FFIEC031_FFIEC041_FFIEC051_20170302_omb

Supporting Statement for the
Consolidated Reports of Condition and Income
(FFIEC 031, FFIEC 041, and FFIEC 051; OMB No. 7100-0036)
Summary
The Board of Governors of the Federal Reserve System (Board) requests approval from
the Office of Management and Budget (OMB) to extend for three years, with revision, the
Federal Financial Institutions Examination Council (FFIEC) Consolidated Reports of Condition
and Income (Call Reports) (FFIEC 031 and FFIEC 041; OMB No. 7100-0036). These data 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 requires information collected on the Call Reports to fulfill its statutory
obligation to supervise state member banks. State member banks are required to file both
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, the FDIC, and the OCC (the agencies) propose to revise the Call Reports to
be submitted on or after April 1, 2017, beginning with the reports reflecting the March 31, 2017,
report date, by (1) creating a new Consolidated Reports of Condition and Income for a Bank with
Domestic Offices Only and Total Assets Less than $1 Billion (FFIEC 051) and (2) revising some
schedules on the FFIEC 031 and FFIEC 041 by removing data items or subjecting institutions to
new or higher reporting thresholds.. The current annual burden for the Call Reports is estimated
to be 197,637 hours and the proposed revisions are estimated to decrease the annual burden by
19,437 hours.
Background and Justification
Banks that are members of the Federal Reserve System are required by law to file reports
of condition with the Federal Reserve System. Section 9(6) of the Federal Reserve Act
(12 U.S.C. § 324) states:
... banks ... shall be required to make reports of condition and of the payment of dividends
to the Federal Reserve Bank of which they become a member. Not less than three of
such reports shall be made annually on call of the Federal Reserve Bank on dates to be
fixed by the Board of Governors of the Federal Reserve System. ...Such reports of
condition shall be in such form and shall contain such information as the Board of
Governors of the Federal Reserve System may require and shall be published by the
reporting banks in such manner and in accordance with such regulations as the said Board
may prescribe.

In discharging this statutory responsibility, the Board of Governors, acting in concert
with the other federal banking supervisory agencies since 1979 through the FFIEC, requires
banks to submit on the quarterly Reports of Condition and Income such financial data as are
needed by the Federal Reserve System to: (1) supervise and regulate banks through monitoring
of their financial condition, ensuring the continued safety of the public’s monies and the overall
soundness of the nation’s financial structure, and (2) contribute information needed for
background for the proper discharge of the Federal Reserve’s monetary policy responsibilities.
The use of the data is not limited to the federal government, but extends to state and local
governments, the banking industry, securities analysts, and the academic community.
Description of Information Collection
The Call Reports 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.
Within the Call Report information collection system as a whole, there are two reporting
forms that apply to different categories of banks: (1) all banks that have domestic and foreign
offices (FFIEC 031), and (2) banks with domestic offices only (FFIEC 041). Prior to March
2001, there were four categories of banks and four reporting forms. The FFIEC 031 was filed by
banks with domestic and foreign offices and the FFIEC 032, FFIEC 033, and FFIEC 034 were
filed by banks with domestic offices only and were filed according to the asset size of the bank.
There is no other series of reporting forms that collect from all commercial and savings
banks the information gathered through the Reports of Condition and Income. There are other
information collections that tend to duplicate certain parts of the Call Reports; however, the
information they provide would be of limited value as a replacement for the Call Reports. For
example, the Board collects various data in connection with its measurement of monetary
aggregates, of bank credit, and of flow of funds. Reporting banks supply the Board with detailed
information relating to such balance sheet accounts as balances due from depository institutions,
loans, and deposit liabilities. The Board also collects financial data from bank holding
companies on a regular basis. Such data are presented for the holding company on a
consolidated basis, including its banking and nonbanking subsidiaries, and on a parent company
only basis.
However, Board reporting forms from banks are frequently obtained on a sample basis
rather than from all insured banks. Moreover, these reporting forms are often prepared as of
dates other than the last business day of each quarter, which would seriously limit their
comparability. Institutions below a certain size are exempt entirely from some Board reporting
requirements. Data collected from bank holding companies on a consolidated basis reflect an
aggregate amount for all subsidiaries within the organization, including banking and nonbanking
subsidiaries, so that the actual dollar amounts applicable to any bank subsidiary are not
determinable from the holding company reporting forms. Hence, these reporting forms could not
be a viable replacement for even a significant portion of the Call Reports since the Board, in its
role as supervisor of insured state member banks, would be lacking the data necessary to assess

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the financial condition of individual insured banks to determine whether there had been any
deterioration in their condition.
Beginning March 1998, all banks were required to transmit their Call Report data
electronically. Banks do not have to submit hard copy Call Reports to any federal bank
supervisory agency unless specifically requested to do so.
Proposed Revisions
As the result of a formal initiative launched by the FFIEC in December 2014 to identify
potential opportunities to reduce burden associated with Call Report requirements for community
banks, the agencies are proposing a new streamlined Call Report (FFIEC 051) for eligible small
institutions and revisions to the existing versions of the Call Report (FFIEC 031 and FFIEC 041).
In embarking on this effort, the FFIEC is responding to industry concerns about the cost and
burden associated with the Call Report. The FFIEC’s formal initiative includes actions in five
areas,1 three of which have served as the foundation for the proposed FFIEC 051. These three
actions, discussed below, include community bank outreach, surveys of agency Call Report data
users, and consideration of a more streamlined Call Report for eligible small institutions. In
addition, as a framework for the actions it is undertaking, the FFIEC developed a set of guiding
principles for use in evaluating potential additions and deletions of Call Report data items and
other revisions to the Call Report. In general, data items collected in the Call Report must meet
three guiding principles: (1) the data items serve a long-term regulatory or public policy purpose
by assisting the FFIEC member entities in fulfilling their missions of ensuring the safety and
soundness of financial institutions and the financial system and the protection of consumer
financial rights, as well as agency-specific missions affecting national and state-chartered
institutions; (2) the data items to be collected maximize practical utility and minimize, to the
extent practicable and appropriate, burden on financial institutions; and (3) equivalent data items
are not readily available through other means.
FFIEC’s Community Bank Call Report Burden-Reduction Initiative
Community Bank Outreach
As one of the actions under the FFIEC’s community bank Call Report burden-reduction
initiative, the agencies conducted and participated in several outreach efforts to better
understand, through industry dialogue, the aspects of reporting institutions’ Call Report process
that are significant sources of reporting burden, including where manual intervention by an
institution’s staff is necessary to report particular information. As an initial step toward
improving this understanding, representatives from the FFIEC member entities visited nine
community institutions during the third quarter of 2015. In the first quarter of 2016, two bank
trade groups, the Independent Community Bankers of America and the American Bankers
Association, each organized a number of conference call meetings with small groups of
community bankers in which representatives from the FFIEC member entities participated.
During the visits to banks and the conference call meetings, the community bankers explained
1

See 80 FR 56539 (September 18, 2015) and 81 FR 45357 (July 13, 2016) for information on other actions taken
under this initiative.

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how they prepare their Call Reports, identified which schedules or data items take a significant
amount of time and/or manual processes to complete, and described the reasons for this. The
bankers also offered suggestions for streamlining the Call Report.
The agencies note that during the banker outreach calls, as well as in comment letters
submitted under a review of agency regulations required by the Economic Growth and
Regulatory Paperwork Reduction Act (EGRPRA),2 they received many comments about the
burden of reporting in accordance with the revised regulatory capital rules in Call Report
Schedule RC-R – Regulatory Capital. The agencies revised this schedule in March 2015 to
include the data items that would be necessary for an institution to calculate its regulatory capital
ratios under the revised capital rules. The greater detail of those rules requires a degree of
categorization, recordkeeping, and reporting that is greater than under the prior applicable capital
rules. The FFIEC, through its Task Force on Reports (task force), is monitoring the banking
agencies’ response to the concerns about the revised regulatory capital rules raised during the
EGRPRA comment process and the associated reporting burden of Schedule RC-R arising from
the implementation of those rules by community banks.
The agencies also note that during the banker outreach calls and visits, they received
many comments addressing the substantive burden arising from reviewing the Call Report
instructions on a quarterly or other periodic basis even for those data items applicable to an
institution for which the institution determines that there is no information for it to report. The
agencies’ burden estimates for the Call Report include estimated time for reviewing instructions,
gathering and maintaining data in the required form, and completing those Call Report data items
for which an institution has a reportable (nonzero) amount. Consistent with past practice, the
agencies’ burden estimates do not reflect burden associated with an institution’s time for
reviewing the instructions for applicable data items for which an institution does not have
reportable amounts. Therefore, the agencies’ burden estimates do not reflect the burden
reduction associated with an institution no longer having to review the instructions for those
applicable data items without reportable amounts that the agencies are proposing to remove from
the Call Report. Further, as noted previously, the estimated burden per response is an average
estimate for all filers of the Call Report. This estimate does not separately distinguish between
the FFIEC 031, FFIEC 041, and the proposed FFIEC 051 versions of the Call Report. The
agencies will consider revising the methodology for estimating burden hours and preparing
separate burden estimates for the FFIEC 031, FFIEC 041, and FFIEC 051 reports.
Acceleration of the Statutorily Mandated Review of the Call Report
As a second action, the agencies accelerated the start of the next statutorily mandated
review of the existing Call Report data items (Full Review),3 which otherwise would have
commenced in 2017. Users of Call Report data items at the FFIEC member entities are
participating in a series of nine surveys conducted over a 19-month period that began in mid-July
2015. As an integral part of these surveys, users are asked to fully explain the need for each Call
2

