FFIEC 031, FFIEC 041, and FFIEC 051 18 Question Format OMB Supporting Statement Emergency

Supporting Statement for the
Consolidated Reports of Condition and Income
(FFIEC 031, FFIEC 041, and FFIEC 051; OMB No. 7100-0036)
1.

Explain the circumstances that make the collection of information necessary.

The Board of Governors of the Federal Reserve System (Board) requests approval from
the Office of Management and Budget (OMB) to revise 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) under the emergency clearance
provisions of OMB’s regulations. 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 Federal Deposit Insurance
Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC) have also
submitted a similar request for OMB review to request this information from banks under their
supervision.
The Board 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, FDIC, and OCC (the agencies) propose under the emergency clearance
provisions of OMB’s regulations to revise the Call Reports effective beginning with the March
31, 2020 report date. The agencies are providing a summary of the three interim final rules
(IFRs) issued in response to disruptions related to COVID-19 and one reporting change related to
the Coronavirus Aid, Relief, and Economic Security Act (CARES Act).1 Although there is a
substantive change to the actual calculation of items, as identified below, for purposes of the Call
Reports, the change should be minimal and result in a zero net change in hourly burden under the
agencies’ information collections. The current estimated total annual burden for the Call Reports
is 138,506 hours, and would not change with the proposed revision.
The agencies have determined that (1) the collection of information within the scope of
this request is needed prior to the expiration of time periods established under 5 CFR 1320.10,
(2) this collection of information is essential to the mission of the agencies, and (3) the agencies
cannot reasonably comply with the normal clearance procedures because an unanticipated event
has occurred and the use of normal clearance procedures is reasonably likely to prevent or
disrupt the collection of information.
Recent events have suddenly and significantly impacted financial markets. The spread of
the coronavirus disease 2019 has disrupted economic activity in many countries. In addition,
financial markets have experienced significant volatility. The magnitude and persistence of the
overall effects on the economy remain highly uncertain. In light of these developments, banking
organizations may realize a sudden, unanticipated drop in capital ratios and liquidity. This could
1

Pub. L. No. 116-136, 134 Stat. 281 (March 27, 2020).

create a strong incentive for these banking organizations to limit their lending and other financial
intermediation activities in order to avoid facing abrupt regulatory capital and liquidity
limitations.
In late March, the agencies issued three IFRs to make changes to their regulatory capital
and liquidity rules to facilitate banking organizations’ use of the Board’s emergency facilities
and support prudent lending by banking organizations. The IFRs were issued with immediate
effective date and they impact amounts reported on Schedule RC-R, Regulatory Capital, Part 1.
These changes, as listed below, apply to the three versions of the Call Report (FFIEC 031,
FFIEC 041, and FFIEC 051). As stated in the three Federal Register notices, the agencies
believe that, in light of current market uncertainty, the public interest is best served by
implementing the IFR changes as soon as possible. The agencies request emergency clearance
from OMB to permit these revisions for the March 31, 2020, Call Reports.
2.

Indicate how, by whom, and for what purpose the information is to be used. Except
for a new collection, indicate the actual use the agency has made of the information
received from the current 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.
The Call Reports consist of three reporting forms that apply to different categories of state
member banks. Currently, banks that have foreign offices or that have total consolidated assets of
$100 billion or more must file the FFIEC 031, banks with domestic offices only and total
consolidated assets of less than $100 billion but more than $5 billion file the FFIEC 041, and
banks with domestic offices only and total assets less than $5 billion file the FFIEC 051.
The information collected by the Call Reports is not available from other sources.
Although there are other reports that collect information similar to certain items on the Call
Reports, the information they collect would be of limited value as a replacement for Call Report
data. For example, the Board collects various data in connection with its measurement of
monetary aggregates, bank credit, and flow of funds. These reports provide 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 collected
on a weekly basis usually prepared as of dates other than the last business day of each quarter.
Moreover, information on bank credit is obtained on a sample basis rather than from all insured
banks. Additionally, institutions below a certain size are exempt entirely from some of these
reporting requirements.
The Board also collects financial data from bank holding companies on a regular basis.
Such data is generally required to be reported 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

entities 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. Therefor, reports collected from bank holding companies lack the
data necessary to assess the financial condition of individual banks to determine whether there
had been any deterioration in their condition.
3.

