FFIEC031_FFIEC041_FFIEC051_20190214_omb

Supporting Statement for the
Consolidated Reports of Condition and Income
(FFIEC 031, FFIEC 041, and FFIEC 051; OMB No. 7100-0036)
Summary
The Board of Governors of the Federal Reserve System (Board) requests approval from
the Office of Management and Budget (OMB) to extend for three years, with revision, the
Federal Financial Institutions Examination Council (FFIEC) Consolidated Reports of Condition
and Income (Call Reports) (FFIEC 031, FFIEC 041, and FFIEC 051; OMB No. 7100-0036).
With respect to the Board, these reports are required of state member banks and are filed on a
quarterly basis. The revisions to the Call Reports that are the subject of this request have been
approved by the FFIEC.
The Board uses the information collected on the Call Reports to fulfill its statutory
obligation to supervise state member banks. State member banks are required to file detailed
schedules of assets, liabilities, and capital accounts in the form of a condition report and
summary statement as well as detailed schedules of operating income and expense, sources and
disposition of income, and changes in equity capital.
The Board, Federal Deposit Insurance Corporation (FDIC) and Office of the Comptroller
of the Currency (OCC) (together, the agencies) are jointly revising the Call Reports for
depository institutions under their supervision, subject to approval by OMB.1 The changes
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 regulatory capital reporting changes
related to implementing the agencies’ recent final rule on the implementation and capital
transition for the current expected credit losses methodology (CECL). In addition, this proposal
includes other revisions to the Call Reports resulting from two sections of the Economic Growth,
Regulatory Relief, and Consumer Protection Act (EGRRCPA) that were effective upon
enactment on May 24, 2018, and were effective for the June 30, 2018, report date. These items
affect the information reported in the Call Reports and for which the agencies submitted
emergency review requests to OMB that OMB approved. The proposed revisions related to
ASU 2016-13 would begin to take effect March 31, 2019, with later effective dates for certain
respondents.
The agencies previously sought public comment on this proposal, and received comments
from two entities. In response to these comments, the agencies made minor alterations to the
initial proposal, as described below. The current annual burden for the Call Reports is estimated
to be 159,200 hours and the proposed revisions are estimated to increase the annual burden by
350 hours.

1

The FDIC and OCC have separately submitted a similar request for OMB review to request this information from
banks under their supervision.

Background and Justification
State banks that are members of the Federal Reserve System are required by section 9(6)
of the Federal Reserve Act (12 U.S.C. 324) to file reports of condition with the Board. The
Board, acting in concert with the other federal banking supervisory agencies through the FFIEC
since 1979, requires state member banks to submit on the quarterly Call Reports such financial
data as are needed by the Federal Reserve System to supervise and regulate banks through
monitoring of their financial condition, ensuring the continued safety of the public’s monies and
the overall soundness of the nation’s financial structure, and for the proper discharge of the
Federal Reserve’s monetary policy responsibilities. The data, which generally is made publicly
available by the agencies, is used not only by the federal government, but also by state and local
governments, the banking industry, securities analysts, and the academic community.
Description of Information Collection
The Call Reports, which consist of the Reports of Condition and Income, collect basic
financial data from commercial banks in the form of a balance sheet, income statement, and
supporting schedules. The Report of Condition contains supporting schedules that provide detail
on assets, liabilities, and capital accounts. The Report of Income contains supporting schedules
that provide detail on income and expenses.
Within the Call Report information collection system as a whole, there are three reporting
forms that apply to different categories of state member banks: (1) banks that have foreign
offices or that have total consolidated assets of $100 billion or more (FFIEC 031), (2) banks with
domestic offices only and total consolidated assets of less than $100 billion but more than
$1 billion (FFIEC 041), and (3) banks with domestic offices only and total assets less than
$1 billion (FFIEC 051).2
There is no other series of reporting forms that collect this information from all
commercial and savings banks. Although there are other information collections that are similar
to certain items on the Call Reports, the information they collect would be of limited value as a
replacement for the Call Reports. For example, the Board collects various data in connection
with its measurement of monetary aggregates, bank credit, and flow of funds. Reporting banks
supply the Board with detailed information relating to balance sheet accounts such as balances
due from depository institutions, loans, and deposit liabilities. These collections of information,
however, are frequently obtained on a sample basis rather than from all insured banks.
Moreover, these reports are often prepared as of dates other than the last business day of each
quarter, which would seriously limit their comparability. Additionally, institutions below a
certain size are exempt entirely from some Board reporting requirements.

