On December 3, BPI submitted a comment letter to the Fed, OCC, and FDIC responding to proposed reporting revisions to the Call Reports and the FFIEC 101 (reporting of risk-weighted assets under the advanced approaches). The letter does not support adoption as proposed of the expansion in the scope of the Call Report for insured depository institution subsidiaries or the proposed change in reporting of home equity lines of credit that convert from revolving to non-revolving status in view of the potential significant operational challenges associated with these proposed changes. The letter encourages the agencies to eliminate supplementary leverage ratio data reporting tables from the FFIEC 101 and to provide an eighteen-month implementation period for the proposed reporting changes to the Call Reports related to the Total Loss Absorbing Capacity Holdings rule.
You Might Also Be Interested In...
Regulatory Reporting and Accounting BPI Submits Comment Letter to Banking Agencies on Revisions to Call Report
Bank Capital and Stress Testing Some Thoughts on the Bank Regulatory Picture: Dividends, CECL, Buffers and the Rest
Regulatory Reporting and Accounting BPI Submits Comment Letter to Agencies on Call Report and FFIEC 101 Reporting Revisions
Regulatory Reporting and Accounting BPI Submits Comment Letter to the Fed on Proposed FR Y-9 Reporting Revisions
More Posts by This Author
FinTech & Innovation Central Bank Digital Currencies: Costs, Benefits and Major Implications for the U.S. Economic System
Central Bank Digital Currency The Benefits and Costs of a Central Bank Digital Currency for Monetary Policy
Bank Activities and Structure BPI President and CEO Greg Baer Submits Formal Statement for HFSC Subcommittee Hearing Examining Trends in Financial Institution Charters
Bank Conditions and Credit Availability BPI and Industry Coalition Encourage Federal Legislation to Address ‘Tough Legacy’ Contracts
Security BPI and Coalition of Trades Express Support for Computer-Security Incident Notification Rulemaking Effort and Recommend Important Changes to Better Align the Proposal to the Intended Outcomes
Bank Conditions and Credit Availability Federal Legislation Would Save ‘Tough Legacy’ Contracts from LIBOR Limbo