Describe whether, and to what extent, the collection of information involves the use
of automated, electronic, mechanical, or other technological collection techniques or
other forms of information technology.

Banks are required to transmit their Call Report data electronically. The agencies have
created the Central Data Repository (CDR) as the only method available to banks and savings
associations for submitting their Call Report data. Under the CDR system, institutions file their
Call Report data via the Internet using software that contains the FFIEC’s edits for validating
Call Report data before submission.
4.

Describe efforts to identify duplication. Show specifically why any similar
information already available cannot be used or modified for use for the purposes
described in Item 2 above.

There is no other report or series of reports that collects from all insured banks and
savings associations the regulatory capital and other information gathered through the Call
Reports as a whole. There are other information collection systems that tend to duplicate certain
parts of the Call Report, but the information they provide would be of limited value as a
replacement for the Call Report.
5.

If the collection of information impacts small businesses or other small entities,
describe any methods used to minimize burden.

Of respondents to the Call Reports, 526 are considered small entities as defined by the
Small Business Administration (i.e., entities with less than $600 million in total assets),
www.sba.gov/document/support--table-size-standards. Data collected in the Call Report
information collection is tiered to the size and activity levels of reporting institutions.
The Call Report requires the least amount of data from small institutions with domestic
offices only and less than $5 billion in total assets that file the streamlined FFIEC 051 report
form. Certain institutions with less than $300 million in total assets have fewer items applicable
to them than do institutions with $300 million to $1 billion in assets. In addition, the
supplemental information schedule in the FFIEC 051, which replaced five entire schedules and
parts of certain other schedules that had been in the FFIEC 041, includes nine indicator questions
with “yes”/”no” responses that ask about an institution’s involvement in certain complex or
specialized activities. Only if the response to a particular indicator question is a “yes” is an
institution required to complete an average of three indicator items that provide data on the
extent of the institution’s involvement in that activity.
Exemptions from reporting certain Call Report data within the FFIEC 041 report form

also apply to institutions with less than $500 million, $1 billion, and $10 billion in total assets. In
both the FFIEC 051 and the FFIEC 041, other exemptions are based on activity levels rather than
total assets and these activity-based thresholds tend to benefit small institutions. In addition, for
small institutions with domestic offices only and less than $1 billion in total assets that file the
FFIEC 051, a significant number of data items in the FFIEC 051 report are collected
semiannually or annually rather than quarterly as they had been when these institutions filed the
FFIEC 041 report.
6.

Describe the consequence to Federal program or policy activities if the collection is
not conducted or is conducted less frequently, as well as any technical or legal
obstacles to reducing burden.

The agencies must have condition and income data at least quarterly to properly monitor
individual bank and industry trends and to comply with a statutory requirement to obtain four
reports of condition per year. Less frequent collection of this information would impair the
agencies’ ability to monitor financial institutions and could delay regulatory response.
7.

Explain any special circumstances that would cause an information collection to be
conducted in a manner inconsistent with 5 CFR 1320.5(d)(2).

This information collection is conducted in a manner consistent with the guidelines in 5
CFR 1320.5(d)(2).
8.

Describe comments in response to the Federal Register notice and efforts to consult
outside the agency.

The Board coordinated and consulted with the FDIC and OCC in proposing these
revisions. The agencies will follow this request for emergency processing with a request under
normal clearance procedures, during which comments will be solicited for the typical 60-day and
30-day periods. All comments received on paperwork burden, whether during the 60-day or
30-day comment periods, will be considered in finalizing the collection.
9.

Explain any decision to provide any payment or gift to respondents, other than
remuneration of contractors or grantees.
There are no payments or gifts provided to respondents.

10.

Describe any assurance of confidentiality provided to respondents and the basis for
the assurance in statute, regulation, or agency policy. If the collection requires a
systems of records notice (SORN) or privacy impact assessment (PIA), those should
be cited and described here.