EGRPRA requires the federal banking agencies to conduct a decennial joint review of their regulations to identify
those that are outdated, unnecessary, or unduly burdensome.
3
This review is mandated by section 604 of the Financial Services Regulatory Relief Act of 2006 (12 U.S.C.
1817(a)(11)).

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Report data item they deem essential, how the data item is used, the frequency with which it is
needed, and the population of institutions from which it is needed. Call Report schedules have
been placed into nine groups and prioritized for review, generally based on level of burden cited
by banking industry representatives. Based on the results of the surveys, the agencies are
identifying data items that are being considered for elimination, less frequent collection, or new
or upwardly revised reporting thresholds. The results of the first three surveys have been
incorporated into this proposal. Burden-reducing reporting changes from the remaining six
surveys will be proposed in future Federal Register notices with an anticipated March 31, 2018,
implementation date for submissions on or after April 1, 2018.
Consideration of a More Streamlined Call Report for Eligible Small Institutions
As a third action, the agencies considered the feasibility and merits of creating a less
burdensome version of the quarterly Call Report for institutions that meet certain criteria.
Together with the outcomes of the preceding two actions to date, the results of this action are the
subject of this proposal, i.e., the FFIEC 051 Call Report for eligible small institutions, which is
summarized in the overview below.
Overview
Under the auspices of the FFIEC and its task force, the agencies collectively reviewed the
feedback from the previously mentioned banker outreach efforts completed in 2015 and 2016 as
one of the inputs for developing a proposal to address industry concerns about the regulatory
reporting burden imposed on institutions by the Call Report. In addressing these concerns, the
agencies aimed to balance institutions’ requests for a less burdensome regulatory reporting
process with FFIEC member entities’ need for sufficient data to monitor the condition and
performance of, and ensure the safety and soundness of, institutions and carry out agencyspecific missions. With these two goals in mind, the task force developed, and the FFIEC and
the agencies agreed to propose, a separate, more streamlined, and noticeably shorter Call Report
to be completed by eligible small institutions as well as certain burden-reducing revisions to the
current FFIEC 031 and FFIEC 041 versions of the Call Report. The agencies recognize that
institutions operate under widely varying business models, which affects the nature and extent of
their activities and translates into differences in the amount of information to be reported in their
Call Reports.
The proposed FFIEC 051 is a streamlined version of the existing Consolidated Reports of
Condition and Income for a Bank with Domestic Offices Only (FFIEC 041), which was created
by (1) removing certain existing schedules and data items and replacing them with a limited
number of data items in a new supplemental schedule, (2) eliminating certain other existing data
items, and (3) reducing the reporting frequency of certain data items. The FFIEC 051 generally
would be available to institutions with domestic offices only and assets of less than $1 billion,
which currently file the FFIEC 041. Of the nearly 6,000 insured depository institutions,
approximately 5,200 would be eligible to file the proposed FFIEC 051. When compared to the
existing FFIEC 041, the proposed FFIEC 051 shows a reduction in the number of pages from 85
to 61. This decrease is the result of the removal of approximately 950 or about 40 percent of the
nearly 2,400 data items in the FFIEC 041. Of the data items remaining from the FFIEC 041, the

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agencies have reduced the reporting frequency for approximately 100 data items in the proposed
FFIEC 051.
For purposes of the FFIEC 051 Call Report, the agencies propose to define “eligible
small institutions” as institutions with total assets less than $1 billion and domestic offices only.4
These institutions currently file the FFIEC 041 Call Report. Eligible small institutions would
have the option to file the FFIEC 041 Call Report rather than the FFIEC 051. In addition, for a
small institution otherwise eligible to file the FFIEC 051, the institution’s primary federal
regulatory agency, jointly with the state chartering authority, if applicable, may require the
institution to file the FFIEC 041 instead based on supervisory needs. In determining whether an
institution with less than $1 billion in total assets should be required to file the FFIEC 041 rather
than the FFIEC 051, the appropriate agency will consider criteria including, but not limited to,
whether the eligible institution is significantly engaged in complex, specialized, or other highrisk activities.5 It is anticipated that such determinations would be made in a limited number of
cases.
The existing Call Report instructions generally provide that shifts in an institution’s
reporting status are to begin with the March Call Report based on the institution’s consolidated
total assets as reported in the Call Report for June of the previous calendar year. Applying this
principle to the FFIEC 051, an institution with domestic offices only would be eligible to file the
FFIEC 051 Call Report reflecting the March 31, 2017, report date, which are to be submitted on
or after April 1, 2017, if it reported consolidated total assets of less than $1 billion in its Call
Report for June 30, 2016.
Thereafter, if the total assets of an institution with domestic offices only that files the
FFIEC 051 Call Report increase to $1 billion or more as of a June 30 report date, it would no
longer be eligible to file the FFIEC 051 Call Report beginning as of the March 31 report date the
following year. The institution would instead begin to file the FFIEC 041 report.6
In developing the proposed FFIEC 051 for eligible small institutions, the data items
currently collected in the FFIEC 041, including individual schedules, were reviewed to
determine how the existing reporting requirements could be modified to make the information in
the Call Report more applicable to and less burdensome for smaller, noncomplex institutions
without adversely affecting FFIEC member entities’ data needs. As a result of this interagency
review, the following changes were made to the FFIEC 041 report form to create the proposed
FFIEC 051 and are discussed in detail below:
• The addition of a Supplemental Schedule to collect indicator questions and indicator data
4

As part of this initiative, the agencies are committed to exploring alternatives to the $1 billion asset-size threshold
that could extend the eligibility to file the FFIEC 051 to additional institutions.
5
This proposed reservation of authority is consistent with the reservation of authority applicable to a holding
company with consolidated total assets of less than $1 billion that would otherwise file the Board’s FR Y-9SP,
Parent Company Only Financial Statements for Small Holding Companies (OMB Control No. 7100-0128). See
page GEN-1 of the instructions for the FR Y-9SP.
6
Consistent with the existing Call Report instructions, if an institution reaches $1 billion or more in consolidated
total assets due to a business combination, a transaction between entities under common control, or a branch
acquisition that is not a business combination, then the institution must file the FFIEC 041 Call Report beginning
with the first quarter-end report date following the effective date of the transaction.

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•
•

items on certain complex and specialized activities as a basis for removing partial or
entire schedules (and other related items) which are currently included in the FFIEC 041,
The elimination of data items identified as no longer necessary for collection from
institutions with less than $1 billion in total assets and domestic offices only during the
completed portions of the Full Review or during a separate interagency review that
focused on data items infrequently reported by institutions of this size,
Changes to the frequency of data collection for certain items identified as needed less
often than quarterly from institutions with less than $1 billion in total assets and domestic
offices only, and
Removal of all data items for which a $1 billion asset-size reporting threshold currently
exists.