2

Prior to March 2001, there were four categories of banks and four reporting forms. The FFIEC 031 was filed by
banks with domestic and foreign offices and the FFIEC 032, FFIEC 033, and FFIEC 034 were filed by banks with
domestic offices only according to the asset size of the bank. Between March 2001 and March 2017, there were two
categories of banks and two reporting forms. The FFIEC 031 was filed by banks with domestic and foreign offices
and the (2) the FFIEC 041 was filed by banks with domestic offices only.

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The Board also collects financial data from bank holding companies on a regular basis.
Such data frequently are presented for the holding company on a consolidated basis, including its
banking and nonbanking subsidiaries, and on a parent-company-only basis. Data collected from
bank holding companies on a consolidated basis reflect aggregate amounts for all subsidiaries
within the organization, including banking and nonbanking subsidiaries, so that the actual dollar
amounts applicable to any banking subsidiary would not be determinable from the holding
company reporting information. Hence, these reporting forms are not a viable replacement for
even a significant portion of the Call Reports since the Board, in its role as supervisor of insured
state member banks, would lack the data necessary to assess the financial condition of individual
banks to determine whether there had been any deterioration in their condition.
Banks are required to transmit their Call Report data electronically. Banks do not have to
submit hard copy Call Reports to any federal bank supervisory agency unless specifically
requested to do so.
Proposed Revisions
General Discussion of Proposed Call Report Revisions
ASU 2016-13, “Financial Instruments - Credit Losses (Topic 326): Measurement of
Credit Losses on Financial Instruments”
Banks are generally required to follow U.S. generally accepted accounting principles
(U.S. GAAP) when completing the Call Reports.3 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. 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 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
3

See 12 USC 1831n(a) (stating that the accounting principles applicable to reports required to be filed with federal
banking agencies shall be uniform and consistent with generally accepted accounting principles).

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impairment models for different financial assets.4 In contrast, CECL introduces a single
measurement objective to be applied to all financial assets measured at amortized cost, including
loans held-for-investment (HFI) and held-to-maturity (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
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 writedown 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.
4

Current U.S. GAAP includes five different credit impairment models for instruments within the scope of CECL:
ASC Subtopic 310-10, Receivables-Overall; ASC Subtopic 450-20, Contingencies-Loss Contingencies; ASC
Subtopic 310-30, Receivables-Loans and Debt Securities Acquired with Deteriorated Credit Quality; ASC Subtopic
320-10, Investments-Debt and Equity Securities - Overall; and ASC Subtopic 325-40, Investments-Other-Beneficial
Interests in Securitized Financial Assets.

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Institutions must apply ASU 2016-13 in their Call Report submissions in accordance with
the effective dates set forth in the ASU. 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 for the quarter ended March 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 for the quarter ended March 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, 2021.5 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 for December 31,
2021, if the institution is required to file these forms.6 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.

5

On 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 non-PBEs for fiscal years beginning after December 15, 2021, including interim periods within those
fiscal years.
6
If the FASB issues a final Accounting Standards Update amending the transition and effective date provisions in
ASU 2016-13 as described in footnote 3, 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.

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Effective Dates for ASU 2016-13
U.S. GAAP Effective Date

Regulatory
Report Effective
Date7

Fiscal years beginning after 12/15/2019, including interim
periods within those fiscal years

3/31/2020

Fiscal years beginning after 12/15/2020, including interim
periods within those fiscal years

3/31/2021

Non-PBEs

Fiscal years beginning after 12/15/2020, and interim
periods for fiscal years beginning after 12/15/2021

12/31/2021

Early
Application

First calendar
Early application permitted for fiscal years beginning after quarter-end after
12/15/2018, including interim periods within those fiscal
effective date of
years
early application of
the ASU

PBEs That
Are SEC
Filers
Other PBEs
(Non-SEC
Filers)