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. Board staff have determined that it is possible to
reverse engineer an institution’s Capital, Asset Quality, Management, Earnings, Liquidity, and
Sensitivity (CAMELS) rating based on the data reported under the FDIC deposit insurance
assessment data item and the prepaid deposit insurance assessments data item. If this information
were publicly available, it would be possible to determine the state member bank’s CAMELS
rating. Therefore, this information can be kept confidential under exemption 8 of the Freedom of
Information Act (FOIA), which specifically exempts from disclosure information “contained in
or related to examination, operating, or condition reports prepared by, on behalf of, or for the use
of an agency responsible for the regulation or supervision of financial institutions” (5 U.S.C.
§ 552(b)(8)). Board staff have also advised that 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. Therefore, this information can be kept confidential also under exemption 4 of FOIA,
which exempts “trade secrets and commercial or financial information obtained from a person
and privileged or confidential” (5 U.S.C. § 552(b)(4)).
11.

Provide additional justification for any questions of a sensitive nature.
There are no questions of a sensitive nature.

12.

Provide estimates of the annual hourly burden of the collection of information.

As shown in the table below, the estimated total annual burden for the Call Reports is
138,506 hours, and would remain unchanged with the proposed revisions. The estimated average
hours per response for the quarterly filings of the Call Report is a weighted average of the three
versions of the Call Report (FFIEC 031, FFIEC 041, and FFIEC 051). Both the weighted average
Call Report burden estimate and the three separate versions of the Call Report vary by agency
because of differences in the composition of the institutions under each agency’s supervision
(e.g., size distribution of institutions, types of activities in which they are engaged, and existence
of foreign offices). These reporting requirements represent 1.3 percent of the Board’s total
paperwork burden.
FFIEC 031, FFIEC 041, and
FFIEC 051
Current

Estimated
number of
respondents

Annual
frequency

Estimated
average hours
per response

779

4

44.45

Estimated
annual burden
hours
138,506

The estimated total annual cost to the public for the Call Reports is $7,977,946.
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 $19, 45% Financial Managers at $71, 15% Lawyers at $69, and 10% Chief Executives
at $96). 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 2018,

published March 29, 2019, https://www.bls.gov/news.release/ocwage.t01.htm. Occupations are
defined using the BLS Occupational Classification System, https://www.bls.gov/soc/.
13.

Provide an estimate for the total annual cost burden to respondents or record
keepers resulting from the collection of information.
There are no annualized costs to the respondents.

14.

Provide estimates of annualized costs to the Federal government.

The estimated cost to the Federal Reserve System for collecting and processing the
FFIEC 031, FFIEC 041, and FFIEC 051 is $1,871,500 per year.
15.

Explain the reasons for any program changes or adjustments reported on the
burden worksheet.

There are no changes to the burden worksheet, but the agencies propose the following
revisions:
Eligible Retained Income - Interim Final Rule
Under the capital rule, a banking organization must maintain a minimum amount of
regulatory capital. In addition, a banking organization must maintain a buffer of regulatory
capital above its minimum capital requirements to avoid restrictions on capital distributions. The
agencies intend for the buffer requirements to limit the ability of banking organizations to
distribute capital in the form of dividends and discretionary bonus payments and therefore
strengthen the ability of banking organizations to continue lending and conducting other
financial intermediation activities during stress periods. The agencies are concerned, however,
that the existing calculation method could lead to sudden and severe distribution limits if such
banking organizations were to experience even a modest reduction in their capital ratios.
Therefore, the agencies adopted an interim final rule2 on March 20, 2020, that revises the
definition of eligible retained income. By modifying the definition of eligible retained income
and thereby allowing banking organizations to more freely use their capital buffers, this interim
final rule should help to promote lending activity and other financial intermediation activities by
banking organizations and avoid compounding disruptions due to COVID-19.
Reporting Revisions
The interim final rule on Eligible Retained Income revises the calculation on the Call
Report, Schedule RC-R, Part I, Item 53, “Eligible retained income”.
Previously, an institution’s eligible retained income was net income for the four
preceding calendar quarters, net of any distributions and associated tax effects not already
reflected in net income. Under the interim final rule, an institution would now report the amount
2