In addition, the agencies plan to prepare a separate, shorter set of Instructions for
Preparation of Consolidated Reports of Condition and Income for users of the FFIEC 051, which
would be published by the beginning of the quarterly reporting period in which the FFIEC 051
takes effect.
In designing the proposed FFIEC 051 Call Report, the agencies have sought to maintain,
to the extent possible, the existing structure of the FFIEC 041 Call Report, including the
numbering and sequencing of data items within Call Report schedules. Institutions and their
staff members involved in the preparation of the Call Report are familiar with how the
FFIEC 041 Call Report is currently organized. Feedback from banker outreach activities
indicated that they did not favor the rearranging of existing data items that would be retained in a
streamlined Call Report for small institutions because the need to adapt to these structural
changes would itself be burdensome.
The statutorily mandated review of the existing Call Report data items is an ongoing
process. The agencies have included certain proposed revisions to the existing FFIEC 031 and
FFIEC 041 Call Reports based on the task force’s evaluation of the results of the first three
surveys of Call Report users at FFIEC member entities are included in this notice. Additional
changes to the FFIEC 031, the FFIEC 041, and the FFIEC 051 will be proposed in future
Federal Register notices after the conclusion of the remaining user surveys.
Discussion of Proposed Call Report Revisions to Create the FFIEC 051
Replacement of Partial or Entire Schedules with a Supplemental Schedule
The FFIEC 041 Call Report schedules requiring the reporting of data on activities
considered complex or specialized were identified and reviewed to determine which schedules
(or portions of schedules) could be eliminated from the FFIEC 051 and replaced with questions
asking whether the institution engages in any of these complex or specialized activities along
with corresponding indicator data items that would be completed for those activities in which the
institution engages. The indicator data items would provide aggregate data specific to the
identified complex or specialized activity, allowing users of the Call Report at FFIEC member
entities to ascertain the degree to which an institution engages in such activity. The following is
a list of the identified schedules and activities along with the related proposed indicator questions

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and data items that would be included in a new Schedule SU in the FFIEC 051 Call Report:
• Derivatives data currently collected on Schedule RC-L – Derivatives and Off-Balance
Sheet Items and in certain other schedules would be eliminated from the FFIEC 051
(except from Schedule RC-R – Regulatory Capital) and replaced with the following
indicator question and data items:
o Does the institution have any derivative contracts? (If yes, complete the following
items.)
o Total gross notional amount of interest rate derivatives held for trading
o Total gross notional amount of all other derivatives held for trading
o Total gross notional amount of interest rate derivatives not held for trading
o Total gross notional amount of all other derivatives not held for trading
• Schedule RC-D – Trading Assets and Liabilities would be eliminated from the
FFIEC 051. Indicator questions and data items are not necessary because total trading
assets and total trading liabilities are reported on Schedule RC – Balance Sheet.
• Schedule RC-P – 1-4 Family Residential Mortgage Banking Activities would be
eliminated from the FFIEC 051 and replaced with the following indicator question and
data items:
o For the two calendar quarters preceding the current calendar quarter, have either the
institution’s sales of 1-4 family residential mortgage loans during the quarter or its 14 family residential mortgage loans held for sale or trading as of quarter-end
exceeded $10 million? (If yes, complete the following items.)
o Principal amount of 1-4 family residential mortgage loans sold during the quarter
o Quarter-end amount of 1-4 family residential mortgage loans held for sale or trading
• Schedule RC-Q – Assets and Liabilities Measured at Fair Value on a Recurring Basis
would be eliminated from the FFIEC 051 and replaced with the following indicator
question and data items:
o Does the institution use the fair value option to measure any of its assets or liabilities?
(If yes, complete the following items.)
o Aggregate amount of fair value option assets
o Aggregate amount of fair value option liabilities
o Year-to-date net gains (losses) recognized in earnings on fair value option assets
o Year-to-date net gains (losses) recognized in earnings on fair value option liabilities
• Schedule RC-S – Servicing, Securitization, and Asset Sale Activities would be eliminated
from the FFIEC 051 and replaced with the following indicator questions and data items:
o Does the institution have any assets it has sold and securitized with servicing retained
or with recourse or other seller-provided credit enhancements? (If yes, complete the
following item.)
o Total outstanding principal balance of assets sold and securitized by the reporting
institution with servicing retained or with recourse or other seller-provided credit
enhancements
o Does the institution have any assets it has sold with recourse or other seller-provided
credit enhancements but has not securitized? (If yes, complete the following item.)
o Total outstanding principal balance of assets sold by the reporting institution with
recourse or other seller-provided credit enhancements, but not securitized by the
reporting institution
o Does the institution service any closed-end 1-4 family residential mortgage loans for

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•

•

others or does it service more than $10 million of other financial assets for others? (If
yes, complete the following item.)
o Total outstanding principal balance of closed-end 1-4 family residential mortgage
loans serviced for others plus the total outstanding principal balance of other financial
assets serviced for others if more than $10 million
To note, the item related to the credit card fees and finance charges will be addressed
in the Credit Card Lending Specialized Items section, below.
Schedule RC-V – Variable Interest Entities would be eliminated from the FFIEC 051 and
replaced with the following indicator question and data items:
o Does the institution have any consolidated variable interest entities? (If yes, complete
the following items.)
o Total assets of consolidated variable interest entities
o Total liabilities of consolidated variable interest entities
Credit Card Lending Specialized Items included in Schedule RI-B – Charge-offs and
Recoveries on Loans and Leases and Changes in Allowance for Loan and Lease Losses;
Schedule RC C – Loans and Lease Financing Receivables; and Schedule RC-S –
Servicing, Securitization, and Asset Sale Activities would be replaced with the following
indicator question and data items:
o Does the institution, together with affiliated institutions, have outstanding credit card
receivables that exceed $500 million as of the report date or is the institution a credit
card specialty bank as defined for Uniform Bank Performance Report (UBPR)
purposes? (If yes, complete the following items.)
o Outstanding credit card fees and finance charges included in credit cards to
individuals for household, family, and other personal expenditures (retail credit cards)
o Separate valuation allowance for uncollectible retail credit card fees and finance
charges
o Amount of allowance for loan and lease losses attributable to retail credit card fees
and finance charges
o Uncollectible retail credit card fees and finance charges reversed against year-to-date
income
o Outstanding credit card fees and finance charges included in retail credit card
receivables sold and securitized with servicing retained or with recourse or other
seller-provided credit enhancements
FDIC Loss-Sharing Agreement data items included in Schedule RC-M – Memoranda,
and Schedule RC-N – Past Due and Nonaccrual Loans, Leases, and Other Assets would
be eliminated from the FFIEC 051 and replaced with the following indicator question and
data items:
o Does the institution have assets covered by FDIC loss-sharing agreements? (If yes,
complete the following items.)
o Loans and leases covered by FDIC loss-sharing agreements
o Past due and nonaccrual loans and leases covered by FDIC loss-sharing agreements,
with separate reporting of loans and leases past due 30-89 days and still accruing,
loans and leases past due 90 days or more and still accruing, and nonaccrual loans and
leases
o Portion of past due and nonaccrual covered loans and leases protected by FDIC losssharing agreements, with separate reporting of loans and leases past due 30-89 days

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and still accruing, loans and leases past due 90 days or more and still accruing, and
nonaccrual loans and leases
o Other real estate owned covered by FDIC loss-sharing agreements
o Portion of covered other real estate owned that is protected by FDIC loss-sharing
agreements
Elimination of Data Items Identified during the Statutorily Mandated Full Review of the
Call Report and the Review of Infrequently Reported Items
Several of the existing Call Report schedules have been reviewed as part of the Full
Review of the Call Report. The resulting burden-reducing changes relevant to institutions with
less than $1 billion in total assets and domestic offices only have been incorporated into the
proposed FFIEC 051. The schedules reviewed to date include:
• Schedule RI – Income Statement
• Schedule RC – Balance Sheet
• Schedule RC-C – Loans and Lease Financing Receivables
• Schedule RI-B – Charge-offs and Recoveries on Loans and Leases and Changes in
Allowance for Loan and Lease Losses
• Schedule RC-N – Past Due and Nonaccrual Loans, Leases, and Other Assets
• Schedule RC-E – Deposit Liabilities
• Schedule RC-O – Other Data for Deposit Insurance and FICO Assessments
This proposal also includes revisions to some of these schedules in the FFIEC 031 and
FFIEC 041 Call Reports as a result of the Full Review. Going forward, the data items in all
other Call Report schedules will continue to be evaluated as part of the Full Review.
As another component of this initiative, data items infrequently reported in the
FFIEC 041 Call Report by banks with total assets less than $1 billion and domestic offices only
were reviewed by the FFIEC member entities to determine which of these items remain
necessary for monitoring the safety and soundness of, and meeting agency mission-specific
needs with respect to, such smaller, less complex institutions. Of these data items, those deemed
no longer essential were excluded from the FFIEC 051.
In the proposed FFIEC 051 Call Report, the following schedules would have data items
removed as a result of the completed portions of the statutorily mandated Full Review or the
review of infrequently reported items:
• Schedule RI – Income Statement
• Schedule RI-B – Charge-offs and Recoveries on Loans and Leases and Changes in
Allowance for Loan and Lease Losses
• Schedule RC-C – Loans and Lease Financing Receivables
• Schedule RC-E – Deposit Liabilities
• Schedule RC-L – Derivatives and Off-Balance Sheet Items
• Schedule RC-N – Past Due and Nonaccrual Loans, Leases, and Other Assets
The agencies note that during the previously mentioned banker outreach efforts, some
community banks specifically cited Schedule RC-C, Part I – Loans and Leases, as a particularly

