Justification for No Material/Nonsubstantive Change

Justification for No Material/Nonsubstantive Change

Call Report IC

OMB 3064-0052

Background

In 2010, pursuant to the Dodd-Frank Act, we added two items to the Call Report (FDIC’s 3064-0052 collection), requiring banks with $1 billion or more in total assets to report quarterly the number of transactional accounts with balances in excess of $250,000 and the aggregate amount of funds in those accounts.  We planned and announced in our federal register notices in 2010 that we would stop collecting this data upon expiration of the FDIC’s unlimited deposit insurance coverage on noninterest-bearing transactional accounts over $250,000.  Although bills were introduced to extend this coverage beyond 2012, Congress ultimately decided not to extend this unlimited insurance coverage.  However, the regulators have learned that this additional information is valuable to track and analyze movement of these large deposits to inform financial regulatory policy making.  Also, the banking industry, particularly banking trade groups, is interested in continuing to receive this information.  These two items are already in the Call Report, and the insignificant incremental burden (about 1% of Call Report burden for FDIC) is already baked into our current Call Report burden. Without continued reporting of noninterest-bearing transaction accounts larger than $250,000, the agencies, insured depository institutions, and other interested parties will be unable to monitor the behavior of these deposit accounts following the end of their unlimited insurance coverage and its effect on both individual institutions and the depository institution system as a whole.