85 FR 15909 (March 20, 2020).

of eligible retained income as the greater of (1) an institution’s net income for the four preceding
calendar quarters, net of any distributions and associated tax effects not already reflected in net
income and (2) the average of an institution’s net income over the four preceding calendar
quarters.
For Schedule RC-R, Part I, item 53, four preceding calendar quarters refers to the
calendar quarter ending on the last day of the reporting period and three preceding calendar
quarters. The average of an institution’s net income over the four preceding calendar quarters
refers to average of three-month net income for the calendar quarter ending on the last of the
reporting quarter and three-month net income for the three preceding calendar quarters.
Money Market Mutual Fund Liquidity Facility (MMLF) - Interim Final Rule
To enhance the liquidity and functioning of money markets, the Federal Reserve Bank of
Boston launched the Money Market Mutual Fund Liquidity Facility (MMLF) on March 18,
2020. On March 23, 2020, the agencies published an interim final rule,3 which permits banking
organizations to exclude from regulatory capital requirements exposures related to the MMLF.
The interim final rule modifies the agencies’ capital rule to allow banking organizations
to neutralize the effects of purchasing assets through the MMLF on their risk-based and leverage
capital ratios. This treatment extends to the community bank leverage ratio. Specifically, a
banking organization may exclude from its total leverage exposure, average total consolidated
assets, standardized total risk-weighted assets, and advanced approaches total risk-weighted
assets, as applicable, any exposure acquired pursuant to a non-recourse loan from the MMLF.
The interim final rule only applies to activities with the MMLF. The facility is scheduled to
terminate on September 30, 2020, unless the facility is extended by the Federal Reserve Board.
Reporting Revisions
Starting with the March 31, 2020 reporting period, banking organizations would include
the amount of assets purchased from the MMLF in Schedule RC-B and Schedule RC-R, as
appropriate. For regulatory capital reporting, assets purchased from the MMLF should be
reported in either Schedule RC-R, Part II, item 2.a., “Held-to-maturity securities,” or Schedule
RC-R, Part II, item 2.b., “Available-for-sale debt securities and equity securities with readily
determinable fair values not held for trading ,” as appropriate, in both Column A (Totals) and
Column C (0% risk-weight category) . The average of such assets purchased would be reported
in Schedule RC-R, part I, item 29, “LESS: Other deductions from (additions to) assets for
leverage ratio purposes,” and thus excluded from Schedule RC-R, item 30, “Total assets for the
leverage ratio.”
Advanced approaches banking organizations should not include assets purchased from
the MMLF in “total risk-weight assets (RWAs)” reported in Schedule, RC-R, Part I, item 48.b.
Banking organizations would report their adjusted “Total leverage exposure” and
“Supplementary leverage ratio” in Schedule RC-R, Part I, item 55.a and 55.b.

3

85 FR 16232 (March 23, 2020).

Borrowings from the Federal Reserve Bank of Boston would be included in Schedule
RC, item 16, “Other borrowed money,” and included in Schedule RC-M, item 5.b.(1)(a), “Other
borrowed money with a remaining maturity of one year or less.”
Furthermore, banking organizations are encouraged to separately disclose in a “Narrative
Statement Concerning the Amounts Reported in the Reports of Condition and Income,” the
amount of assets purchased from the MMLF included in Schedule RC-R, Part II, item 2.a. or 2.b.
In addition, banking organizations are encouraged to separately disclose in a similar narrative,
the average amount of assets purchased from the MMLF that were excluded from Schedule
RC-R, item 30.
Current Expected Credit Losses (CECL) Revised Transition - Interim Final Rule
The interim final rule,4 published on March 31, 2020, delays the estimated impact on
regulatory capital stemming from the implementation of Accounting Standards Update No.
2016-13, Financial Instruments - Credit Losses, Topic 326, Measurement of Credit Losses on
Financial Instruments. The interim final rule provides banking organizations that implement
CECL before the end of 2020 the option to delay for two years an estimate of CECL’s effect on
regulatory capital, relative to the incurred loss methodology’s effect on regulatory capital,
followed by a three-year transition period. The agencies are providing this relief to allow such
banking organizations to better focus on supporting lending to creditworthy households and
businesses in light of market disruptions as a result of COVID-19, while also maintaining the
quality of regulatory capital.
Reporting Revisions
The interim final rule on Current Expected Credit Losses Regulatory Capital Transition
would revise the calculation on the Call Report, Schedule RC-R, Part I, Items 2 (Retained
earnings), 27 (Average total consolidated assets), 42 (FFIEC 041 and FFIEC 051) or 42.a.
(FFIEC 031) (Allowance for Loan and Lease Losses includable in Tier 2 capital), 42.b. (Eligible
credit reserves includable in tier 2 capital) (FFIEC 031 only), 55.a (Total leverage exposure)
(FFIEC 031 and FFIEC 041 only), and Schedule RC-R, Part II, Item 8 (All other assets).
Institutions that elect the 2020 CECL transition approach would need to calculate the
following amounts as described below, as applicable.
AACL refers to the Adjusted Allowances for Credit Losses, as defined in 12 CFR 3.2
(OCC); 12 CFR 217.2 (Board); or 12 CFR 324.2 (FDIC):
CECL Transitional Amount means the decrease in the amount of an institution’s retained
earnings as of the beginning of the fiscal year in which the institution adopts CECL from the
amount of the institution’s retained earnings as of the closing of the fiscal year-end immediately
prior to the institution’s adoption of CECL.
Deferred Tax Assets (DTA) Transitional Amount means the increase in the amount of an
4