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burdensome schedule to complete. Many of these banks also indicated that completing this
schedule requires a significant degree of manual intervention.
Call Report data serve a regulatory or public policy purpose by assisting the FFIEC
member entities in fulfilling their missions of ensuring the safety and soundness of financial
institutions and the financial system and the protection of consumer financial rights, as well as
agency-specific missions. These agency needs are particularly evident for data collected on
Schedule RC-C, Part I.
Loan and lease data are critical inputs to assessing the safety and soundness of financial
institutions through analysis of the institutions’ management of credit risk, interest rate risk, and
liquidity risk, including the analysis of lending concentrations and earnings. Further,
standardization of loan categories across the schedules within the Call Report is essential for peer
group analysis and industry analysis. Loan and lease information is also an important
component of agency statistical models that assess the risk profile of an institution, including its
risk of failure.
Finally, loan and lease information assists the agencies in fulfilling their specific
missions. The Federal Reserve, as part of its monetary policy mission, relies on institutionspecific Call Report data to provide information on credit availability and lending conditions not
available elsewhere. Loan and lease detail at all sizes of institutions are necessary for
policymaking purposes addressing the overall health of the economy.
In general, monetary policy initiatives function most effectively when implemented early
during a period of credit constraint, with the responses tailored to the types of institutions
affected, using standardized loan information only available from Call Reports. Reducing loan
detail or data frequency for smaller institutions could potentially derail these efforts by delaying
the identification of the start of an economic downturn as well as determinations of the
effectiveness of any monetary policy changes. Furthermore, Schedule RC-C, Part I, data are
used to benchmark weekly loan data collected from a sample of both small and large institutions
that are the source for estimating weekly loan aggregates that serve as a more timely and critical
input for monetary policymaking purposes.
The FDIC’s deposit insurance assessment system for “established small banks” relies on
information reported by individual institutions for the Schedule RC-C, Part I, standardized loan
categories in the determination of the loan mix index in the financial ratios method, as recently
amended, which is used to determine assessment rates for such institutions.7
Notwithstanding the above discussion of the agencies overall needs for information
collected on Schedule RC-C, Part I, the agencies have identified 23 data items as having lesser
utility for these purposes.
Changes to the Frequency of Data Collection
The FFIEC member entities have reviewed existing data items in the FFIEC 041 Call
7

See 81 FR 323186-32188 and 32208 (May 20, 2016).

11

Report that would be retained in the FFIEC 051 to determine whether some of these data items
could be collected less frequently than quarterly from eligible small institutions without
adversely affecting the agencies’ data needs. Data items would be collected in the FFIEC 051 on
a less than quarterly basis if they are deemed not necessary for quarterly collection for a
supervisory, surveillance, monitoring, or agency mission-specific purpose relevant to institutions
with total assets of less than $1 billion and domestic offices only.
The following Call Report schedules in the proposed FFIEC 051 would have data items
that have had a change in the frequency of data collection from quarterly to semiannually or
annually:
• Schedule RI – Income Statement
• Schedule RC-B – Securities
• Schedule RC-A – Cash and Balances Due from Depository Institutions
• Schedule RC-C – Loans and Lease Financing Receivables
• Schedule RC-F – Other Assets
• Schedule RC-G – Other Liabilities
• Schedule RC-L – Derivatives and Off-Balance Sheet Items
• Schedule RC-M – Memoranda
• Schedule RC-N – Past Due and Nonaccrual Loans, Leases, and Other Assets
The agencies note that during the previously mentioned banker outreach efforts, some
community banks specifically cited Schedule RC-C, Part II – Loans to Small Businesses and
Small Farms, as a particularly burdensome schedule to complete. Many of these banks also
indicated that their reported values on this schedule did not vary significantly from quarter to
quarter, and inquired whether the reporting frequency could be reduced to annual or semiannual.
In 2010, the FFIEC changed the reporting frequency for Schedule RC-C, Part II, from
annually to quarterly. Call Report small business and small farm lending data are an invaluable
resource for understanding credit conditions facing small businesses. More frequent collection
of these data improves the Board’s ability to monitor credit conditions facing small businesses
and small farms and significantly contributes to its ability to develop policies intended to address
any problems that arise in credit markets. In 2009, the U.S. Department of the Treasury, also
identified a particular need for these data as they worked to develop policies to ensure that more
small businesses and small farms would have access to credit.8 In addition, the Board finds these
data very valuable for monetary policymaking purposes.
The institution-level Call Report data provide information that cannot be obtained from
other indicators of small business and small farm credit conditions. The agencies’ other
indicators of small business credit conditions – including the Board’s Senior Loan Officer
Opinion Survey9 and its Flow of Funds – do not provide the same level of detail that is available
from Call Reports, and therefore cannot be used to answer many questions that naturally arise
during the policy development process. For example, during a period of credit contraction, these
other data sources cannot be used to identify which types of institutions are reducing the volume
of their loans to small businesses and small farms. This is a significant constraint for the Board,
8
9

See 74 FR 41973 (August 19, 2009).
See FR 2018; OMB No. 7100-0058.

12

as having detailed information about the characteristics of affected institutions is crucial to
designing well-targeted and effective policy responses. Moreover, there is evidence that small
business lending by small institutions does not correlate with lending by larger institutions.
Monetary policymaking benefits importantly from more timely information on small
business credit conditions and flows. To determine how best to adjust the federal funds rates
over time, the Board must continuously assess the prospects for real activity and inflation in
coming quarters. Credit conditions have an important bearing on the evolution of those
prospects over time, and so the Board pays close attention to data from Call Reports and other
sources. In trying to understand the implications of aggregate credit data for the macroeconomic
outlook, it is helpful to be able to distinguish between conditions facing small firms and those
affecting other businesses, for several reasons. First, small businesses comprise a substantial
portion of the nonfinancial business sector, and so their hiring and investment decisions have an
important influence on overall real activity.10 Second, because small businesses tend to depend
more heavily on depository institutions for external financing, they likely experience material
swings in their ability to obtain credit relative to larger firms. Third, the relative opacity of small
businesses and their consequent need to provide collateral for loans is thought to create a “credit”
channel for monetary policy to influence real activity. Specifically, changes in monetary policy
may alter the value of assets used as collateral for loans, thereby affecting the ability of small
businesses to obtain credit, abstracting from the effects of any changes in loan rates. Finally, the
credit conditions facing small businesses and small farms differ substantially from those facing
large businesses, making it necessary to collect indicators that are specific to these borrowers.
Large businesses may access credit from a number of different channels, including the corporate
bond market and the commercial paper market. In contrast, small businesses and small farms
rely more heavily on credit provided through the depository institution lending channel. The
dependence of small businesses and small farms on bank lending – particularly from smaller
institutions – magnifies the importance of Call Report data, which provide the most
comprehensive data on depository institution lending to small businesses and small farms, and
emphasizes the importance of collecting quarterly data from institutions of all sizes.
In response to feedback received from banker outreach efforts conducted by the FFIEC
member entities, where a sample of community banks indicated that data reported on Call Report
Schedule RC-C, Part II, does not vary significantly from quarter to quarter, the Board examined
the quarter-to-quarter variation in the Call Report data on small loans to businesses and small
loans to farms since 2010. Although some individual banks may see little variation over time in
these Call Report items, the aggregate data for community banks do vary enough from quarter to
quarter to make a difference in the Board’s sense of what is happening with regard to aggregate
credit availability to small businesses, which is a very important sector of the economy. During
a downturn, this variability is likely to increase. However, the Board recognizes that the very
smallest institutions – those with less than $50 million in total assets – did not contribute
significantly to the quarterly variation. Therefore, the agencies propose to change the frequency
of reporting Schedule RC-C, Part II, in the FFIEC 051 from quarterly to semiannually for banks
with less than $50 million in total assets.
10

Based on statistics tabulated early in the decade, roughly one quarter of all nonfinancial business assets were
outside the corporate sector, and such firms tend to be partnerships and proprietorships, which tend to be small
businesses.

