 380
burden hours.
FDIC
OMB Number: 3064–0011.
Estimated Number of Respondents: 8
annual branch respondents (FFIEC 030);
1 quarterly branch respondent (FFIEC
030); 8 annual branch respondents
(FFIEC 030S).
Estimated Average Time per
Response: 3.4 burden hours (FFIEC
030); 0.5 burden hours (FFIEC 030S).
Estimated Total Annual Burden: 45
burden hours.
Type of Review: Extension and
revision of currently approved
collections.
General Description of Reports
This information collection is
mandatory: 12 U.S.C. 602 (Board); 12
U.S.C. 161 and 602 (OCC); and 12 U.S.C.
1828 (FDIC). This information collection
is given confidential treatment under 5
U.S.C. 552(b)(4) and (8).
Abstract
The FFIEC 030 collects asset and
liability information for foreign
branches of insured U.S. banks and
insured U.S. savings associations (U.S.
depository institutions) and is required
for regulatory and supervisory purposes.
The information is used to analyze the
foreign operations of U.S. institutions.
All foreign branches of U.S. institutions
regardless of charter type file this report
as provided in the instructions to the
FFIEC 030 and FFIEC 030S.
A U.S. depository institution
generally must file a separate report for
each foreign branch, but in some cases
may consolidate filing for multiple
foreign branches in the same country, as
described below. A branch with either
total assets of at least $2 billion or
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currencies and U.S. dollar exchange of
at least $5 billion as of the end of a
calendar quarter is considered a
‘‘significant branch’’ and an FFIEC 030
report is required to be filed quarterly.
A U.S. depository institution with a
foreign branch having total assets in
excess of $250 million that does not
meet either of the criteria to file
quarterly must file the entire FFIEC 030
report for this foreign branch on an
annual basis as of December 31.
A U.S. depository institution with a
foreign branch having total assets of $50
million, but less than or equal to $250
million that does not meet the criteria
to file the FFIEC 030 report must file the
FFIEC 030S report for this foreign
branch on an annual basis as of
December 31. A U.S. depository
institution with a foreign branch having
total assets of less than $50 million is
exempt from filing the FFIEC 030 and
030S reports.
D. FFIEC 101
The agencies propose to extend for
three years, with revision, the FFIEC
101 report.
Report Title: Risk-Based Capital
Reporting for Institutions Subject to the
Advanced Capital Adequacy
Framework.
Form Number: FFIEC 101.
Frequency of Response: Quarterly.
Affected Public: Business or other forprofit.

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OCC
OMB Control No.: 1557–0239.
Estimated Number of Respondents: 20
national banks and federal savings
associations.
Estimated Time per Response: 674
burden hours per quarter to file.
Estimated Total Annual Burden:
53,920 burden hours to file.
Board
OMB Control No.: 7100–0319.
Estimated Number of Respondents: 6
state member banks; 16 bank holding
companies and savings and loan
holding companies; and 6 intermediate
holding companies.
Estimated Time per Response: 674
burden hours per quarter for state
member banks to file, 677 burden hours
per quarter for bank holding companies
and savings and loan holding
companies to file; and 3 burden hours
per quarter for intermediate holding
companies to file.
Estimated Total Annual Burden:
16,176 burden hours for state member
banks to file; 43,328 burden hours for
bank holding companies and savings
and loan holding companies to file; and
72 burden hours for intermediate
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FDIC
OMB Control No.: 3064–0159.
Estimated Number of Respondents: 2
insured state nonmember banks and
state savings associations.
Estimated Time per Response: 674
burden hours per quarter to file.
Estimated Total Annual Burden:
5,392 burden hours to file.
Type of Review: Extension and
revision of currently approved
collections.
General Description of Reports
Each advanced approaches
institution 14 is required to report
quarterly regulatory capital data on the
FFIEC 101. The FFIEC 101 information
collection is mandatory for advanced
approaches institutions: 12 U.S.C. 161
(national banks), 12 U.S.C. 324 (state
member banks), 12 U.S.C. 1844(c) (bank
holding companies), 12 U.S.C. 1467a(b)
(savings and loan holding companies),
12 U.S.C. 1817 (insured state
nonmember commercial and savings
banks), 12 U.S.C. 1464 (savings
associations), and 12 U.S.C. 1844(c),
3106, and 3108 (intermediate holding
companies). Certain data items in this
information collection are given
confidential treatment under 5 U.S.C.
552(b)(4) and (8).
Abstract
The agencies use data reported in the
FFIEC 101 to assess and monitor the
levels and components of each reporting
entity’s capital requirements and the
adequacy of the entity’s capital under
the Advanced Capital Adequacy
Framework; 15 to evaluate the impact of
the Advanced Capital Adequacy
Framework on individual reporting
entities and on an industry-wide basis
and its competitive implications; and to
supplement on-site examination
processes. The reporting schedules also
assist advanced approaches institutions
in understanding expectations relating
to the system development necessary for
implementation and validation of the
Advanced Capital Adequacy
Framework. Submitted data that are
released publicly will also provide other
interested parties with information
about advanced approaches institutions’
regulatory capital.
Current Actions
I. Introduction
In response to the new credit losses
standard, key elements of which were
14 See 12 CFR 3.100(b) (OCC); 12 CFR 217.100(b)
(Board); 12 CFR 324.100(b) (FDIC).
15 12 CFR part 3, subpart E (OCC); 12 CFR part
217, subpart E (Board); 12 CFR part 324, subpart E
(FDIC).

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outlined above in Section A of
‘‘Supplementary Information, I.
Background,’’ the agencies reviewed the
existing FFIEC reports to determine
which reports may be affected by ASU
2016–13. As a result, revisions are
proposed to the following FFIEC
reports: (1) Call Reports (FFIEC 031,
FFIEC 041, and FFIEC 051), (2) FFIEC
002 and FFIEC 002S, (3) FFIEC 030 and
FFIEC 030S, and (4) the FFIEC 101.
The agencies also reviewed the
existing FFIEC reports to determine
which reports may be affected by
EGRRCPA. As a result, additional
revisions are proposed for the Call
Reports (FFIEC 031, FFIEC 041, and
FFIEC 051) and the FFIEC 101.
A detailed description of the
proposed revisions resulting from both
ASU 2016–13 and EGRRCPA follows.
II. Call Report Revisions
A. General Discussion of Proposed Call
Report Revisions
1. ASU 2016–13 Proposed Call Report
Revisions
In response to the changes in
accounting for credit losses under ASU
2016–13, the agencies are proposing
revisions to the manner in which data
on credit losses is reported in the Call
Report. These changes are necessary to
align the information reported in the
Call Report with the new accounting
standard as it relates to the credit losses
for loans and leases, including offbalance sheet credit exposures.16 The
revisions also address the broader scope
of financial assets for which an
allowance for credit losses must be
established and maintained, and the
elimination of the existing model for
PCI assets, as described in more detail
later in this section.
In developing these proposed Call
Report revisions, the agencies followed
the guiding principles for evaluating
potential additions and deletions of Call
Report data 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
shared 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 state-chartered
institutions; (2) the data items to be
collected maximize practical utility and
minimize, to the extent practicable and
appropriate, burden on financial
16 See

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institutions; and (3) equivalent data
items are not readily available through
other means. The agencies also applied
these principles in developing the
proposed revisions to the other FFIEC
reports within the scope of this notice.
In following these principles, the
agencies sought to limit the number of
data items being added to the Call
Report and the other reports within the
scope of this notice to address the
changes in accounting for credit losses.
The majority of the proposed changes
address the broader scope of assets
subject to an allowance for credit losses
assessment under ASU 2016–13.
Throughout the Call Report, the
agencies generally propose to request
credit loss information on loans and
leases, HTM debt securities, and AFS
debt securities given the materiality of
these asset types to institutions’ overall
balance sheets as well as the potential
materiality of the allowances for credit
losses on these assets.
The existing Call Report schedules
impacted by ASU 2016–13 and included
in the development of this proposal are:
D Schedule RI—Income Statement
D Schedule RI–B—Charge-offs and
Recoveries on Loans and Leases and
Changes in Allowance for Loan and
Lease Losses
D Schedule RI–C—Disaggregated Data
on the Allowance for Loan and Lease
Losses [FFIEC 031 and FFIEC 041 only]
D Schedule RI–D—Income from
Foreign Offices [FFIEC 031 only]
D Schedule RI–E—Explanations
D Schedule RC—Balance Sheet
D Schedule RC–B—Securities
D Schedule RC–C—Loans and Lease
Financing Receivables
D Schedule RC–F—Other Assets
D Schedule RC–G—Other Liabilities
D Schedule RC–H—Selected Balance
Sheet Items for Domestic Offices [FFIEC
031 only]
D Schedule RC–K—Quarterly
Averages
D Schedule RC–N—Past Due and
Nonaccrual Loans, Leases, and Other
Assets
D Schedule RC–R—Regulatory Capital
D Schedule RC–V—Variable Interest
Entities [FFIEC 031 and FFIEC 041 only]
D Schedule SU—Supplemental
Information [FFIEC 051 only]
As noted previously, ASU 2016–13
broadens the scope of financial assets
for which allowances for credit losses
must be estimated. CECL is applicable
to all financial instruments measured at
amortized cost (including loans held for
investment and HTM debt securities, as
well as trade and reinsurance
receivables and receivables that relate to
repurchase agreements and securities

