Insured financial institutions must
provide quarterly reports of condition and income to the
appropriate regulatory for supervisory, surveillance, regulatory,
research, insurance assessment and informational purposes. Section
331(b) of the Dodd-Frank Act required the FDIC to amend its
regulations to redefine the assessment base used for calculating
deposit insurance assessments as average consolidated total assets
minus average tangible equity. In order for the FDIC to calculate
deposit insurance assessments under the final rule implementing
Section 331(b) of the Dodd-Frank Act and the revised large
institution assessment system, the FDIC needs certain information
not currently collected from insured depository institutions. The
best method for obtaining this information would be through
revisions to the current collections of information. These
revisions involve the addition of new items to be completed by all
insured depository institutions to support the measurement of the
redefined assessment base, as well as new items applicable only to
institutions subject to the revised large institution assessment
system that will be used as inputs to the scorecard measures that
determine the initial base assessment rates for these institutions.
These new items would be added to these information collections
effective June 30, 2011, the first quarter-end report date
following the effective date of the FDIC's February 2011 final rule
amending its assessment regulations. On March 16, 2011, the
agencies published an initial 60-day PRA Federal Register notice in
which they requested comment on proposed revisions to these
regulatory reports that would provide the data needed by the FDIC
to implement the provisions of the February 2011 final rule
beginning with the June 30, 2011, report date. The new data items
proposed in the initial PRA notice were linked to specific
requirements in the FDIC's amended assessment regulations. The
draft instructions for these proposed new items incorporated the
definitions in and other provisions of these regulations.
Accordingly, the FDIC and the other agencies did not anticipate
receiving material comments on the reporting changes proposed in
their March 2011 initial PRA notice. However, commenters stated
that institutions generally do not maintain data on these loans in
the manner in which these two loan categories are defined for
assessment purposes in the FDIC's final rule, or do not have the
ability to capture the prescribed data to enable them to identify
these loans in time to file their regulatory reports for the June
30, 2011, report date. This unanticipated outcome at the end of the
public comment process for the agencies' March 2011 initial PRA
notice led the FDIC to consider and adopt reporting approaches that
addressed institutions' concerns about their ability to identify
loans meeting the subprime and leveraged loan definitions in the
FDIC's assessments final rule, while also meeting the objectives of
the revised large institution assessment system.
The unanticipated
outcome at the end of the public comment process for the agencies
March 2011 initial 60-day PRA notice required the FDIC to consider
possible reporting approaches that would address institutions
concerns about their ability to identify loans meeting the subprime
and leveraged loan definitions in the FDICs assessments final
rule, while also meeting the objectives of the revised large
institution assessment system. However, the consequence of the
unexpected need to develop and reach agreement on a workable
transition approach for identifying loans that are to be reported
as subprime or leveraged for assessment purposes is that the
agencies use of normal clearance procedures for the
assessment-related reporting changes to the Call Report, TFR, and
FFIEC 002/002S reports is reasonably likely to prevent or disrupt
the initial collection of these new assessment data as of the June
30, 2011, report date as called for under the FDICs final rule.
Absent OMB approval to implement these reporting changes as of June
30, 2011, community banks will experience a delay in the shifting
of a portion of the overall deposit insurance assessment burden
away from them, which was the intent of Section 331(b) of the
Dodd-Frank Act.
US Code:
12
USC 1817(a) Name of Law: Federal Deposit Insurance Act
US Code: 12 USC 1817(a) Name of Law:
Dodd-Frank Act
The change in burden associated
with this request for emergency clearance is caused by two factors:
(1) the FDIC's implementation of a final rule adopted February 7,
2011, that (a) redefines the assessment base for insured depository
institutions in accordance with Section 31(b) of the Dodd-Frank Act
and (b) revises the system used to set assessment rates for "large
institutions" and "highly complex institutions" by using a
scorecard that combines CAMELS ratings and certain forward-looking
financial measures to assess the risk such institutions pose to the
DIF, and (2) a net decrease in the number of reporting institutions
supervised by the FDIC. Currently, there are 4,687 FDIC-supervised
banks submitting quarterly Call Reports. This number is 26 less
than previously reported (4,713 previously versus 4,687 now).
Because of the extremely small number of FDIC-supervised banks that
are large or highly complex institutions for assessment purposes in
comparison to the overall number of FDIC-supervised banks, the FDIC
estimates that the overall effect of the proposed
assessment-related reporting revisions across the range of banks
under its supervision would be an average increase of 0.05 hours
per response. The analysis of the change in burden is as follows:
Currently-approved burden: 761,998 hours Revisions to
assessment-related data (program change): +938 hours Adjustment
(change in estimate): -4,204 hours Requested (new) burden: 758,732
hours Net change in burden: -3,266 hours
On behalf of this Federal agency, I certify that
the collection of information encompassed by this request complies
with 5 CFR 1320.9 and the related provisions of 5 CFR
1320.8(b)(3).
The following is a summary of the topics, regarding
the proposed collection of information, that the certification
covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a
benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control
number;
If you are unable to certify compliance with any of
these provisions, identify the item by leaving the box unchecked
and explain the reason in the Supporting Statement.
Form FFIEC 031 Consolidated Reports of Condition and Income (Call Report)
Request for Emergency Clearance Letter 3064-0052 6-16-11.pdf
SST-0052_Call_Report__611xSupportingStatement_061611[1].doc
Consolidated Reports of Condition and Income (Call Report)