13

Some proponents of reduced reporting frequency for Schedule RC-C, Part II, have
suggested that the agencies could tie the frequency of reporting to the business cycle, with lower
frequency (annually or semiannually) during normal or expansionary times, and quarterly
frequency during a downturn. The agencies do not consider this approach to be feasible because
they generally cannot anticipate a downturn before it starts, and once it has been determined that
a downturn is under way, there would be an inevitable lag in implementing the quarterly
reporting requirement. Furthermore, declines in small business and small farm lending may
precede a downturn in economic activity and serve as a leading indicator of such a downturn,
providing useful information to the agencies for policymaking purposes.
Removal of Data Items for Which a Reporting Threshold Currently Exists
The proposed FFIEC 051 would not include those FFIEC 041 Call Report data items for
which a reporting threshold currently exists that creates an exemption from reporting for banks
with total assets less than $1 billion. The following schedules were affected by the removal of
these data items:
• Schedule RI- Income Statement
• Schedule RI-C – Disaggregated Data on the Allowance for Loan and Lease Losses
• Schedule RC-B – Securities
• Schedule RC-E – Deposit Liabilities
• Schedule RC-L – Derivatives and Off-Balance Sheet Items
• Schedule RC-O – Other Data for Deposit Insurance and FICO Assessments
Preparation of Separate Instructions for the FFIEC 051
The FFIEC and the agencies would create a separate set of Instructions for Preparation of
Consolidated Reports of Condition and Income (FFIEC 051). A combined set of instructions for
the FFIEC 031 and the FFIEC 041 Call Reports would still be maintained. Instructions for
identical data items in the FFIEC 051 and the FFIEC 041 generally would reflect the same text in
both sets of instructions. Instructions for those FFIEC 041 data items that are not included in the
FFIEC 051 would be excluded from the instructions for the FFIEC 051. Glossary entries in the
instructions for the FFIEC 041 that are not relevant to the FFIEC 051 also would be excluded
from the FFIEC 051 instructions. Instructions would be added to the FFIEC 051 instructions for
the indicator questions and data items in the proposed Supplemental Schedule.
Shifts in Reporting Status
The Call Report instructions presently provide that once an institution reaches or exceeds
a specified total asset or other reporting threshold that requires the reporting of additional
information in the Call Report, the institution must continue to report the additional information
in subsequent years without regard to whether it later falls below reporting threshold. To reduce
reporting burden, the agencies are proposing to revise these instructions on reporting thresholds.
Accordingly, if an institution’s consolidated total assets or activity level subsequently fall to less
than the applicable asset or activity threshold for four consecutive quarters, the institution may
cease reporting the data items to which the threshold applies for all reporting thresholds in the
FFIEC 031 and FFIEC 041 (and proposed FFIEC 051) Call Reports unless the institution

14

exceeds the threshold as of a subsequent June 30 report date.
Proposed Changes to the FFIEC 031 and FFIEC 041
In addition to the creation of the FFIEC 051, this proposal also includes proposed
revisions to some of the schedules in the FFIEC 041 and FFIEC 031 Call Reports as a result of
the first three agency user surveys conducted under the Full Review. Going forward, the data
items in all other Call Report schedules will continue to be evaluated as part of the Full Review.
The following schedules in the FFIEC 031 and FFIEC 041 versions of the Call Report
would have data items removed or subject to new or higher reporting thresholds as a result of the
statutorily mandated Full Review:
• Schedule RI – Income Statement
• Schedule RI-B – Charge-offs and Recoveries on Loans and Leases and Changes in
Allowance for Loan and Lease Losses
• Schedule RC-C – Loans and Lease Financing Receivables
• Schedule RC-E – Deposit Liabilities
• Schedule RC-M – Memoranda
• Schedule RC-N – Past Due and Nonaccrual Loans, Leases, and Other Assets
In addition, the proposed change governing shifts in reporting status would also be
applicable to institutions that file the FFIEC 031 and FFIEC 041 Call Reports.
Time Schedule for Information Collection
The Call Reports are collected quarterly as of the end of the last calendar day of March,
June, September, and December. Less frequent collection of Call Reports would reduce the
Federal Reserve’s ability to identify on a timely basis those banks that are experiencing adverse
changes in their condition so that appropriate corrective measures can be implemented to restore
their safety and soundness. State member banks must submit the Call Reports to the appropriate
Federal Reserve Bank within 30 calendar days following the as-of date; a five-day extension is
given to banks with more than one foreign office.
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.

15

Legal Status
The Board’s Legal Division has determined that section 9 of the Federal Reserve Act
(12 U.S.C. § 324) authorizes the Board to require these reports from all state member banks.
The obligation to respond is mandatory. Most of the information provided on the Call Reports is
publicly available. 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 respond to memorandum items 6-9, 14-15, and 18 on schedule RC-O. This
information can be exempt from disclosure pursuant to the Freedom of Information Act (FOIA)
(5 U.S.C. §§ 552 (b)(4) and (8)) for periods beginning June 30, 2009. The individual respondent
information contained in the trust schedule, RC-T are exempt from disclosure (5 U.S.C. §§
552(b)(4) and (8)) for periods prior to March 31, 2009. Finally, Column A and memorandum
item 1 to Schedule RC-N, Past Due and Nonaccrual Loans, Leases, and Other Assets are exempt
from disclosure (5 U.S.C. §§ 552(b)(4) and (8)) for periods prior to March 31, 2001.
Consultation Outside the Agency and Discussion of Public Comments
On August 15, 2016, the agencies, under the auspices of the FFIEC, published an initial
notice in the Federal Register (81 FR 54190) requesting public comment for 60 days on the
extension, with revision, of the Call Reports. The comment period for this notice expired on
October 14, 2016. The agencies collectively received comments on the proposal from
approximately 1,100 entities, including individuals, banking organizations, bankers’
associations, and a government entity.11 A discussion of general and specific comments on the
proposed FFIEC 051 and existing FFIEC 031 and FFIEC 041 Call Reports follows below.
General Comments on the Proposed FFIEC 051
Commenters expressed mixed opinions on the proposed FFIEC 051. Approximately 25
commenters representing banking organizations, bankers’ associations, and a government entity
supported the effort put forth by the agencies. One bankers’ association stated that the initial
proposal was “a positive step in an ongoing, iterative process” that shows a “modest but material
burden relief to institutions eligible to file the [FFIEC 051] report.” One institution stated that
the proposed FFIEC 051 would assist small banks by reducing preparation time and minimizing
confusion by removing schedules related to activities in which the bank does not engage.
Another commenter stated that this proposal was a good start by removing items that have no
relationship with the reporting institution. Another commenter agreed with the proposal to
shorten the length of the Call Report and the instructions, which would reduce the time spent
reviewing updates to determine items that may or may not be applicable to the bank. One
commenter stated the reduction and the removal of non-relevant data items for noncomplex
institutions saves both time and money. The government entity stated it uses certain data items
in the Call Report in preparing national economic reports, and encouraged the agencies to
continue collecting those items.

11

The agencies received approximately 100 unique letters and 1,000 form letters.