85 FR 17723 (March 31, 2020).

institution’s DTAs arising from temporary differences as of the beginning of the fiscal year in
which the institution adopts CECL from the amount of the institution’s DTAs arising from
temporary differences as of the closing of the fiscal year-end immediately prior to the
institution’s adoption of CECL.
AACL Transitional Amount means the difference in the amount of an institution’s AACL
as of the beginning of the fiscal year in which the institution adopts CECL and the amount of the
institution’s ALLL as of the closing of the fiscal year-end immediately prior to the institution’s
adoption of CECL.
Eligible Credit Reserves Transitional Amount means the increase in the amount of an
institution’s eligible credit reserves as of the beginning of the fiscal year in which the institution
adopts CECL from the amount of the institution’s eligible credit reserves as of the closing of the
fiscal year-end immediately prior to the institution’s adoption of CECL.
Modified CECL Transitional Amount means A) during the first two years of the
transition period, the difference between AACL as reported in the most recent Call Report (or
FR Y-9C), and the AACL as of the beginning of the fiscal year in which the institution adopts
CECL, multiplied by 0.25, plus the CECL transitional amount and B) during the last three years
of the transition period, the difference between AACL as reported in the Call Report at the end of
the second year of the transition period and the AACL as of the beginning of the fiscal year in
which the institution adopts CECL, multiplied by 0.25, plus the CECL transitional amount.
Modified AACL Transitional Amount means A) during the first two years of the
transition period, the difference between AACL as reported in the most recent Call Report (or
FR Y-9C), and the AACL as of the beginning of the fiscal year in which the institution adopts
CECL, multiplied by 0.25, plus the AACL transitional amount and B) during the last three years
of the transition period, the difference between AACL as reported in the Call Report at the end of
the second year of the transition period and the AACL as of the beginning of the fiscal year in
which the institution adopts CECL, multiplied by 0.25, plus the AACL transitional amount.
Adjustments to Instructions for Call Report Data Items
RC-R, Part I, Item 2: (Retained Earnings) – An institution electing the 2020 CECL
transition would add the Modified CECL Transitional Amount, as defined in section 301 of the
agencies’ regulatory capital rules, when calculating this item, adjusted as follows: 100% in Years
1 and 2 of the transition period; 75% in Year 3 of the transition period; 50% in Year 4 of the
transition period; and 25% in Year 5 of the transition period.
RC-R, Part I, Item 2.a: (CECL Transition) (Starting in June 30, 2020, Call Report) – An
institution that has adopted CECL would report whether it is using a CECL transition, as defined
in section 301 of the agencies’ regulatory capital rules, in the Call Report for the current quarter.
The institution can choose from the following entries: 0 = Did not Adopt; 1 = Adopted Without
Transition; 2 = 3-year CECL Transition; 3 = 5-year 2020 CECL Transition.
(FFIEC 041 and FFIEC 051) RC-R, Part I, Item 15: (DTAs Arising from Temporary