EGRRCPA
On May 24, 2018, EGRRCPA amended various statutes administered by the agencies.8
Two of the amendments made by EGRRCPA, as described below, changed the regulatory
treatment of certain information that is reported on the Call Reports. Following a request by the
agencies for emergency review, the OMB authorized the agencies, under the auspices of the
FFIEC to revise, without seeking public comment, the reporting of information in the Call
Reports on certain high volatility commercial real estate (HVCRE) exposures and reciprocal
deposits, effective for the June 30, 2018, report date. As a result of OMB’s emergency approval,
the expiration date of these collections is now February 28, 2019. The agencies are now
undertaking the regular PRA process for revising and extending these information collections for
three years.
• HVCRE Exposures. Section 214 of EGRRCPA modified the Federal Deposit Insurance
Act (FDI Act) to add a new section 51 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, the agencies revised the Call Reports to permit
depository institutions to use the EGRRCPA definition of HVCRE ADC Loan in place of the
definition of HVCRE loan found in the Call Report instructions 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.

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8

For institutions with calendar fiscal year-ends and reports with quarterly report dates.
See Pub. L. No. 115-174, 132 Stat. 1296 (2018).

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• Reciprocal Deposits. 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. The agencies revised the Call Reports to permit institutions to
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.
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
off-balance sheet credit exposures. 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.
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 institutions, and (3) equivalent data items
are not readily available through other means. In following these principles, the agencies sought
to limit the number of data items being added to the Call Report 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:
 Schedule RI – Income Statement
 Schedule RI-B – Charge-offs and Recoveries on Loans and Leases and Changes in
Allowance for Loan and Lease Losses
 Schedule RI-C – Disaggregated Data on the Allowance for Loan and Lease Losses
(FFIEC 031 and FFIEC 041 only)
 Schedule RI-D – Income from Foreign Offices (FFIEC 031 only)

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Schedule RI-E – Explanations
Schedule RC – Balance Sheet
Schedule RC-B – Securities
Schedule RC-C – Loans and Lease Financing Receivables
Schedule RC-F – Other Assets
Schedule RC-G – Other Liabilities
Schedule RC-H – Selected Balance Sheet Items for Domestic Offices (FFIEC 031 only)
Schedule RC-K – Quarterly Averages
Schedule RC-N – Past Due and Nonaccrual Loans, Leases, and Other Assets
Schedule RC-R – Regulatory Capital
Schedule RC-V – Variable Interest Entities (FFIEC 031 and FFIEC 041 only)
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 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 201613, 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 201613, 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
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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 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. Therefore, the Call Report instructions would be
clarified to the effect that upon adoption of the new standard, unconditionally cancellable offbalance sheet exposures would be excluded from the allowance for credit losses assessment .
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. 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, 2022.9
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 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
9

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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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.
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:
 Schedule RC-E – Deposit Liabilities
 Schedule RC-O – Other Data for Deposit Insurance and FICO Assessments
 Schedule RC-R – Regulatory Capital: Part II. Risk-Weighted Assets
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.
ASU 2016-13 Proposed Call Report Revisions
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. Therefore, 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

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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 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 “Charge-offs 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, 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).”

11

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-to-investment 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 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,

12

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 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. Total mortgage-backed securities (MBS) (including CMOs, REMICs, and stripped MBS)
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 report the

13

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 securities-related 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.
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 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

14

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 held-to-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, 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 cost10 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 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
10

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.

15

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 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.
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.11 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 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
11

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.

16

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 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-balancesheet 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 off-balance-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

17

amortized cost amounts reported for HTM debt securities in column A.12 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.
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 201613.
Schedule RC-R (FFIEC 031, FFIEC 041, and FFIEC 051)
In connection with the agencies’ recently approved final rule on the implementation of
CECL and the related transition for regulatory capital (CECL Rule),13 the agencies are proposing
a number of revisions to Schedule RC-R to incorporate new terminology and the approved
optional regulatory capital transition. The proposed reporting changes to Schedule RC-R would
be tied to the revisions in the CECL Rule. 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 Rule introduces a newly defined regulatory capital term, allowance for credit
losses (ACL), which replaces the term ALLL, as defined under the existing capital rules, for
institutions that have adopted CECL. The CECL Rule also provides that credit loss allowances
for PCD assets held by these institutions should be netted when determining the carrying value,
as defined in the CECL Rule, and, therefore, only the resulting net amount is be subject to riskweighting. In addition, in the CECL Rule, the agencies have provided each institution the option
to phase in the day-one regulatory capital effects that may result from the adoption of ASU 201612

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.
13
See https://www.federalreserve.gov/newsevents/pressreleases/bcreg20181221a.htm.