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lending agreements), net investments in
leases, and off-balance-sheet credit
exposures not accounted for as
insurance, including loan commitments,
standby letters of credit, and financial
guarantees. In addition, under ASU
2016–13, institutions will record credit
losses on AFS debt securities through an
allowance for credit losses rather than
as a write-down through earnings for
other-than-temporary impairment
(OTTI). The broader scope of financial
assets for which allowances must be
estimated under ASU 2016–13 results in
the proposed reporting of additional
allowances, and related charge-off and
recovery data, in the Call Report and
proposed changes to the terminology
used to describe allowances for credit
losses within the Call Report. To
address the broader scope of assets that
will have allowances under ASU 2016–
13, the agencies propose to change the
allowance nomenclature to consistently
use ‘‘allowance for credit losses’’
followed by the specific asset type as
relevant, e.g., ‘‘allowance for credit
losses on loans and leases’’ and
‘‘allowance for credit losses on HTM
debt securities.’’
By broadening the scope of financial
assets for which the need for allowances
for credit losses must be assessed to
include HTM and AFS debt securities,
the new standard eliminates the existing
OTTI model for such securities.
Subsequent to an institution’s adoption
of ASU 2016–13, the concept of OTTI
will no longer be relevant and
information on OTTI will no longer be
captured in the Call Report.
The new standard also eliminates the
separate impairment model for PCI
loans and debt securities. Under CECL,
credit losses on PCD financial assets
measured at amortized cost are subject
to the same credit loss measurement
standard as all other financial assets
measured at amortized cost. Subsequent
to an institution’s adoption of ASU
2016–13, information on PCI loans will
no longer be captured in the Call Report.
While the standard generally does not
change the scope of off-balance sheet
credit exposures subject to an allowance
for credit loss assessment, the standard
does change the period over which an
institution should estimate expected
credit losses. For off-balance-sheet
credit exposures, an institution will
estimate expected credit losses over the
contractual period in which it is
exposed to credit risk via a present
contractual obligation to extend credit.
For the period of exposure, the estimate
of expected credit losses should
consider both the likelihood that
funding will occur and the amount
expected to be funded over the

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estimated remaining life of the
commitment or other off-balance-sheet
exposure. In contrast to existing
practices, the FASB decided that no
credit losses should be recognized on
off-balance-sheet credit exposures that
are unconditionally cancellable by the
issuer. The exclusion of unconditionally
cancellable off-balance sheet exposures
from the allowance for credit losses
assessment requires clarification in the
Call Report instructions.
The agencies also note that, because
of the different effective dates for ASU
2016–13 for PBEs that are SEC filers,
other PBEs (non-SEC filers), and all
other entities, as well as the option for
early adoption and the varying fiscal
years across the population of
institutions that file Call Reports, the
period over which institutions may be
implementing this ASU ranges from the
first quarter of 2019 through the fourth
quarter of 2022. December 31, 2022, will
be the first quarter-end Call Report date
as of which all institutions would be
required to prepare their Call Reports in
accordance with ASU 2016–13.17 As a
result, the agencies are proposing
revisions to the reporting of information
on credit losses in response to the ASU
that would be introduced in the Call
Report effective March 31, 2019, but
would not be fully phased in until the
Call Report for December 31, 2022.18
As of the new accounting standard’s
effective date for an individual
institution, the institution will apply the
standard based on the characteristics of
financial assets as follows:
• Financial assets measured at
amortized cost (that are not PCD assets)
and net investments in leases: A
cumulative-effect adjustment for the
changes in the allowances for credit
losses on these assets will be recognized
in retained earnings, net of applicable
taxes, as of the beginning of the fiscal
year in which the new standard is
adopted. The cumulative-effect
adjustment to retained earnings should
be reported in Call Report Schedule RI–
A, item 2, ‘‘Cumulative effect of changes
in accounting principles and corrections
of material accounting errors,’’ and
explained in Schedule RI–E, item 4.a,
for which a preprinted caption,
‘‘Adoption of Current Expected Credit
17 If the FASB issues a final Accounting
Standards Update amending the transition and
effective date provisions in ASU 2016–13 as
described in footnote 6, December 31, 2022, would
continue to be the first quarter-end Call Report date
as of which all institutions would be required to
prepare their Call Reports in accordance with ASU
2016–13.
18 See CECL FAQs, question 36, for examples of
how and when institutions with non-calendar fiscal
years must incorporate the new credit losses
standard into their regulatory reports.

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Losses Methodology—ASC Topic 326,’’
will be provided in the text field for this
item.
• Purchased credit-deteriorated
financial assets: Financial assets
classified as PCI assets prior to the
effective date of the new standard will
be classified as PCD assets as of the
effective date. For all financial assets
designated as PCD assets as of the
effective date, an institution will be
required to gross up the balance sheet
amount of the financial asset by the
amount of its allowance for expected
credit losses as of the effective date,
resulting in an adjustment to the
amortized cost basis of the asset to
reflect the addition of the allowance for
credit losses as of that date. For loans
held for investment and held-tomaturity debt securities, this allowance
gross-up as of the effective date of ASU
2016–13 should be reported in the
appropriate columns of Schedule RI–B,
Part II, item 6, ‘‘Adjustments,’’ and
should be included in the amount
reported in Schedule RI–E, item 6.b, for
which a preprinted caption, ‘‘Effect of
adoption of current expected credit
losses methodology on allowances for
credit losses on loans and leases held
for investment and held-to-maturity
debt securities,’’ will be provided in the
text field for this item. Subsequent
changes in the allowances for credit
losses on PCD financial assets will be
recognized by charges or credits to
earnings through provisions for credit
losses. The institution will accrete the
noncredit discount or premium to
interest income based on the effective
interest rate on the PCD financial assets
determined after the gross-up for the
CECL allowance as of the effective date,
except for PCD financial assets in
nonaccrual status.
• AFS and HTM debt securities: A
debt security on which OTTI had been
recognized prior to the effective date of
the new standard will transition to the
new guidance prospectively (i.e., with
no change in the amortized cost basis of
the security). The effective interest rate
on such a debt security before the
adoption date will be retained and
locked in. Amounts previously
recognized in accumulated other
comprehensive income related to cash
flow improvements will continue to be
accreted to interest income over the
remaining life of the debt security on a
level-yield basis. Recoveries of amounts
previously written off relating to
improvements in cash flows after the
date of adoption will be recognized in
income in the period received.

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2. EGRRCPA Proposed Call Report
Revisions
This proposal addresses the changes
to the reporting of reciprocal deposits
and HVCRE exposures in the Call
Report resulting from EGRRCPA. The
guiding principles, noted above, were
applied in determining these proposed
changes to the Call Report.
The existing Call Report schedules
impacted by EGRRCPA and for which
revisions are included in this proposal
are:
D Schedule RC–E—Deposit Liabilities
D Schedule RC–O—Other Data for
Deposit Insurance and FICO
Assessments
D Schedule RC–R—Regulatory
Capital: Part II. Risk-Weighted Assets
B. Detail of Specific Proposed Call
Report Revisions
The proposed Call Report revisions
are consistent across the FFIEC 031,
FFIEC 041, and FFIEC 051 reporting
forms to the extent that the same
schedule and data items within these
schedules currently exist within each
reporting form. Throughout this detailed
discussion of specific proposed Call
Report revisions, for each schedule
discussed, the agencies have included
the affected form numbers next to the
schedule name. Unless otherwise stated,
all changes relating to a particular
schedule apply to all forms listed.
1. ASU 2016–13
Revisions

Proposed Call Report

Due to the staggered effective dates,
ASU 2016–13 will not be implemented
by all institutions until December 2022.
It is expected that the majority of
institutions will implement the standard
in the first or fourth quarter of 2021. As
such, the proposed revisions to
schedule titles or specific data item
captions resulting from the change in
nomenclature upon the adoption of
CECL generally would not be reflected
in the reporting forms until March 31,
2021, as outlined in the following
schedule-by-schedule descriptions of
the proposed changes to the affected
Call Report schedules. Effective for the
March 31, 2021, report date, unless
otherwise indicated, the schedule titles
or specific data item captions
referencing the ‘‘provision for loan and
lease losses’’ and the ‘‘allowance for
loan and lease losses’’ would be
changed to the ‘‘provision for credit
losses’’ and the ‘‘allowance for credit
losses on loans and leases,’’
respectively.
From March 31, 2019, through
December 31, 2020, the reporting form
and instructions for each schedule title