Differences) – An institution electing the 2020 CECL transition would subtract the DTA
Transitional Amount, as defined in section 301 of the agencies’ regulatory capital rules, from the
amount of DTAs from temporary differences used in the calculation of this item, adjusted as
follows: 100% in Years 1 and 2 of the transition period; 75% in Year 3 of the transition period;
50% in Year 4 of the transition period; and 25% in Year 5 of the transition period.
(FFIEC 031) RC-R, Part I, Item 15.a. or 15.b.: (DTAs Arising from Temporary
Differences) – An institution electing the 2020 CECL transition would subtract the DTA
Transitional Amount, as defined in section 301 of the agencies’ regulatory capital rules, from the
amount of DTAs from temporary differences used in the calculation of this item, adjusted as
follows: 100% in Years 1 and 2 of the transition period; 75% in Year 3 of the transition period;
50% in Year 4 of the transition period; and 25% in Year 5 of the transition period.
RC-R, Part I, Item 27: (Average Total Consolidated Assets) – An institution electing the
2020 CECL transition would add the Modified CECL Transitional Amount, as defined in section
301 of the agencies’ regulatory capital rules, when calculating this item, adjusted as follows:
100% in Years 1 and 2 of the transition period; 75% in Year 3 of the transition period; 50% in
Year 4 of the transition period; and 25% in Year 5 of the transition period.
RC-R, Part I, Item 42: (Adjusted Allowances for Credit Losses/ALLL in Tier 2 Capital) –
An institution electing the 2020 CECL transition would subtract the Modified AACL
Transitional Amount, as defined in section 301 of the agencies’ regulatory capital rules, when
calculating this item, adjusted as follows: 100% in Years 1 and 2 of the transition period; 75% in
Year 3 of the transition period; 50% in Year 4 of the transition period; and 25% in Year 5 of the
transition period.
(FFIEC 031 and FFIEC 041) RC-R, Part I, Item 55.a: (Total Leverage Exposure) – For an
institution subject to the supplementary leverage ratio (advanced approaches or Category III
institution), the institution electing the 2020 CECL transition would add the Modified CECL
Transitional Amount, as defined in section 301 of the agencies’ regulatory capital rules, when
calculating this item, adjusted as follows: 100% in Years 1 and 2 of the transition period; 75% in
Year 3 of the transition period; 50% in Year 4 of the transition period; and 25% in Year 5 of the
transition period.
(FFIEC 031): RC-R, Part I, Item 42.b: (Eligible Credit Reserves) – For an institution
subject to the advanced approaches, the institution electing the 2020 CECL transition would
deduct Eligible Credit Reserves Transitional Amount, as defined in section 301 of the agencies’
regulatory capital rules, when calculating this item, adjusted as follows: 100% in Years 1 and 2
of the transition period; 75% in Year 3 of the transition period; 50% in Year 4 of the transition
period; and 25% in Year 5 of the transition period.
RC-R, Part II, Item 8: (All Other Assets) – An institution electing the 2020 CECL
transition would subtract the DTA Transitional Amount, as defined in section 301 of the
agencies’ regulatory capital rules, from the amount of temporary difference DTAs associated
with the AACL that are risk-weighted in this item, adjusted as follows: 100% in Years 1 and 2 of
the transition period; 75% in Year 3 of the transition period; 50% in Year 4 of the transition

period; and 25% in Year 5 of the transition period.
CARES Act Section 4013
Section 4013 of the CARES Act permits banking organizations flexibility in modifying
loans related to COVID-19. The statute also permits the agencies to collect information about the
volume of loans modified under this section. Since the agencies anticipate a significant amount
of activity related to these modifications will occur in the second quarter, the agencies are
requesting emergency clearance to add a new reporting item for these loans.
Reporting Revisions
While the agencies are interested in the balance of loans modified in the first quarter, it is
not operationally feasible to add a new item, as the first quarter reporting forms have already
been published. Therefore, a new data item would be added to the Call Report, Schedule RC-C,
starting in the second quarter of 2020. The agencies would tentatively add this as new
memorandum item 17. Banks would be required to report the ending balance of any loans
modified under this section of the statute.
16.

Provide information regarding plans for publication of data.

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.
17.

If seeking approval to not display the expiration date for OMB approval of the
information collection, explain the reasons that display would be inappropriate.
No such approval is sought.

18.

Explain each exception to the topics of the certification statement identified in
“Certification for Paperwork Reduction Act Submissions.”
There are no exceptions.