18

13 over the three-year period beginning with the institution’s CECL effective date.14
Allowances for Credit Losses Definition and Treatment of Purchased Credit Deteriorated
Assets
In general, under the CECL Rule, institutions that have adopted CECL will be required to
report ACL amounts 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 revisions to the instructions would affect Schedule RC-R,
Part I. Regulatory Capital Components and Ratios, item 30 (FFIEC 051) and item 30.a
(FFIEC 031 and FFIEC 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, “Risk-weighted 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, consistent with the CECL Rule, assets and off-balance sheet credit exposures
for which any related credit loss allowances are eligible for inclusion in regulatory capital should
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, Heldfor-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, “On-balance 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.15
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 credit-deteriorated assets.” The amount of such
allowances for credit losses would be reported separately for “Loans and leases held for
14

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
Rule, such a non-PBE should 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.
15
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.

19

investment” in Memorandum item 4.a, “Held-to-maturity 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 Rule, 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 Rule, an electing institution should 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 Rule.
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 FFIEC 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
FFIEC 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 Rule 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.

20

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 RCV 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.”
EGRRCPA Proposed Call Report Revisions
As described above, effective beginning with the June 30, 2018, report date, the agencies
implemented emergency revisions to the Call Reports regarding the reporting of HVCRE
exposures and reciprocal deposits in order to reflect statutory amendments made by sections 202
and 214 of EGRRCPA. 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. The agencies are now undertaking the
regular PRA process for revising and extending these information collections for three years.
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.
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

21

reciprocal deposits up to the lesser of the following amounts as non-brokered 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.
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 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 reissued 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 added a new Memorandum item 1.g to Schedule RC-E in which
institutions 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 is 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”
is 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-by-institution
basis. The Memorandum item for “Total reciprocal deposits” enable the agencies to identify

22

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,” 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 reissued these Supplemental Instructions for September 2018.
Revised instructions for items 9 and 9.a will be incorporated into the Call Report instructions 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.
Time Schedule for Information Collection and Publication
The Call Reports are collected quarterly as of the end of the last calendar day of March,
June, September, and December, although certain information is collected on a semiannual or
annual basis, as described in the Call Report instructions. Less frequent collection of Call
Reports would reduce the Board’s ability to identify on a timely basis those banks that are
experiencing adverse changes in their condition so that appropriate corrective measures can be
implemented to restore their safety and soundness. State member banks generally must submit
the Call Reports to the appropriate Federal Reserve Bank within 30 calendar days following the
as-of date, except that banks with more than one foreign office must submit the call Reports
within 35 calendar days following the as-of date.