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or data item impacted by the change in
nomenclature would include guidance
stating how institutions that have
adopted ASU 2016–13 would report the
data items related to the ‘‘provision for
credit losses’’ and ‘‘allowance for credit
losses,’’ as applicable. For the transition
period from March 31, 2021, through
December 31, 2022, the reporting form
and instructions for each impacted
schedule title or data item would be
updated to include guidance stating
how institutions that have not adopted
ASU 2016–13 would report the
‘‘provision for loan and lease losses’’ or
the ‘‘allowance for loan and lease
losses,’’ as applicable.
Schedule RI (FFIEC 031, FFIEC 041, and
FFIEC 051)
To address the broader scope of
financial assets for which provisions
will be calculated under ASU 2016–13,
the agencies propose to revise Schedule
RI, item 4, from ‘‘Provision for loan and
lease losses’’ to ‘‘Provisions for credit
losses on financial assets,’’ effective
March 31, 2021. To address the
elimination of the concept of OTTI by
ASU 2016–13, effective December 31,
2022, the agencies propose to remove
Schedule RI, Memorandum item 14,
‘‘Other-than-temporary impairment
losses on held-to-maturity and
available-for-sale debt securities
recognized in earnings.’’ Under the new
standard, institutions will recognize
credit losses on HTM and AFS debt
securities through an allowance for
credit losses, and the agencies propose
to collect information on the allowance
for credit losses on these two categories
of debt securities in Schedule RI–B as
described below. From March 31, 2019,
through September 30, 2022, the
reporting form and instructions for
Memorandum item 14 will include
guidance stating that Memorandum item
14 is to be completed only by
institutions that have not adopted ASU
2016–13.
Schedule RI–B (FFIEC 031, FFIEC 041,
and FFIEC 051)
To address the broader scope of
financial assets for which allowances
will be calculated under ASU 2016–13
and for which charge-offs and recoveries
will be applicable, the agencies propose
to change the title of Schedule RI–B
effective March 31, 2019, from ‘‘Chargeoffs and Recoveries on Loans and Leases
and Changes in Allowance for Loan and
Lease Losses’’ to ‘‘Charge-offs and
Recoveries on Loans and Leases and
Changes in Allowances for Credit
Losses.’’
In addition, for the FFIEC 031 and
FFIEC 041 only, effective March 31,

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2021, to address the change in
allowance nomenclature arising from
the broader scope of allowances under
ASU 2016–13, the agencies propose to
revise Schedule RI–B, Part I,
Memorandum item 4, from
‘‘Uncollectible retail credit card fees and
finance charges reversed against income
(i.e., not included in charge-offs against
the allowance for loan and lease losses)’’
to ‘‘Uncollectible retail credit card fees
and finance charges reversed against
income (i.e., not included in charge-offs
against the allowance for credit losses
on loans and leases).’’
To further address the broader scope
of financial assets for which allowances
will be calculated under ASU 2016–13,
the agencies propose to revise Schedule
RI–B, Part II, to also include changes in
the allowances for credit losses on HTM
and AFS debt securities. Effective
March 31, 2019, the agencies propose to
change the title of Schedule RI–B, Part
II, from ‘‘Changes in Allowance for Loan
and Lease Losses’’ to ‘‘Changes in
Allowances for Credit Losses.’’
In addition, effective March 31, 2019,
Schedule RI–B, Part II, would be
expanded from one column to a table
with three columns titled:
—Column A: Loans and leases held for
investment
—Column B: Held-to-maturity debt
securities
—Column C: Available-for-sale debt
securities
From March 31, 2019, through
September 30, 2022, the reporting form
and instructions for Schedule RI–B, Part
II, would include guidance stating that
Columns B and C are to be completed
only by institutions that have adopted
ASU 2016–13.
In addition, effective March 31, 2019,
Schedule RI–B, Part II, item 4, will be
revised from ‘‘Less: Write-downs arising
from transfers of loans to a held-for-sale
account’’ to ‘‘Less: Write-downs arising
from transfers of financial assets’’ to
capture changes in allowances from
transfers of loans from held-toinvestment to held-for-sale and from
transfers of securities between
categories, e.g., from the AFS to the
HTM category. Further, effective March
31, 2019, Schedule RI–B, Part II, item 5,
will be revised from ‘‘Provision for loan
and lease losses’’ to ‘‘Provisions for
credit losses’’ to capture the broader
scope of financial assets included in the
schedule.
Effective March 31, 2019, or the first
quarter in which an institution reports
its adoption of ASU 2016–13, whichever
is later, Schedule RI–B, Part II, item 6,
‘‘Adjustments,’’ would be used to
capture the initial impact of applying

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ASU 2016–13 as of the effective date in
the period of adoption, including the
initial allowance gross-up for PCD assets
as of the effective date. Item 6 also
would be used to report the allowance
gross-up upon the acquisition of PCD
assets on or after the effective date.
These adjustments would be explained
in items for which preprinted captions
would be provided in place of the
existing text fields in Schedule RI–E,
items 6.a and 6.b, respectively, as
proposed below.
In the memorandum section of
Schedule RI–B, Part II, on the FFIEC 031
and the FFIEC 041, to address the
change in allowance nomenclature
arising from the broader scope of
allowances under ASU 2016–13, the
agencies propose to revise the caption
for Memorandum item 3, effective
March 31, 2021, from ‘‘Amount of
allowance for loan and lease losses
attributable to retail credit card fees and
finance charges’’ to ‘‘Amount of
allowance for credit losses on loans and
leases attributable to retail credit card
fees and finance charges.’’ Also in the
memorandum section of Schedule RI–B,
Part II, on the FFIEC 031 and the FFIEC
041, effective December 31, 2022, the
agencies propose to remove existing
Memorandum item 4, ‘‘Amount of
allowance for post-acquisition credit
losses on purchased credit impaired
loans accounted for in accordance with
FASB ASC 310–30,’’ as ASU 2016–13
eliminates the concept of PCI loans and
the separate credit impairment model
for such loans. From March 31, 2019,
through September 30, 2022, the
reporting form and instructions for
Schedule RI–B, Part II, Memorandum
item 4, would specify that this item
should be completed only by
institutions that have not yet adopted
ASU 2016–13.
Given that the scope of ASU 2016–13
is broader than the three financial asset
types proposed to be included in the
table in Schedule RI–B, Part II, effective
March 31, 2019, the agencies propose to
also add new Memorandum item 5,
‘‘Provisions for credit losses on other
financial assets measured at amortized
cost,’’ and Memorandum item 6,
‘‘Allowance for credit losses on other
financial assets measured at amortized
cost,’’ to Schedule RI–B, Part II, at the
same time. For purposes of
Memorandum items 5 and 6, other
financial assets would include all
financial assets measured at amortized
cost other than loans and leases held for
investment and held-to-maturity debt
securities. From March 31, 2019,
through September 30, 2022, the
reporting form and instructions for
Schedule RI–B, Part II, would include

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guidance stating that Memorandum
items 5 and 6 are to be completed only
by institutions that have adopted ASU
2016–13.
Schedule RI–C (FFIEC 031 and FFIEC
041)
Schedule RI–C currently requests
allowance information for specified
categories of loans held for investment
that is disaggregated on the basis of
three separate credit impairment
models, and the amounts of the related
recorded investment, from institutions
with $1 billion or more in total assets.
ASU 2016–13 eliminates these separate
credit impairment models and replaces
them with CECL for all financial assets
measured at amortized cost. As a result
of this change, effective March 31, 2021,
the agencies propose to change the title
of Schedule RI–C from ‘‘Disaggregated
Data on the Allowance for Loan and
Lease Losses’’ to ‘‘Disaggregated Data on
Allowances for Credit Losses.’’
To capture disaggregated data on
allowances for credit losses from
institutions that have adopted ASU
2016–13, the agencies propose to create
Schedule RI–C, Part II, ‘‘Disaggregated
Data on Allowances for Credit Losses,’’
effective March 31, 2019. The existing
table in Schedule RI–C, which includes
items 1 through 6 and columns A
through F, would be renamed ‘‘Part I.
Disaggregated Data on the Allowance for
Loan and Lease Losses.’’ From March
31, 2019, through September 30, 2022,
the reporting form and instructions for
Schedule RI–C, Part I, would include
guidance stating that only those
institutions that have not adopted ASU
2016–13 should complete Schedule RI–
C, Part I.
The proposed Part II of this schedule
would contain the same six loan
portfolio categories and the unallocated
category for which data are currently
collected in existing Schedule RI–C
along with the following portfolio
categories for which allowance
information would begin to be reported
for HTM debt securities:
1. Securities issued by states and
political subdivisions in the U.S.
2. Mortgage-backed securities (MBS)
(including CMOs, REMICs, and
stripped MBS)
a. Mortgage-backed securities issued
or guaranteed by U.S. Government
agencies or sponsored agencies
b. Other mortgage-backed securities
3. Asset-backed securities and
structured financial products
4. Other debt securities
5. Total
For each category of loans in Part II
of Schedule RI–C, institutions would