16

On the other hand, the majority of commenters from banking organizations and bankers’
associations responded that there was no perceived impact by adopting the FFIEC 051. Many of
the banking organizations stated that the data items proposed to be removed were not reported
currently by their institutions; therefore, the changes would not impact their burden in preparing
the Call Report. Three of the bankers’ associations stated that the agencies removed items
largely not reported, and related to activities not engaged in, by community banks. Another
institution responded that by making the change to the FFIEC 051, it would add burden at the
conversion date with little time savings in future filings. One commenter stated that the
inclusion of the supplemental schedule (Schedule SU) could actually increase burden, as banks
must use the same processes or new processes to verify the data (or inapplicability) of the new
supplemental items.
The agencies recognize that not all community institutions eligible to file the FFIEC 051
will see an immediate and large reduction in burden by switching to that form. Some of the
items that were removed from the FFIEC 041 to create the FFIEC 051 only needed to be
reported by institutions with assets of $1 billion or more. Other items not included in the
FFIEC 051 applied to institutions of all sizes, but may not have applied to every community
institution, due to the nature of each institution’s activities. Approximately 100 data items would
be collected at a reduced frequency in the FFIEC 051. For example, in creating the FFIEC 051,
the agencies have removed from the FFIEC 041 the data items on Schedule RC-L, Derivatives
and Off-Balance Sheet Items, in which the more than 700 eligible institutions that have
derivative contracts have been required to report the gross positive and negative fair values of
these contracts. The agencies also have reduced from quarterly to semiannually the reporting
frequency in the FFIEC 051 of Schedule RC-C, Part II, Loans to Small Businesses and Small
Farms, which is applicable to the approximately 5,200 institutions eligible to file the FFIEC 051,
and Schedule RC-A, Cash and Balances Due from Depository Institutions, which applies to the
more than 1,400 eligible institutions that have $300 million or more in total assets. Additionally,
as noted earlier, the agencies are shortening the instructions associated with the FFIEC 051, so
that community bankers will not need to review as many nonapplicable instructions, or the
associated changes to those instructions that may occur in the future. Taken together, the
agencies believe these changes are a positive step toward providing meaningful Call Report
burden relief to community institutions.
A majority of the commenters that did not favor the proposed FFIEC 051 suggested the
agencies adopt a “short-form” Call Report to be filed in the first and third quarters. The shortform Call Report recommended by commenters would consist only of an institution’s balance
sheet, income statement, and statement of changes in equity capital. The institution would file a
full Call Report including all supporting schedules in the second and fourth quarters.
The agencies recognize that the information requested in the Call Report is often more
granular than information presented in standard financial statements, including the notes to the
financial statements, and can require refining or subdividing the information contained in
accounts reported in an institution’s general ledger system or core processing systems. This
process may be burdensome, particularly when account balances have not materially changed
from the prior quarter. However, one element that sets banking apart from other industries is the
regulatory framework, particularly the provision of Federal deposit insurance and the important

17

role of financial intermediation, which requires safety and soundness supervision and
examination. A key component of bank supervision is reviewing granular financial data about
an institution’s activities to identify changes in those activities and in the institution’s condition,
performance, and risk profile from quarter to quarter that suggest areas for further investigation
by the institution’s supervisory agency. For example, granular data on loan categories, past due
and nonaccrual loans, and loan charge-offs and recoveries12 feed into an analysis of credit risk,
while data on loan, security, time deposit, and other borrowed money maturities and repricing
dates13 feed into analyses of interest rate risk and liquidity risk. Much of this analysis occurs offsite, so an institution may not be aware of the extent of this process unless it identifies anomalies
or other “red flags” at the institution. Even then, some anomalies and other “red flags” may be
discussed immediately with the institution, while other concerns are flagged for investigation at
the next on-site examination. The earlier that anomalies, upon immediate follow-up, are found
to evidence deficiencies in risk management or deterioration in an institution’s condition, the less
difficult it will be for the institution to implement appropriate corrective action. In this context,
with full-scope on-site examinations occurring no less than once during each 18-month period
for institutions that have total assets of less than $1 billion and meet certain other criteria,
quarterly data are necessary for many of the data items in the Call Report in order for an
institution’s supervisory agency to have a sufficient number of data points to both identify and
distinguish between one-time anomalies and developing trends at the institution. Moreover, the
agencies note that extending the examination cycle to 18 months for certain qualifying
institutions is discretionary, and the analysis of trends in a particular institution’s Call Report
data is a significant factor in deciding whether to exercise that discretion with respect to that
institution.
In addition to supporting the identification of higher-risk situations, enabling timely
corrective action for such cases, and justifying the extended examination cycle, the quarterly
reporting of the more granular Call Report items also aids in the identification of low-risk areas
prior to on-site examinations, allowing the agencies to improve the allocation of their
supervisory resources and increase the efficiency of supervisory assessments, which reduces the
scope of examinations in these areas, thereby reducing regulatory burden. While the quarterly
monitoring process enabled by the more granular Call Report items historically has focused on
raising “red flags,” similar emphasis has also been placed on the identification of low-risk
situations. A six-month reporting cycle for the more granular Call Report items would hamper
the agencies’ ability to form timely risk assessments and so could stymie efforts to improve the
focus of on-site examinations for low-risk institutions. In this manner, an effort to reduce
regulatory burden by lengthening the reporting cycle for the more granular Call Report items
could limit the agencies’ opportunities to reduce burden for on-site examinations.
In addition to safety and soundness data, other data items are required quarterly due to
various statutes or regulations. Leverage ratios based on average quarterly assets and risk-based
capital ratios are necessary under the prompt corrective action framework established under 12
U.S.C. 1831o.14 Data on off-balance sheet assets and liabilities are required every quarter for

12
13
14

Reported on Schedules RI-B; RC-C, Part I; and RC-N.
Reported on Schedules RC-B; RC-C, Part I; RC-E; and RC-M.
Reported on Schedules RC-K and RC-R.

18

which an institution submits a balance sheet to the agencies pursuant to 12 U.S.C. 1831n.15
Granular data on deposit liabilities and data affecting risk assessments for deposit insurance are
required four times per year under 12 U.S.C. 1817.16
Further, the public availability of most quarterly Call Report information from
institutions that are not publicly held is desired by their depositors (particularly those whose
deposits are not fully insured), other creditors, investors, and other institutions. An institution’s
depositors and other creditors may use quarterly Call Report information to perform their own
assessments of the condition of the institution. Existing and potential investors may evaluate
Call Report data to assess an institution’s condition and future prospects; the absence of quarterly
information could impair the institution’s ability to raise capital or could limit the liquidity of the
institution’s shares for existing stockholders. Other institutions that engage in transactions with
the reporting institution may utilize Call Report information to assess the condition of their
counterparties to these transactions. In addition, some institutions use peer analysis to
benchmark against local competitors using data obtained from their Call Reports directly, or by
using third-party vendors who often leverage information from the agencies’ repository of Call
Report data. For example, as part of their financial control structures, some institutions analyze
their allowance for loan and lease losses (ALLL) by comparing their delinquency ratios and their
ratios of ALLL to loans and leases to peer group ranges and averages.
While the agencies understand the commenters’ desire for a “short-form” Call Report, for
the reasons stated above, the agencies did not adopt this suggestion. In addition to the basic
financial statements, the most streamlined quarterly report possible must also include quarterly
data required by statute or regulation, along with quarterly data necessary for adequate
supervision by the agencies. However, as part of the continuing burden reduction efforts, the
agencies will continue to review the quarterly data collected in the proposed FFIEC 051 and
existing FFIEC 031 and FFIEC 041 reports that go beyond the statutory or regulatory
requirements or essential supervisory needs. For example, the agencies are revising Schedule
RC-C, Part II, in the FFIEC 051 to reduce its reporting frequency from quarterly to semiannual
for all institutions that file the FFIEC 051.
General Comments on the Call Report Initiatives
The agencies are still engaged in the statutorily mandated review of the existing Call
Report data items (Full Review). The agencies are conducting the Full Review as a series of
nine surveys of internal users of Call Report data within the FFIEC member entities. Proposed
changes resulting from the first three surveys were included in the August 2016 proposal, and a
summary of the member entities’ uses of the data items retained in the Call Report schedules
covered in these three surveys is included as Appendix A. The agencies are analyzing the results
of four additional surveys, and still need to collect and review data from the final two surveys to
determine any future proposed revisions to the FFIEC 031, FFIEC 041, and FFIEC 051. Burdenreducing reporting changes to these three versions of the Call Report from the remaining six
surveys will be proposed in future Federal Register notices with an anticipated implementation
date of March 31, 2018. The agencies described this staged approach to proposing changes to
15
16

Reported on Schedule RC-L.
Reported on Schedules RC-E and RC-O.