23

Aggregate data are published in the Federal Reserve Bulletin and the Annual Statistical
Digest. Additionally, data are used in the Uniform Bank Performance Report (UBPR) and the
Annual Report of the FFIEC. Individual respondent data, excluding confidential information,
are available to the public from the National Technical Information Service in Springfield,
Virginia, upon request approximately twelve weeks after the report date. Data are also available
from the FFIEC Central Data Repository Public Data Distribution (CDR PDD) website
(https://cdr.ffiec.gov/public/). Data for the current quarter are made available, shortly after a
bank’s submission, beginning the first calendar day after the report date. Updated or revised data
may replace data already posted at any time thereafter.
Legal Status
The Board is authorized to collect information on the Call Reports from state member
banks pursuant to section 9 of the Federal Reserve Act, which requires state member banks to
file reports of condition and of the payment of dividends with the Federal Reserve
(12 U.S.C. 324). The obligation for state member banks to respond is mandatory.
Most of the information provided on the Call Reports is made public. However, the
following items are confidential: (1) the FDIC deposit insurance assessment information
reported in response to item 2.g on schedule RI-E, (2) the prepaid deposit insurance assessments
information reported in response to item 6.f on schedule RC-F, and (3) the information regarding
other data for deposit insurance and FICO assessments reported in response to memorandum
items 6-9, 14-15, and 18 on schedule RC-O. It is possible to determine an institution’s
confidential Capital, Asset Quality, Management, Earnings, Liquidity, and Sensitivity
(CAMELS) rating based on the data reported under the FDIC deposit insurance assessment data
item and the prepaid deposit insurance assessments data item. As a result, this information is
exempt from disclosure under (b)(8), which specifically exempts from disclosure information
“contained in or related to examination, operating, or condition reports prepared by, on behalf of,
or for the use of an agency responsible for the regulation or supervision of financial institutions”
(5 U.S.C. 552(b)(8)). Additionally, this information can be kept confidential under section (b)(4)
of the Freedom of Information Act (5 U.S.C. 552(b)(4)). The release of this information and
information regarding other data for deposit insurance and FICO assessments reported in
response to memorandum items 6-9, 14-15, and 18 on schedule RC-O would likely cause
substantial harm to the competitive position of the institution from whom the information was
obtained if it was released.
Public Comments and Response
On September 28, 2018, the agencies, under the auspices of the FFIEC, published an
initial notice in the Federal Register (83 FR 49160) requesting public comment for 60 days on
the extension, with revision, of the Call Reports. The comment period for this notice expired on
November 27, 2018. The agencies received comments from two entities: a bankers’ association
and a bank. The commenters requested clarification regarding certain statements made in the
Federal Register notice, recommended that the Board alter certain proposed language in the
reporting instructions or reporting forms for clarification, and recommended certain other
organizational and substantive changes to the proposal.

24

One commenter requested clarification regarding whether losses caused by interest rate
movement, which currently is included as part of OTTI, will be considered credit losses after the
adoption of CECL, under which the concept of OTTI will no longer be relevant. The commenter
appears to be seeking an interpretation of how the new credit losses accounting standard, ASU
2016-13, applies to securities (because inventory is not within the scope of ASU 2016-13)
compared to how the previous accounting standards on OTTI applied to securities. This request
for interpretation of ASU 2016-13 should be directed to the Financial Accounting Standards
Board.
One commenter asked whether footnote 3 to Schedule RC should refer to institutions that
have not adopted ASU 2016-13, instead of institutions that have done so. Schedule RC
footnote 3 has been corrected to refer to institutions that have not adopted ASU 2016-13. The
commenter also requested clarification regarding the proposed footnote 2 to the reporting form
for Schedule RC-F, Other assets, item 1. Specifically, the commenter asked whether a reporter
has a choice between reporting accrued interest receivable as part of the financial asset’s
amortized cost and reporting it on this Line on Schedule RC-F and whether the footnote creates a
distinction in the treatment of interest accrued on assets at amortized cost versus those held for
sale or under the fair value option. Schedule RC-F, footnote 2 has been corrected to remove the
reference to “financial asset’s amortized cost.”
One commenter noted that the instructions provided in the proposed footnote 2 to the
reporting form for Schedule RC-R, Regulatory Capital Part II. Risk-Weighted Assets, line 5,
would incorrectly cause column A to not equal the sums of columns B through R. Schedule RCR, Part II, footnote 2 has been corrected. Similarly, the commenter noted that the instructions
provided in Schedule RC-R – Regulatory Capital Part II. Risk-Weighted Assets lines 2a, 3b, 8,
and 9a, footnote 3 (9a, footnote 2), would incorrectly cause column A to not equal the sums of
columns B through R. This comment reflects an incorrect understanding of the risk-based
capital rules and how they are applied when reporting under the standardized approach in
Schedule RC-R, Part II. The comment is based on a view that assets are risk weighted net of the
allowance when the allowance is includable in tier 2 capital, which is incorrect because assets are
risk weighted gross of the allowance when the allowance is includable in tier 2 capital.
A commenter suggested that it would be appropriate to collect the proposed new
Memorandum item “Amount of allowances for credit losses on purchased credit-deteriorated
assets” as part of Schedule RI-C – Part II. Disaggregated Data on the Allowance for Credit
Losses, rather than Schedule RC-R, Part II. Risk-Weighted Assets, as originally proposed. Since
Schedule RI-C, Part II, is completed only by institutions with greater than $1 billion in total
consolidated assets and therefore not collected on the FFIEC 051, the memorandum item was
retained on Schedule RC-R, Part II.
The agencies also reevaluated the proposed portfolio categories for which disaggregated
allowance information would begin to be reported by institutions after adoption of ASU 2016-13
for held-to-maturity (HTM) debt securities on Schedule RI-C, Part II, on the FFIEC 031 and
FFIEC 041. The agencies determined that separate reporting of allowances on HTM mortgagebacked securities issued or guaranteed by U.S. government agencies or sponsored agencies and
other HTM mortgage-backed securities, which had been proposed in the September 2018 notice,