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report the amortized cost and the related
allowance balance in Columns A and B,
respectively. The amortized cost
amounts to be reported would exclude
any accrued interest receivable that is
reported in ‘‘Other assets’’ on the
balance sheet. For each category of HTM
debt securities in Part II of Schedule RI–
C, institutions would report only the
related allowance balance. The
amortized cost and allowance
information on loans and the allowance
information on HTM debt securities
would be reported quarterly only by
institutions with $1 billion or more in
total assets, as is currently done with
existing Part I of Schedule RI–C.
The agencies will use the securitiesrelated information gathered in
proposed Part II of the schedule to
monitor the allowance levels and
changes in these levels for the categories
of HTM debt securities specified above,
which would serve as a starting point
for assessing the appropriateness of
these levels. Further, with the proposed
removal of the Call Report item for OTTI
losses recognized in earnings (Schedule
RI, Memorandum item 14), proposed
Schedule RI–C, Part II, will become
another source of information regarding
credit losses on HTM debt securities, in
addition to data proposed to be reported
in Schedule RI–B, Part II. From March
31, 2019, through September 30, 2022,
the reporting form and instructions for
Schedule RI–C, Part II, would include
guidance stating that only those
institutions with $1 billion or more in
total assets that have adopted ASU
2016–13 should complete Schedule RI–
C, Part II.
In addition, effective December 31,
2022, the agencies propose to remove
the existing Schedule RI–C, Part I.
Schedule RI–C, Part II, would then be
the only table remaining within this
schedule and the ‘‘Part II’’ designation
would be removed.

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Schedule RI–D (FFIEC 031)
To address the broader scope of
financial assets for which provisions
will be calculated under ASU 2016–13,
effective March 31, 2021, the agencies
propose to revise Schedule RI–D, item 3,
from ‘‘Provision for loan and lease
losses in foreign offices’’ to ‘‘Provisions
for credit losses in foreign offices.’’
Schedule RI–E (FFIEC 031, FFIEC 041,
and FFIEC 051)
Institutions use item 4 of Schedule
RI–E to itemize and describe amounts
included in Schedule RI–A, item 2,
‘‘Cumulative effect of changes in
accounting principles and corrections of
material accounting errors.’’ Effective
March 31, 2019, the agencies propose to

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replace the existing text field for
Schedule RI–E, item 4.a, with a
preprinted caption that would be titled
‘‘Adoption of Current Expected Credit
Losses Methodology—ASC Topic 326.’’
Institutions will use this item to report
the cumulative-effect adjustment (net of
applicable income taxes) recognized in
retained earnings for the changes in the
allowances for credit losses on financial
assets and off-balance sheet credit
exposures as of the beginning of the
fiscal year in which the institution
adopts ASU 2016–13. Providing a
preprinted caption for this data item,
rather than allowing each institution to
enter its own description for this
cumulative-effect adjustment in the text
field for item 4.a, will enhance the
agencies’ ability to compare the impact
of the adoption of ASU 2016–13 across
institutions. From March 31, 2019,
through December 31, 2022, the
reporting form and instructions for
Schedule RI–E, item 4.a, would specify
that this item is to be completed only in
the quarter-end Call Reports for the
remainder of the calendar year in which
an institution adopts ASU 2016–13. The
agencies anticipate that the preprinted
caption for Schedule RI–E, item 4.a,
would be removed after all institutions
have adopted ASU 2016–13.
For Schedule RI–E, item 6, to address
the broader scope of financial assets for
which allowances will be maintained
under ASU 2016–13, effective March 31,
2019, the agencies propose to revise this
item from ‘‘Adjustments to allowance
for loan and lease losses’’ to
‘‘Adjustments to allowances for credit
losses.’’ In addition, effective March 31,
2019, the agencies propose to replace
the existing text field for Schedule
RI–E, item 6.a, with a preprinted
caption that would be titled ‘‘Initial
allowances for credit losses recognized
upon the acquisition of purchased
credit-deteriorated assets on or after the
effective date of ASU 2016–13.’’ Also,
effective March 31, 2019, the agencies
propose to replace the existing text field
for Schedule RI–E, item 6.b, with a
preprinted caption that would be titled
‘‘Effect of adoption of current expected
credit losses methodology on
allowances for credit losses on loans
and leases held for investment and heldto-maturity debt securities.’’ Item 6.b
would be used to capture the change in
the amount of allowances from initially
applying ASU 2016–13 to these two
categories of assets as of the effective
date of the accounting standard in the
period of adoption, including the initial
allowance gross-up for any PCD assets
held as of the effective date. From
March 31, 2019, through September 30,

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2022, the reporting form and
instructions for Schedule RI–E, items
6.a and 6.b, would specify that these
items are to be completed only by
institutions that have adopted ASU
2016–13. The instructions for item 6.b
would further state that this item is to
be completed only in the quarter-end
Call Reports for the remainder of the
calendar year in which an institution
adopts ASU 2016–13. The agencies
anticipate that the preprinted caption
for Schedule RI–E, item 6.b, would be
removed after all institutions have
adopted ASU 2016–13.
Schedule RC (FFIEC 031, FFIEC 041,
and FFIEC 051)
To address the broader scope of
financial assets for which allowances
will be estimated under ASU 2016–13,
the agencies propose revisions to the
reporting form and instructions to
specify which asset categories should be
reported net of an allowance for credit
losses on the Call Report balance sheet
and which asset categories should be
reported gross of such an allowance.
The agencies determined that the only
financial asset category for which
separate (i.e., gross) reporting of the
amortized cost 19 and the allowance is
needed on Schedule RC continues to be
item 4.b, ‘‘Loans and leases held for
investment,’’ because of the large size
and overall importance of this asset
category and its related allowances in
comparison to the total assets reported
on the balance sheet by most
institutions. For other financial assets
within the scope of CECL, the agencies
propose that institutions report these
assets at amortized cost 20 net of the
related allowance for credit losses on
Schedule RC.
Effective March 31, 2021, the agencies
propose to revise Schedule RC, item 2.a,
from ‘‘Held-to-maturity securities’’ to
‘‘Held-to-maturity securities, net of
allowance for credit losses.’’ From
March 31, 2019, through December 31,
2020, the agencies propose to add a
footnote to Schedule RC, item 2.a,
specifying that institutions should
‘‘report this amount net of any
applicable allowance for credit losses.’’
Additionally, for Schedule RC, item 3.b,
‘‘Securities purchased under agreements
to resell,’’ and Schedule RC, item 11,
‘‘Other assets,’’ effective March 31,
2019, the agencies propose to add a
footnote to these items specifying that
institutions should ‘‘report this amount
net of any applicable allowance for
19 Amortized cost amounts to be reported by asset
category would exclude any accrued interest
receivable on assets in that category that is reported
in ‘‘Other assets’’ on the Call Report balance sheet.
20 See footnote 19.

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credit losses.’’ From March 31, 2019,
through September 30, 2022, the
reporting form and instructions for
Schedule RC, items 2.a, 3.b, and 11,
would specify that reporting such items
net of any related allowances for credit
losses is applicable only to those
institutions that have adopted ASU
2016–13. Given that AFS debt securities
are reported on Schedule RC at fair
value, the agencies are not proposing
any changes to Schedule RC, item 2.b,
‘‘Available-for-sale securities,’’ and
instead propose reporting allowances
for credit losses on AFS debt securities
only in Schedule RI–B, Part II.
In addition, to address the change in
allowance nomenclature under ASU
2016–13, the agencies propose to revise
Schedule RC, item 4.c, from ‘‘LESS:
Allowance for loan and lease losses’’ to
‘‘LESS: Allowance for credit losses on
loans and leases’’ effective March 31,
2021.

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Schedule RC–B (FFIEC 031, FFIEC 041,
and FFIEC 051)
Effective March 31, 2019, the agencies
propose to revise the instructions to
Schedule RC–B to clarify that for
institutions that have adopted ASU
2016–13, allowances for credit losses
should not be deducted from the
amortized cost amounts reported in
columns A and C of this schedule.21 In
other words, institutions should
continue reporting the amortized cost of
HTM and AFS debt securities in these
two columns of Schedule RC–B gross of
their related allowances for credit
losses.
Schedule RC–C (FFIEC 031, FFIEC 041,
and FFIEC 051)
Effective March 31, 2021, to address
the change in allowance nomenclature,
the agencies propose to revise the
reporting form and instructions for
Schedule RC–C by replacing references
to the allowance for loan and lease
losses in statements indicating that the
allowance should not be deducted from
the loans and leases reported in this
schedule with references to the
allowance for credit losses. Thus, loans
and leases will continue to be reported
gross of any related allowances or
allocated transfer risk reserve in
Schedule RC–C, Part I.
In addition, to address the elimination
of PCI assets by ASU 2016–13, the
agencies propose to remove Schedule
RC–C, Part I, Memorandum items 7.a
and 7.b, in which institutions report the
21 Amortized cost amounts to be reported by
securities category in Schedule RC–B would
exclude any accrued interest receivable on the
securities in that category that is reported in ‘‘Other
assets’’ on the Call Report balance sheet.

