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 FDICÂs 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 FDICÂs 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
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)