25

is not needed because, at present, the former category of mortgage-backed securities could have
zero expected credit losses based on historical credit loss information, adjusted for current
conditions and reasonable and supportable forecasts. As a result, the agencies propose to
combine these portfolio categories and collect only one data item, rather than two data items, for
the total allowances on an institution’s HTM mortgage-backed securities.
In addition, in December 2018, the agencies approved the CECL Rule. The final rule
included revised terminology for the allowance balance eligible for inclusion in regulatory
capital. The agencies have made a conforming terminology revision regarding the allowance
balance eligible for inclusion in regulatory capital to the reporting to the reporting instructions
for Schedule RC-R.
After considering these comments, the agencies are adopting the revisions proposed in
the September 2018 notice to the FFIEC 031, FFIEC 041, and FFIEC 051 as originally proposed,
with the modifications noted above.
On February 14, 2019, the agencies published a final notice in the Federal Register
(84 FR 4131).
Consultation outside the Agency
There has been no consultation outside of the Federal Reserve System.
Estimate of Respondent Burden
The current annual reporting burden for the Call Report is estimated to be 159,200 hours
and would increase to 159,550 hours as shown in the following table. The average estimated
hours per response for Board Call Report filers would increase from 50.00 hours to 50.11 hours
due to the proposed changes. The estimated average burden hours collectively reflect the
estimates for the FFIEC 031, FFIEC 041, and FFIEC 051 reports. When the estimates are
calculated by type of report across the agencies, the estimated average burden hours per quarter
are 95.47 (FFIEC 031), 55.71 (FFIEC 041), and 39.77 (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). These reporting requirements represent 1.4 percent of
the total Federal Reserve paperwork burden.

26

Number of
respondents16

Annual
frequency

Estimated
average hours
per response

Estimated
annual burden
hours

Current

796

4

50.00

159,200

Proposed

796

4

50.11

159,550

FFIEC 031, FFIEC 041, and
FFIEC 051

350

Change

The current total annual cost to all state member banks is estimated to be $8,923,160 and with
the proposed revisions would increase to $8,942,778.17 This estimate represents costs associated
with recurring salary and employee benefits, and expenses associated with software, data
processing, and bank records that are not used internally for management purposes but are
necessary to complete the Call Reports.
Sensitive Questions
This collection of information contains no questions of a sensitive nature, as defined by
OMB guidelines.
Estimate of Cost to the Federal Reserve System
The current cost to the Federal Reserve System for collecting and processing the
FFIEC 031, FFIEC 041, and FFIEC 051 is estimated to be $1,871,500 per year.

16

Of these respondents, 529 are considered small entities as defined by the Small Business Administration (i.e.,
entities with less than $550 million in total assets), www.sba.gov/document/support--table-size-standards.
17
Total cost to the public was estimated using the following formula: percent of staff time, multiplied by annual
burden hours, multiplied by hourly rates (30% Office & Administrative Support at $18, 45% Financial Managers at
$69, 15% Lawyers at $68, and 10% Chief Executives at $94). Hourly rates for each occupational group are the
(rounded) mean hourly wages from the Bureau of Labor and Statistics (BLS), Occupational Employment and Wages
May 2017, published March 30, 2018, www.bls.gov/news.release/ocwage.t01.htm. Occupations are defined using
the BLS Occupational Classification System, www.bls.gov/soc/.

27