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outstanding balance and balance sheet
amount, respectively, of PCI loans held
for investment effective December 31,
2022. The agencies determined that
these items were not needed after the
transition to PCD loans under ASU
2016–13 because the ASU eliminates
the separate credit impairment model
for PCI loans and applies CECL to all
loans held for investment measured at
amortized cost. From March 31, 2019,
through September 30, 2022, the
reporting form and instructions for
Schedule RC–C, Part I, Memorandum
items 7.a and 7.b, would specify that
these items should be completed only
by institutions that have not yet adopted
ASU 2016–13.
Additionally, since ASU 2016–13
supersedes ASC 310–30, the agencies
propose to revise Schedule RC–C, Part
I, Memorandum item 12, ‘‘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,’’
effective December 31, 2022. As revised,
the loans held for investment to be
reported in Memorandum item 12
would be those not considered
purchased credit deteriorated per ASC
326. From March 31, 2019, through
September 30, 2022, the agencies
propose to revise the reporting form and
instructions for Schedule RC–C, Part I,
by adding a statement explaining that,
subsequent to adoption of ASU 2016–
13, an institution should report only
loans held for investment not
considered purchased credit
deteriorated per ASC 326 in Schedule
RC–C, Part I, Memorandum item 12.
Schedule RC–F (FFIEC 031, FFIEC 041,
and FFIEC 051)
To address the broader scope of
financial assets for which allowances
will be applicable under ASU 2016–13,
the agencies propose to specify that
assets within the scope of the ASU that
are included in Schedule RC–F should
be reported net of any applicable
allowances for credit losses. Effective
March 31, 2019, the agencies propose to
revise the reporting form and the
instructions for Schedule RC–F by
adding a statement explaining that,
subsequent to adoption of ASU 2016–
13, an institution should report asset
amounts in Schedule RC–F net of any
applicable allowances for credit losses.
In addition, effective March 31, 2019,
the agencies propose to add a footnote
to item 1, ‘‘Accrued interest receivable,’’
on the reporting form and a statement to
the instructions for item 1 that specify
that institutions should exclude from

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this item any accrued interest receivable
that is reported elsewhere on the
balance sheet as part of the related
financial asset’s amortized cost.
Schedule RC–G (FFIEC 031, FFIEC 041,
and FFIEC 051)
To address ASU 2016–13’s exclusion
of off-balance sheet credit exposures
that are unconditionally cancellable
from the scope of off-balance sheet
credit exposures for which allowances
for credit losses should be measured,
the agencies propose to revise the
reporting form and instructions for
Schedule RC–G, item 3, ‘‘Allowance for
credit losses on off-balance-sheet credit
exposures,’’ effective March 31, 2019.
As revised, the reporting form and
instructions would state that
institutions that have adopted ASU
2016–13 should report in item 3 the
allowance for credit losses on those offbalance-sheet credit exposures that are
not unconditionally cancellable.
Schedule RC–H (FFIEC 031)
Effective March 31, 2019, the agencies
propose to revise the instructions to
Schedule RC–H to clarify that
institutions that have adopted ASU
2016–13 should report Schedule RC–H,
item 3, ‘‘Securities purchased under
agreements to resell,’’ at amortized cost
net of any related allowance for credit
losses, which would be consistent with
the proposed reporting of this asset
category in Schedule RC—Balance
Sheet. Also effective March 31, 2019,
the agencies propose to revise the
instructions to items 10 through 17 of
Schedule RC–H to clarify that, for
institutions that have adopted ASU
2016–13, allowances for credit losses
should not be deducted from the
amortized cost amounts reported for
HTM debt securities in column A.22
This proposed reporting treatment for
HTM debt securities is consistent with
proposed reporting of the cost amounts
of such securities in Schedule RC–B,
column A.
Schedule RC–K (FFIEC 031, FFIEC 041,
FFIEC 051)
Effective March 31, 2019, the agencies
propose to revise the instructions to
Schedule RC–K to clarify that, for
institutions that have adopted ASU
2016–13, allowances for credit losses
should not be deducted from the related
amortized cost amounts when
calculating the quarterly averages for all
debt securities.
22 Amortized cost amounts to be reported by
securities category in Schedule RC–H would
exclude any accrued interest receivable on the
securities in that category that is reported in ‘‘Other
assets’’ on the Call Report balance sheet.

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Schedule RC–N (FFIEC 031, FFIEC 041,
and FFIEC 051)
To address the elimination of PCI
assets by ASU 2016–13, the agencies
propose to remove Schedule RC–N,
Memorandum items 9.a and 9.b, in
which institutions report the
outstanding balance and balance sheet
amount, respectively, of past due and
nonaccrual PCI loans effective
December 31, 2022. The agencies
determined that these items were not
needed for PCD loans under ASU 2016–
13 given that the ASU eliminates the
separate credit impairment model for
PCI loans and applies CECL to PCD
loans and all other loans held for
investment measured at amortized cost.
From March 31, 2019, through
September 30, 2022, the reporting form
and the instructions for Schedule RC–N,
Memorandum items 9.a and 9.b, would
specify that these items should be
completed only by institutions that have
not yet adopted ASU 2016–13.

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Schedule RC–R (FFIEC 031, FFIEC 041,
and FFIEC 051)
In connection with the agencies’
recently issued proposed rule on the
implementation of CECL and the related
transition for regulatory capital (CECL
NPR),23 the agencies are proposing a
number of revisions to Schedule RC–R
to incorporate new terminology and the
proposed optional regulatory capital
transition. The proposed reporting
changes to Schedule RC–R are tied to
the revisions proposed in the CECL
NPR. To the extent the agencies revise
proposed elements of the CECL NPR
when issuing a final rule, the agencies
would make any necessary
corresponding adjustments to the
proposed Schedule RC–R reporting
revisions discussed in this notice and
describe these adjustments in their
required second Federal Register notice
for this proposal to revise the Call
Report and other FFIEC reports prior to
submitting the revised reports for OMB
review. Unless otherwise indicated, the
proposed revisions to Schedule RC–R
discussed below would take effect
March 31, 2019 (or the first quarter-end
report date thereafter following the
effective date on any final rule) and
would apply to those institutions that
have adopted CECL.
The CECL NPR would introduce a
newly defined regulatory capital term,
allowance for credit losses (ACL), which
would replace the term ALLL, as
defined under the existing capital rules,
for institutions that have adopted CECL.
The CECL NPR also proposes that credit
23 83

FR 22312 (May 14, 2018).

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loss allowances for PCD assets held by
these institutions would be netted when
determining the carrying value, as
defined in the CECL NPR, and,
therefore, only the resulting net amount
would be subject to risk-weighting. In
addition, under the CECL NPR, the
agencies are proposing to provide each
institution the option to phase in over
the three-year period beginning with the
institution’s CECL effective date the
day-one regulatory capital effects that
may result from the adoption of ASU
2016–13.24
Allowances for Credit Losses Definition
and Treatment of Purchased Credit
Deteriorated Assets
In general, under the CECL NPR,
institutions that have adopted CECL
would report ACL amounts in Schedule
RC–R items instead of ALLL amounts
that are currently reported. Effective
December 31, 2022, the agencies are
proposing to remove references to ALLL
and replace them with references to
ACL on the reporting form for Schedule
RC–R. From March 31, 2019, through
September 30, 2022, the agencies are
proposing to revise the instructions to
Schedule RC–R to direct institutions
that have adopted CECL to use ACL
amounts instead of ALLL amounts in
calculating regulatory capital. The
instructional revisions would affect
Schedule RC–R, Part I. Regulatory
Capital Components and Ratios, item 30
(FFIEC 051) and item 30.a (FFIEC 031
and 041), ‘‘Allowance for loan and lease
losses includable in tier 2 capital’’; and
Schedule RC–R, Part II. Risk-Weighted
Assets, item 6, ‘‘LESS: Allowance for
loan and lease losses’’; item 26, ‘‘Riskweighted assets base for purposes of
calculating the allowance for loan and
lease losses 1.25 percent threshold’’;
item 28, Risk-weighted assets before
deductions for excess allowance for loan
and lease losses and allocated transfer
risk reserve’’; and item 29, ‘‘LESS:
Excess allowance for loan and lease
losses’’.
In addition, under the CECL NPR,
assets and off-balance sheet credit
exposures for which any related credit
loss allowances are eligible for inclusion
24 A non-PBE with a calendar year fiscal year that
does not early adopt CECL would first report under
CECL as of December 31, 2021, even though the
non-PBE’s CECL effective date is January 1, 2021.
Thus, under the CECL NPR, such a non-PBE would
use the phase-in percentage applicable to the first
year of the three-year transition period only for the
December 31, 2021, report date (i.e., one quarter),
not the four quarters that begin with the first report
under CECL. The non-PBE may use the applicable
phase-in percentages for all four quarters of the
second and third years after the CECL effective date
(i.e., 2022 and 2023). The same principle would
apply to the optional phase-in by a non-PBE with
a non-calendar fiscal year.