19

the FFIEC 031, FFIEC 041, and FFIEC 051 resulting from the Full Review in their August 2016
proposal, but asked whether it would be less burdensome to delay all the changes to the Call
Report until the completion of the Full Review.
The agencies received comments about the burden reduction initiative and the Full
Review. On the timing of future revisions, one commenter stated that it would not matter, while
another commenter wanted the changes implemented as soon as possible. Three commenters
recommended adopting all of the changes at once. These commenters stated it is more
burdensome to deal with more frequent changes to the Call Report, even if those changes would
reduce burden. Six commenters sought a better understanding for the agencies’ use of the Call
Report data items submitted by institutions. Two bankers’ associations requested a published
report of how the data are used either by individual line item or by schedule.
The agencies are cognizant of the burden caused by frequent changes to the Call Report,
but also must consider the ongoing burden imposed until the completion of the review by
collecting data items the agencies have agreed are no longer necessary. In an attempt to balance
those concerns, the agencies plan to propose changes related to the user surveys in two future
notices. The agencies already included the results from the first three user surveys in the August
2016 notice. The next notice would include changes from a second set of user surveys and is
expected to be issued in early 2017. The last notice would include any changes from a third and
final set of user surveys and is expected to be issued in late 2017. The proposed effective date
for changes in both future notices would be March 31, 2018.
A significant amount of the data collected in the Call Report is used for safety and
soundness purposes, especially for quarterly off-site monitoring and reviews between on-site
examinations. Additional data items are required by statute or regulation. A lesser number of
data items are used for consumer financial protection purposes or for specific agency missions,
such as deposit insurance and monetary policy. To provide additional detail on the uses of Call
Report schedules and data elements, the agencies are including, in Appendix A, a summary of
the FFIEC member entities’ uses of specific schedules and data items from the first three user
surveys conducted in the Full Review. The agencies plan to publish similar summaries when
proposing additional changes based on the results of the second two sets of Full Review surveys
in future notices.
Finally, while it may not directly reduce burden at this time, as described in the
August 2016 notice, the agencies will apply a set of guiding principles in evaluating potential
future additions and revisions to the Call Report. Those principles are: (1) the data items serve a
long-term regulatory or public policy purpose by assisting the FFIEC member entities in
fulfilling their missions of ensuring the safety and soundness of financial institutions and the
financial system and the protection of consumer financial rights, as well as agency-specific
missions affecting national and state-chartered institutions; (2) the data items to be collected
maximize practical utility and minimize, to the extent practicable and appropriate, burden on
financial institutions; and (3) equivalent data items are not readily available through other means.
The agencies intend to apply these principles with rigor for items proposed to be added to the
Call Reports, with the goal of minimizing future burden increases.

20

Specific Comments on the Proposed FFIEC 051
A. Eligibility
The agencies proposed to make the FFIEC 051 available as an option to eligible small
institutions. For purposes of the FFIEC 051 Call Report, the agencies proposed to define
“eligible small institutions” as institutions with total assets less than $1 billion and domestic
offices only. Total assets for eligibility would be measured as of June 30 each year to determine
the institution’s eligibility to file the FFIEC 051 beginning in March of the following year. In
addition, for an institution otherwise eligible to file the FFIEC 051, the institution’s primary
federal regulatory agency, jointly with the state chartering authority, if applicable, may require
the institution to file the FFIEC 041 instead based on supervisory needs. In making this
determination, the appropriate agency will consider criteria including, but not limited to, whether
the eligible institution is significantly engaged in complex, specialized, or other higher risk
activities. The agencies anticipate making such determinations only in a limited number of
cases.
The agencies received numerous comments on eligibility for the FFIEC 051. Eight
commenters supported expanding the threshold. One commenter suggested using the FDIC’s
definition of a “community bank” (from the FDIC’s Community Banking Study), which is based
on deposit and lending activity and certain other criteria rather than solely asset size, while
another commenter suggested expanding the FFIEC 051 to all institutions that do not engage in
complex activities. Another commenter suggested tying the asset threshold to the definition of
“small bank” under the Community Reinvestment Act (currently, $1.216 billion and indexed for
inflation). Two commenters recommended using a $10 billion asset threshold, with one of those
commenters suggesting that the asset threshold be automatically adjusted for inflation in the
future.
At this time, the agencies are retaining their proposed $1 billion asset-size threshold to be
eligible for the FFIEC 051. This threshold is consistent with one of the eligibility criteria
established by Congress for community institutions to be eligible for an 18-month examination
cycle rather than the standard 12-month cycle.17 The agencies are considering other size
thresholds and other eligibility criteria, such as whether relevant criteria could be developed for
determining that an institution should be considered a “community” institution for Call Report
purposes; however, an asset-size threshold tied to an existing statutory basis was chosen to keep
the initial eligibility criteria simple and transparent, and avoid delaying the proposed effective
date reflecting the March 31, 2017, report date, to be submitted on or after April 1, 2017, for
those eligible institutions interested in beginning to file the FFIEC 051 as of that date while the
agencies evaluate additional potential eligibility criteria. The agencies plan to review additional
data in determining whether to propose any changes to the initial eligibility threshold in the
future. The agencies are also making one revision to the eligibility criteria to disallow advanced

See 12 U.S.C. 1820(d), as amended by Section 83001 of the Fixing America’s Surface Transportation Act, Pub.
L. 114-94, 129 Stat. 1312 (2015). The $1 billion asset-size threshold for the proposed FFIEC 051 also is consistent
with the incremental approach taken by Congress when increasing the threshold for the Board’s Small Bank Holding
Company and Savings and Loan Holding Company Policy Statement; see Pub. L. 113–250 (December 18, 2014).
17

21

approaches institutions18 from being eligible to use the FFIEC 051.19 Even though such an
institution may be under the $1 billion asset-size threshold, it is part of a consolidated banking
organization with assets greater than $250 billion and as such the agencies do not believe such an
institution shares the same risks as eligible small institutions.
The agencies also asked whether filing the FFIEC 051 by eligible institutions should be
mandatory or optional. Six commenters supported allowing the FFIEC 051 to be optional. The
agencies agree with the commenters and will continue to offer it as an option to eligible small
institutions that would otherwise need to file the FFIEC 041. If an institution is eligible for and
chooses to adopt the FFIEC 051, the agencies expect the institution will continue filing that
version of the report going forward as long as it remains eligible.20 If an institution’s assets
increase to $1 billion or more as of June 30 of any calendar year, the institution must return to
filing the FFIEC 041 beginning with the first quarter of the following calendar year.
The agencies received three comments on the proposed reservation of authority for filing
the FFIEC 051. Two commenters opposed this reservation of authority, stating that the language
was too broad and would allow too much discretion to examiners to arbitrarily make institutions
change their version of the Call Report. One of these commenters suggested a process where
any determination by an examiner that an institution must revert to the FFIEC 041 should be
automatically appealable to the agency’s Ombudsman. The other commenter recommended
more clearly defining and limiting the scenarios in which the agencies would consider making an
institution revert to filing the FFIEC 041. The agencies acknowledge the criteria to use the
reservation of authority listed in the notice could be interpreted more broadly than the agencies
intended. The agencies would consider using the reservation of authority if an institution has a
large amount of activity in one or more complex activities that would be reported on one of the
schedules or items proposed to be eliminated in the FFIEC 051. These schedules include
Schedules RC-D (trading activity), RC-L (off-balance sheet derivatives), RC-P (mortgage
banking), RC-Q (fair value measurements), RC-S (servicing, securitization, and asset sale
activities), and RC-V (variable interest entities). The agencies do not intend to use this
reservation of authority widely, or to apply it to institutions that engage only in activities that are
fully reported on the FFIEC 051. Furthermore, the exercise of the reservation of authority would
require a decision by a member of the appropriate agency’s senior management and would not be
at the discretion of examination staff.
B. Implementation Date
The agencies proposed implementing the FFIEC 051 for submissions on or after April 1,
2017, beginning with the reports reflecting the March 31, 2017, report date, for all eligible small
institutions. Nine commenters indicated the lead time was sufficient because most of the
changes between the FFIEC 041 and FFIEC 051 did not affect their institutions. Three
18

See 12 CFR 3.100(b) (OCC); 12 CFR 217.100(b) (Board); 12 CFR 324.100(b) (FDIC).
As a consequence, the data items in Schedule RC-R that are applicable only to advanced-approaches institutions
would be removed from the FFIEC 051.
20
An institution whose assets remain below $1 billion as of June 30 of any year may choose to file the FFIEC 041
instead of the FFIEC 051 beginning with the first quarter of the following calendar year. An institution’s primary
federal supervisory agency may approve an institution’s request to change to the FFIEC 041 in a later quarter of a
calendar year on a case-by-case basis.
19