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in regulatory capital would be
calculated and reported in Schedule
RC–R, Part II. Risk-Weighted Assets, on
a gross basis. Therefore, the agencies are
proposing to revise the instructions for
Schedule RC–R, Part II, Risk-Weighted
Assets, item 2.a, ‘‘Held-to-maturity
securities’’; item 3.b, ‘‘Securities
purchased under agreements to resell’’;
item 5.a, ‘‘Residential mortgage
exposures’’ held for investment; item
5.b, ‘‘High volatility commercial real
estate exposures’’ held for investment;
item 5.c, Held-for-investment
‘‘Exposures past due 90 days or more or
on nonaccrual’’; item 5.d, ‘‘All other
exposures’’ held for investment; item 8,
‘‘All other assets,’’ and item 9.a, ‘‘Onbalance sheet securitization exposures:
Held-to-maturity securities’’; to explain
that institutions that have adopted CECL
should report and risk weight their
loans and leases held for investment,
HTM securities, and other financial
assets measured at amortized cost gross
of their credit loss allowances, but net
of any associated allowances on PCD
assets.25
In addition, effective March 31, 2019,
the agencies propose to add a new
Memorandum item 4 to Schedule RC–R,
Part II, that would collect data by asset
category on the ‘‘Amount of allowances
for credit losses on purchased creditdeteriorated assets.’’ The amount of
such allowances for credit losses would
be reported separately for ‘‘Loans and
leases held for investment’’ in
Memorandum item 4.a, ‘‘Held-tomaturity debt securities’’ in
Memorandum item 4.b, and, ‘‘Other
financial assets measured at amortized
cost’’ in Memorandum item 4.c. The
instructions for Schedule RC–R, Part II,
Memorandum item 4, would specify
that these items should be completed
only by institutions that have adopted
ASU 2016–13.
The agencies also would include
footnotes for the affected Schedule RC–
R items on the reporting forms to
highlight the revised treatment of those
items for institutions that have adopted
CECL.
CECL Transition Provision
Under the CECL NPR, an institution
that experiences a reduction in retained
earnings as of the effective date of CECL
for the institution as a result of the
institution’s adoption of CECL may elect
to phase in the regulatory capital impact
of adopting CECL (electing institution).
As described in the CECL NPR, an
25 Amortized cost amounts to be reported by asset
category in Schedule RC–R, Part II, would exclude
any accrued interest receivable on assets in that
category that is reported in ‘‘Other assets’’ on the
Call Report balance sheet.

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electing institution would indicate in its
Call Report whether it has elected to use
the CECL transition provision beginning
in the quarter that it first reports its
credit loss allowances as measured
under CECL. To identify which
institutions are electing institutions, the
agencies are proposing to revise
Schedule RC–R, Part I. Regulatory
Capital Components and Ratios, by
adding a new item 2.a in which an
institution that has adopted CECL
would report whether it has or does not
have a CECL transition election in effect
as of the quarter-end report date. Each
institution would complete item 2.a
beginning in the Call Report for its first
reporting period under CECL and in
each subsequent Call Report thereafter
until item 2.a is removed from the
report. Until an institution has adopted
CECL, it would leave item 2.a blank.
Effective March 31, 2025, the agencies
propose to remove item 2.a from
Schedule RC–R, Part I, because the
optional three-year phase-in period will
have ended for all electing institutions
by the end of the prior calendar year. If
an individual electing institution’s
three-year phase-in period ends before
item 2.a is removed (e.g., its phase-in
period ends December 31, 2022), the
institution would change its response to
item 2.a and report that it does not have
a CECL transition election in effect as of
the quarter-end report date.
During the CECL transition period, an
electing institution would need to make
adjustments to its retained earnings,
temporary difference deferred tax assets
(DTAs), ACL, and average total
consolidated assets for regulatory
capital purposes. An advanced
approaches electing institution also
would need to make an adjustment to its
total leverage exposure. These
adjustments are described in detail in
the CECL NPR.
The agencies are proposing to revise
the instructions to Schedule RC–R, Part
I. Regulatory Capital Components and
Ratios, item 2, ‘‘Retained earnings’’;
items 30 (FFIEC 051) and 30.a (FFIEC
031 and 041), ‘‘Allowance for loan and
lease losses includable in tier 2 capital’’;
item 36, ‘‘Average total consolidated
assets’’; and item 45.a (FFIEC 031 and
041), ‘‘Total leverage exposure’’; and
Schedule RC–R, Part II. Risk-Weighted
Assets, item 8, ‘‘All other assets,’’
consistent with the adjustments to these
items for the applicable transitional
amounts as described in the CECL NPR
for the reporting by electing institutions
of the adjusted amounts. The agencies
also propose to include footnotes on the
reporting forms to highlight the changes
to these items for electing institutions.

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Schedule RC–V (FFIEC 031 and FFIEC
041)
The agencies propose to clarify in the
instructions effective March 31, 2019,
that all assets of consolidated variable
interest entities should be reported net
of applicable allowances for credit
losses by institutions that have adopted
ASU 2016–13. Net reporting on
Schedule RC–V by such institutions is
consistent with the proposed changes to
Schedules RC and RC–F. Similarly,
effective March 31, 2019, the reporting
form for Schedule RC–V will also
specify that institutions that have
adopted ASU 2016–13 should report
assets net of applicable allowances.
Schedule SU (FFIEC 051)
To address the change in allowance
nomenclature arising from the broader
scope of allowances under ASU 2016–
13, the agencies propose to revise
Schedule SU, item 8.c, effective March
31, 2021, from ‘‘Amount of allowance
for loan and lease losses attributable to
retail credit card fees and finance
charges’’ to ‘‘Amount of allowance for
credit losses on loans and leases
attributable to retail credit card fees and
finance charges.’’
2. EGRRCPA Proposed Call Report
Revisions
As mentioned above in Section B of
‘‘Supplementary Information, I.
Background,’’ Sections 202 and 214 of
EGRRCPA on reciprocal deposits and
HVCRE ADC loans, respectively, were
effective upon enactment on May 24,
2018, and affect the reporting of
information in the Call Reports effective
beginning with the June 30, 2018, report
date. To assist institutions in preparing
their Call Reports for that report date,
the Call Report Supplemental
Instructions for June 2018 included
information regarding the reporting of
HVCRE exposures and reciprocal
deposits.
In amending Section 29 of the FDI Act
to except a capped amount of reciprocal
deposits from treatment as brokered
deposits for qualifying institutions,
Section 202 defines ‘‘reciprocal
deposits’’ to mean ‘‘deposits received by
an agent institution through a deposit
placement network with the same
maturity (if any) and in the same
aggregate amount as covered deposits
placed by the agent institution in other
network member banks.’’ The terms
‘‘agent institution,’’ ‘‘deposit placement
network,’’ ‘‘covered deposit,’’ and
‘‘network member bank,’’ all of which
are used in the definition of ‘‘reciprocal
deposit,’’ also are defined in Section
202.

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In particular, an ‘‘agent institution’’ is
an FDIC-insured depository institution
that meets at least one of the following
criteria:
• The institution is well-capitalized
and has a composite condition of
‘‘outstanding’’ or ‘‘good’’ when most
recently examined under section 10(d)
of the FDI Act (12 U.S.C. 1820(d));
• The institution has obtained a
waiver from the FDIC to accept, renew,
or roll over brokered deposits pursuant
to section 29(c) of the FDI Act (12 U.S.C.
1831f(c)); or
• The institution does not receive
reciprocal deposits in an amount that is
greater than a ‘‘special cap’’ (discussed
below).
Under the ‘‘general cap’’ set forth in
Section 202, an agent institution may
classify reciprocal deposits up to the
lesser of the following amounts as nonbrokered reciprocal deposits:
• $5 billion, or
• An amount equal to 20 percent of
the agent institution’s total liabilities.
Any amount of reciprocal deposits in
excess of the ‘‘general cap’’ would be
treated as, and should be reported in the
Call Report as, brokered deposits.
A ‘‘special cap’’ applies if an agent
institution is either not ‘‘well-rated’’ or
not well capitalized. In this situation,
the institution may classify reciprocal
deposits as non-brokered in an amount
up to the lesser of the ‘‘general cap’’ or
the average amount of reciprocal
deposits held by the agent institution on
the last day of each of the four calendar
quarters preceding the calendar quarter
in which the agent institution was
found to not have a composite condition
of ‘‘outstanding’’ or ‘‘good’’ or was
determined to be not well capitalized.
Section 51 of the FDI Act, as added by
Section 214 of EGRRCPA, governs the
risk-based capital requirements for
HVCRE ADC Loans and defines this
term. Under Section 214, the assignment
of a heightened risk weight to HVCRE
exposures may be required only if the
exposure meets the statutory definition
of an HVCRE ADC Loan.
The revisions discussed in this
section have already been submitted to
OMB under the emergency review
process, and OMB has approved these
changes. However, the agencies are
requesting comment on whether there
should be any further changes for these
items or revisions to the items or
instructions developed by the agencies.
Schedule RC–E (FFIEC 031, FFIEC 041,
and FFIEC 051)
To address the change in the
treatment of certain reciprocal deposits
under Section 202 of EGRRCPA in the
Call Report, the agencies, through the

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issuance of Call Report Supplemental
Instructions for June 2018, explained
how institutions could report certain
data on brokered deposits in accordance
with EGRRCPA or based on the
reporting instructions in effect prior to
passage of EGRRCPA. The agencies
explained that institutions that chose to
report based on the new law should
include in Memorandum items 1.b
through 1.d only those reciprocal
deposits that are still considered
brokered deposits under Section 202.
The agencies plan to reissue these
Supplemental Instructions for
September 2018. Revised instructions
for Memorandum item 1.b will be
incorporated into the Call Report
instruction books at a future date.
In addition, the agencies plan to add
a new Memorandum item 1.g to
Schedule RC–E in which institutions
would report their ‘‘Total reciprocal
deposits’’ (as of the report date) in
accordance with the definition of this
term in Section 202, starting with the
September 30, 2018, Call Report. The
new Memorandum item 1.g of Schedule
RC–E would be used in determining an
institution’s ‘‘special cap’’ if the
institution were found to not have a
composite condition of ‘‘outstanding’’ or
‘‘good’’ or was determined not to be
well capitalized. The measurement of an
institution’s ‘‘special cap’’ would be the
average of reciprocal deposits held on
the last day of each of the four calendar
quarters preceding the calendar quarter
in which the institution was found to
not have a composite condition of
‘‘outstanding’’ or ‘‘good’’ or was
determined not to be well capitalized.
From a supervisory perspective, a
funding concentration could arise if a
significant amount of an institution’s
deposits comes from reciprocal deposits
obtained through a single deposit
placement network, regardless of
whether the reciprocal deposits are
treated as brokered under Section 202.
Examiners review funding
concentrations on an institution-byinstitution basis. The Memorandum
item for ‘‘Total reciprocal deposits’’
would enable the agencies to identify
significant changes in the reported
amounts of such deposits at institutions
for appropriate supervisory follow-up.
Schedule RC–O (FFIEC 031, FFIEC 041,
and FFIEC 051)
To address the change in the
treatment of certain reciprocal deposits
under Section 202 of EGRRCPA, the
agencies, through the Supplemental
Instructions for June 2018, explained
that institutions that chose to report
based on the new law should include in
items 9, ‘‘Reciprocal brokered deposits,’’

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and 9.a, ‘‘Fully consolidated reciprocal
brokered deposits,’’ only those
reciprocal deposits that are still
considered brokered deposits after
application of Section 202 of the new
law. The agencies plan to reissue these
Supplemental Instructions for
September 2018. Revised instructions
for items 9 and 9.a will be incorporated
into the Call Report instruction books at
a future date.
Schedule RC–R (FFIEC 031, FFIEC 041,
and FFIEC 051)
To address the EGRRCPA change that
applies to the reporting of HVCRE
exposures for risk-based capital
purposes, the agencies revised the
instructions to Schedule RC–R, Part II,
through the Call Report Supplemental
Instructions for June 2018. The revised
instructions explain that, pending
further action by the agencies, when
reporting HVCRE exposures in Schedule
RC–R, Part II, institutions may use
available information to reasonably
estimate and report only ‘‘HVCRE ADC
Loans’’ held for sale, held for
investment, and held for trading in
Schedule RC–R, Part II, items 4.b, 5.b
and 7, respectively. The portion of any
‘‘HVCRE ADC Loan’’ that is secured by
collateral or has a guarantee that
qualifies for a risk weight lower than
150 percent may continue to be assigned
a lower risk weight when completing
Schedule RC–R, Part II. Pending further
agency action, institutions may refine
their estimates of ‘‘HVCRE ADC Loans’’
in good faith as they obtain additional
information, but they will not be
required to amend Call Reports
previously filed for report dates on or
after June 30, 2018, as these estimates
are adjusted. Alternatively, institutions
may continue to report and risk weight
HVCRE exposures in a manner
consistent with the current Call Report
instructions for Schedule RC–R, Part II,
until the agencies take further action.
The agencies will incorporate the
instructions for these items, currently in
the Supplemental Instructions for June
2018, into the Call Report instruction
books at a future date.
III. FFIEC 002/002S Revisions
FFIEC 002 Schedule M—Due From/
Due to Related Institutions in the U.S.
and in Foreign Countries
At present, a reporting U.S. branch or
agency of a foreign bank is not required
to, but may choose to, establish a
general allowance for loan losses, which
it would report in its FFIEC 002 report
in Schedule M, Part IV, item 1,
‘‘Amount of allowance for loan losses, if
any, carried on the books of the

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reporting branch or agency including its
IBF.’’ In addition, any general allowance
for loan losses is reported in Schedule
M, Part I, item 2(a), column B, as part
of the ‘‘Gross due to’’ the ‘‘Head office
of parent bank,’’ as well as in either
Schedule RAL, item 2(a), ‘‘Net due from
related depository institutions,’’ or item
5(a), Net due to related depository
institutions,’’ as applicable. The
institution would report the total
amount of the allowance carried on the
books of the reporting institution, even
if part of that allowance is applicable to
other branches.
To address the change in allowance
nomenclature arising from the broader
scope of allowances under ASU 2016–
13, the agencies propose to revise
Schedule M, Part IV, item 1, from
‘‘Amount of allowance for loan losses’’
to ‘‘Allowance for credit losses on loans
and leases,’’ effective March 31, 2021.
For the period from March 31, 2019,
through December 31, 2020, the
reporting form and instructions for this
data item would include guidance
stating that institutions that have
adopted ASU 2016–13 would report the
‘‘allowance for credit losses on loans
and leases,’’ as applicable. For the
transition period from March 31, 2021,
through December 31, 2022, the
reporting form and instructions for this
data item would be updated to include
guidance stating that institutions that
have not adopted ASU 2016–13 would
report the amount of the ‘‘allowance for
loan losses,’’ as applicable. In addition,
for these same time periods, the
agencies propose to revise the
instructions for Schedule M, Part I, item
2(a), column B, as well as Schedule
RAL, items 2(a) and 5(a), to incorporate
language clarifying that institutions
should include any allowance for loan
losses or any allowances for credit
losses in these items, as applicable. If an
institution chooses to establish them,
the allowances for credit losses
reportable in item 2(a) or 5(a), as
applicable, could apply to loans, leases,
other financial assets measured at
amortized cost, and off-balance sheet
credit exposures (but not available-forsale securities, which are reported at fair
value on Schedule RAL).
Finally, effective March 31, 2019, the
agencies propose to add a statement to
the instructions for Schedule RAL, item
1(h), ‘‘Other assets (including other
claims on nonrelated parties,’’ that
specifies that institutions that have
adopted ASU 2016–13 should exclude
from this item any accrued interest
receivable that is reported elsewhere on
the balance sheet as part of the related
financial asset’s amortized cost.

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FFIEC 002S
The General Instructions for the
FFIEC 002S state that due from/due to
relationships with related institutions
(both depository and nondepository) are
to be reported on a gross basis and that
such relationships include all claims
between the foreign branch and any
related institutions (whether depository
or nondepository) arising in connection
with any accounting or regulatory
allocations entered on the books of the
reporting foreign branch that ultimately
affect unremitted profits. As an example
of such allocations, the General
Instructions cite the ‘‘allowance for
possible loan losses.’’ In addition, the
instructions for item 2(c), ‘‘Loans,’’
states that loans (and leases) should be
reported before deduction of any
allowance for loan losses. To address
the change in allowance nomenclature
arising from the broader scope of
allowances under ASU 2016–13, the
agencies propose to revise the FFIEC
002S General Instructions and item 2(c)
instructions to change the ‘‘allowance
for loan losses’’ terminology to
‘‘allowances for credit losses’’ and
‘‘allowances for credit losses on loans
and leases,’’ respectively, effective
March 31, 2021. Allowances for credit
losses could apply to loans, leases, other
financial assets measured at amortized
cost, and off-balance sheet credit
exposures (but not available-for-sale
securities). For the period from March
31, 2019, through December 31, 2020,
the General Instructions for reporting
due from/due to relationships would
include guidance stating that
institutions that have adopted ASU
2016–13 should interpret the
‘‘allowance for loan losses’’ as
‘‘allowances for credit losses,’’ as
applicable. For the transition period
from March 31, 2021, through December
31, 2022, these General Instructions
would include guidance stating that
institutions that have not adopted ASU
2016–13 should interpret ‘‘allowances
for credit losses’’ as the ‘‘allowance for
loan losses,’’ as applicable. Comparable
changes would be made to the
instructions for item 2(c) for these
periods.

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V. FFIEC 030/030S Revisions
FFIEC 030 Assets
All asset categories on the FFIEC 030
report are reported gross of any related
allowances. Allowances for credit
losses, including loan and lease losses,
are reported in line item 16, ‘‘Gross due
to head office, U.S. branches, and other
foreign branches of this bank.’’
Currently, however, the instructions for
line item 8, ‘‘Gross due from head office,

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U.S. branches, and other foreign
branches of this bank,’’ also state that
institutions should report any allowance
for loan and lease losses and other
valuation allowances in this line item.
Effective March 31, 2019, the agencies
propose to remove this language from
the line item 8 instructions since the
allowance for loan and lease losses and
other valuation allowances are reported
in line item 16. Additionally, the
agencies propose to add a statement to
the instructions for balance sheet item
10, ‘‘Other assets,’’ that specifies that
institutions that have adopted ASU
2016–13 should exclude from this item
any accrued interest receivable that is
reported elsewhere on the balance sheet
as part of the related financial asset’s
amortized cost.
FFIEC 030

Liabilities

The gross due to amounts reported in
Liabilities item 16, ‘‘Gross due to head
office, U.S. branches, and other foreign
branches of this bank,’’ include any
allowance for loan and lease losses on
the books of the reporting branch. To
address the change in allowance
nomenclature arising from the broader
scope of allowances under ASU 2016–
13, effective March 31, 2019, the
agencies propose to revise the reporting
instructions for Liabilities item 16, to
change ‘‘any allowance for loan and
lease losses’’ to ‘‘any allowances for
credit losses.’’ From March 31, 2019,
through September 30, 2022, the
instructions for item 16 would specify
that institutions that have not adopted
ASU 2016–13 should continue to
include the allowance for loan and lease
losses in this item.
FFIEC 030S

Financial Data

Branches that file the FFIEC 030S
report their ‘‘Gross due to related
institutions’’ in item 3. The instructions
for item 3 state that this item
corresponds to FFIEC 030 Liabilities
items 16 and 17.26 Thus, the effect of the
proposed revisions to the instructions
for FFIEC 030 Liabilities item 16,
described above, will carry over to
FFIEC 030S item 3.
VI. FFIEC 101 Revisions
The proposed changes in the CECL
NPR would revise the capital rules
applicable to an advanced approaches
institution 27 that has completed the
26 Liabilities item 17 is used to report a branch’s
‘‘Gross due to consolidated subsidiaries of this
bank.’’
27 An institution is an advanced approaches
institution if it has consolidated assets of at least
$250 billion or if it has consolidated on-balance
sheet foreign exposures of at least $10 billion, or if
it is a subsidiary of a depository institution, bank

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parallel run process 28 by aligning the
definition of eligible credit reserves
(ECR) with the definition of ACL. In
addition, as described in the CECL NPR,
an advanced approaches institution may
elect to phase in the impact of CECL by
adjusting ECR, which could affect the
reporting of certain items in the FFIEC
101.
To reflect the proposed changes in the
CECL NPR and in the optional CECL
transition provision, the agencies are
proposing to revise the instructions to
FFIEC 101, Schedule A—Advanced
Approaches Regulatory Capital, item 50,
‘‘Eligible credit reserves includable in
tier 2 capital’’; item 76, ‘‘Total
allowance for loan and lease losses
(ALLL) under the standardized
approach’’; and item 77, ‘‘Amount of
ALLL includable in tier 2 capital under
the standardized approach,’’ effective
March 31, 2019, for advanced
approaches institutions that have
adopted CECL. The proposed revisions
to these instructions would incorporate
the new definitions in the CECL NPR, as
well as the mechanics of the CECL
transition provision for electing
advanced approaches institutions that
have adopted CECL. The agencies also
would include footnotes on the forms to
highlight these items for these advanced
approaches institutions.
In addition, the definition of HVCRE
ADC Loan in Section 214 of EGRRCPA
that applies to the reporting of such
exposures held for sale, held for
investment, and held for trading in
Schedule RC–R, Part II, of the Call
Report also impacts the reporting of
information in the FFIEC 101 on HVCRE
exposures in Schedule B, item 5, and
Schedule G—High Volatility
Commercial Real Estate.29 The agencies
have received OMB approval to revise
the instructions to these schedules to
allow institutions to report commercial
holding company, savings and loan holding
company, or intermediate holding company that is
an advanced approaches institution. An institution
that elects to use the advanced approaches to
calculate its total risk-weighted assets also is an
advanced approaches institution. See 12 CFR 3.100
(OCC); 12 CFR 217.100 (Board); 12 CFR 324.100
(FDIC).
28 An advanced approaches institution is
considered to have completed the parallel run
process once it has completed the advanced
approaches qualification process and received
notification from its primary federal regulator
pursuant to section 121(d) of subpart E of the
capital rules. See 12 CFR 3.121(d) (OCC); 12 CFR
217.121(d) (Board); 12 CFR 324.121(d) (FDIC).
29 To assist advanced approaches institutions in
preparing their FFIEC 101 reports for the June 30,
2018, report date, the FFIEC sent a letter to these
institutions providing instructions regarding the
reporting of HVCRE exposures in the FFIEC 101 as
of that date. Guidance from this letter will be
incorporated into the FFIEC 101 Instructions at a
future date.

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real estate exposures that meet the
statutory definition of ‘‘HVCRE ADC
Loan’’ in Section 214 of this new law.
Therefore, to address the EGRRCPA
change that applies to the reporting of
HVCRE exposures in the FFIEC 101, the
agencies revised the instructions for the
FFIEC 101 to allow an advanced
approaches institution to estimate and
report HVCRE exposures on Schedules
B and G of the FFIEC 101 using the
definition under Section 214 of the new
law. Pending further agency action,
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.

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VII. Request for Comment
Public comment is requested on all
aspects of this joint notice. Comment is
specifically invited on:
(a) In Call Report Schedule RI, Income
Statement, whether institutions should
continue reporting the provision for
credit losses on off-balance sheet credit
exposures in item 7.d, ‘‘Other
noninterest expense,’’ or whether
institutions should report this expense
as part of proposed item 4, ‘‘Provisions
for credit losses on financial assets’’;
(b) In Call Report Schedule RI–C, Part
II, Disaggregated Data on Allowances for
Credit Losses, whether the agencies
should retain item 5 for reporting
unallocated allowances for loans and
leases, as proposed, or whether ASU
2016–13 is viewed as eliminating the
potential for unallocated allowances
considering the accounting standard

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requires allowances to be estimated at a
pool level when similar risk
characteristics exist and at an individual
asset level when similar risk
characteristics do not exist;
(c) For proposed Schedule RI–C, Part
II, whether the general categories of debt
securities for which data are proposed
to be collected are at the appropriate
level of granularity or whether
alternative categories should be used
and, if so, what these categories should
be;
(d) Also for proposed Schedule RI–C,
Part II, whether the proposed annual
reporting frequency for the
disaggregation of data on the allowances
for credit losses on HTM debt securities
and AFS debt securities is appropriate
or whether more frequent reporting of
these data would be more appropriate
and, if so, what the reporting frequency
should be;
(e) Whether, after an institution
adopts ASU 2016–13, all accrued
interest receivable currently reported in
‘‘Other assets’’ should be reported as
part of the balance sheet amount of the
related financial asset, consistent with
the definition of amortized cost in the
ASU;
(f) Whether the agencies should
consider according confidential
treatment to Schedule RC–O, items 9
and 9.a, on reciprocal brokered deposits,
and Schedule RC–E, Memorandum
items 1.b through 1.d, on brokered
deposits, because amounts an
institution reports in these items in
relation to the amount reported in
proposed Schedule RC–E, Memorandum
item 1.g, ‘‘Total reciprocal deposits,’’
and changes in these reported amounts
over time, may enable users of Call
Report data to make inferences about
the institution’s composite rating under
the Uniform Financial Institutions

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Rating System, which is confidential
supervisory information;
(g) Whether the proposed revisions to
the collections of information that are
the subject of this notice are necessary
for the proper performance of the
agencies’ functions, including whether
the information has practical utility;
(h) The accuracy of the agencies’
estimates of the burden of the
information collections as they are
proposed to be revised, including the
validity of the methodology and
assumptions used;
(i) Ways to enhance the quality,
utility, and clarity of the information to
be collected;
(j) Ways to minimize the burden of
information collections on respondents,
including through the use of automated
collection techniques or other forms of
information technology; and
(k) Estimates of capital or start-up
costs and costs of operation,
maintenance, and purchase of services
to provide information.
Comments submitted in response to
this joint notice will be shared among
the agencies. All comments will become
a matter of public record.
Dated: September 20, 2018.
Theodore J. Dowd,
Deputy Chief Counsel, Office of the
Comptroller of the Currency.
Board of Governors of the Federal Reserve
System, September 21, 2018.
Ann Misback,
Secretary of the Board.
Dated at Washington, DC, on September
20, 2018.
Federal Deposit Insurance Corporation.
Valerie Best,
Assistant Executive Secretary.
[FR Doc. 2018–21105 Filed 9–27–18; 8:45 am]
BILLING CODE 4810–33–P; 6210–01–P; 6714–01–P

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