22

commenters suggested delaying the implementation date. One commenter suggested setting the
date at least six months from the start of the quarter in which the final changes are published.
Another commenter stated a minimum of one quarter is needed after the final FFIEC 051 is
approved. One institution suggested a June 30, 2017, implementation date.
The agencies believe that it is important to offer this new report form as an option as
early as feasibly possible, to reduce burden for those eligible institutions that are able to switch
to the FFIEC 051 beginning as of the March 31, 2017, report date. The conversion to the
FFIEC 051 is optional, and initial eligibility would be determined by an institution’s asset size as
of June 30, 2016. For an institution that qualifies to use the FFIEC 051 and desires to use that
form, but is unable to do so for the March 31, 2017, report date, for submissions on or after April
1, 2017, the institution may begin reporting on the FFIEC 051 as of the June 30, 2017, report
date or in a subsequent quarter of 2017. Alternatively, the institution could wait until March 31,
2018, for submission on or after April 1, 2018, to begin reporting on the FFIEC 051, assuming it
continues to meet the eligibility criteria.
C. Comments on Schedule RC-R, Regulatory Capital
The agencies received approximately 30 comment letters that highlighted the burden
required to prepare Schedule RC-R, Regulatory Capital. The agencies received similar
comments during their banker outreach efforts, as well as in comment letters submitted under a
review of agency regulations required by the Economic Growth and Regulatory Paperwork
Reduction Act (EGRPRA).
An institution must calculate its capital ratios quarterly pursuant to the prompt corrective
action provisions of statute and the agencies’ regulations. The agencies revised Schedule RC-R
in March 2015 to include the data items that would be necessary for an institution to calculate its
regulatory capital ratios under the agencies’ revised capital rules. The greater detail of those
rules requires a degree of categorization, recordkeeping, and reporting that is greater than under
the previously applicable capital rules. While many of the data fields on Schedule RC-R may
not be applicable to community institutions not engaged in complex activities, some community
institutions do engage in activities that would need to be reported in those fields to perform the
correct calculation under the capital rules. The agencies are developing responses to the
concerns about the burden of the regulatory capital rules raised during the EGRPRA comment
process and the associated reporting requirements on Schedule RC-R. If the agencies propose
modifications to the regulatory capital rules, the agencies would also propose modifications to
the associated reporting requirements on Schedule RC-R.
D. Comments on Schedule RC-C, Loans and Lease Financing Receivables
Twelve commenters emphasized Schedule RC-C as a significant contributor to the
reporting burden for smaller institutions. Five banking organizations specifically highlighted
Schedule RC-C, Part II, Loans to Small Businesses and Small Farms, as particularly burdensome
and suggested eliminating the schedule or reducing the frequency of the data collected. During
the agencies’ banker outreach efforts, community institutions similarly highlighted the burden of
Schedule RC-C, and particularly Part II of the schedule.

23

In developing the proposed FFIEC 051, the agencies removed 38 items from Schedule
RC-C, Part I, that are currently reported in the FFIEC 041 and were identified as having lesser
utility for institutions eligible to file the new report.
The remaining loan and lease data in Schedule RC-C, Part I, are critical inputs to
assessing the safety and soundness of individual institutions through analysis of the institutions’
credit risk, interest rate risk, and liquidity risk, including the identification and analysis of
lending concentrations. The granularity of the loan categories is also essential for peer group
analysis and industry analysis. Loan and lease information is also an important component of
agency statistical models that assess the risk profile of an institution. In addition, many
community institutions use the Call Report loan categories when they measure the estimated
credit losses that have been incurred on groups of loans with similar risk characteristics in their
calculations of the ALLL each quarter under U.S. generally accepted accounting principles
(GAAP).
Finally, loan and lease information assists the agencies in fulfilling their specific
missions. The Board, as part of its monetary policy mission, relies on the loan data in Schedule
RC-C, Part I, to provide information on credit availability and lending conditions not available
elsewhere. Loan and lease detail at all sizes of institutions is necessary for monitoring the
overall health of the economy. Reducing loan detail or data frequency for smaller institutions
would limit the ability to monitor credit availability and lending conditions widely, including in
response to any changes in monetary policy. At times, loan availability and lending conditions
may be different at smaller institutions than at larger institutions. Furthermore, Schedule RC-C,
Part I, data are used to benchmark weekly loan data collected by the Board from a sample of
both small and large institutions; the weekly data are used to estimate weekly loan aggregates for
the banking sector as a whole to provide more timely input for the purposes of monitoring the
macroeconomy.
The FDIC’s deposit insurance assessment system for “established small banks” relies on
information reported by individual institutions for the Schedule RC-C, Part I, standardized loan
categories in the determination of the loan mix index in the financial ratios method, which is
used to determine assessment rates for such institutions.
The data collected in Schedule RC-C, Part II, is based on a statutory requirement to
collect data on small business and small farm loans on an annual basis and began in 1993.21 In
2010, the FFIEC changed the reporting frequency for Schedule RC-C, Part II, from annual to
quarterly. At that time, the agencies approved the more frequent collection of these data to
improve the Board’s ability to monitor credit conditions facing small businesses and small farms
and contribute to its ability to develop policies intended to address any problems that arise in
credit markets. The U.S. Department of the Treasury also identified a particular need for these
data as they worked to develop policies to ensure that more small businesses and small farms
would have access to credit. The Board also found the more frequent data valuable for
monitoring the macroeconomy and credit availability in particular for the purposes of monetary
policymaking. However, after extensive analysis by the Board, the agencies agreed in the

21

See Section 122 of the Federal Deposit Insurance Corporation Improvement Act of 1991, Pub. L. 102-242.

24

August 2016 proposal to reduce the frequency of Schedule RC-C, Part II, to semiannually in
June and December for institutions with assets of less than $50 million.
The agencies received five comments stating that Schedule RC-C, Part II, was
particularly burdensome for their institutions due to the level of manual intervention required to
report the data. This schedule requests the number and amount currently outstanding of existing
loans in each of these categories, but categorized by the loans’ original amounts. One banker
noted that their bank had to manually stratify loan data into the three loan size categories for
each type of loan according to the loans’ original amounts, and then manually adjust for lines of
credit and participations purchased and sold to accurately report the amount currently
outstanding. One bank questioned how valuable the small business and small farm loan data are
for setting monetary policy, particularly since the Board had been setting monetary policy for
many years before the FFIEC began requiring quarterly data in 2010 and also because the Call
Report data collected in Schedule RC-C, Part II, does not capture significant nonbank funding
sources for small businesses such as credit cards and vendor financing. The agencies received
similar comments about burden from banker outreach efforts conducted by the FFIEC member
entities and through the EGRPRA process. After additional review, the Board has determined
that semiannual reporting by all institutions filing the FFIEC 051 would be of sufficient
frequency to meet their data needs. Therefore, the agencies will collect this loan information
from all institutions filing the FFIEC 051 in the June and December quarterly reports only.
E. Coordination with Other Reports
Two commenters from multibank holding companies stated that the FFIEC 051 does not
provide any relief for their institutions, because many of the items removed from the FFIEC 041
must still be reported on the holding company’s FR Y-9C22 report and therefore must still be
collected at the bank level. One of these commenters noted that unless all banks in a multibank
holding company can use the FFIEC 051, likely none of them will, as it may be more difficult to
consolidate the information from different Call Report forms when completing the FR Y-9C.
The Board notes that for most holding companies with total assets less than $1 billion, the
holding company can file the FR Y 9SP, which does not require data being removed from the
FFIEC 051. For holding companies with total assets of $1 billion or more, the FR Y-9C does
require a significant amount of information that is being removed from the FFIEC 051. The
Board believes this information is necessary on the FR Y-9C, even if the activity is spread
among multiple subsidiary institutions, some of which may have assets less than $1 billion, for
the effective supervision of the consolidated holding company. In those cases, the holding
company and its subsidiary institutions can best determine whether there is any burden saved at
the institution level by filing the FFIEC 051 rather than the FFIEC 041.
Four commenters stated that the agencies should reduce duplication between the Call
Report and other regulatory reports collected by the agencies. Commenters noted perceived
duplication of one or more data items with the following reports: FR 2900,23 FR 2644,24 the
22

Consolidated Financial Statements for Holding Companies (FR Y-9C; OMB No. 7100-0128).
Report of Transaction Accounts, Other Deposits, and Vault Cash (FR 2900; OMB No. 7100-0087).
24
Weekly Report of Selected Assets and Liabilities of Domestically Chartered Commercial Banks and U.S.
Branches and Agencies of Foreign Banks (FR 2644; OMB No. 7100-0075).
23

25

FDIC’s annual Summary of Deposits survey,25 and loan data provided to the institution’s Federal
Home Loan Bank for access to advances. The agencies do not believe data collected in these
collections are duplicative of Call Report data. The FR 2900 collects select data on cash and
deposit liabilities for reserve requirement purposes, from most institutions on a weekly basis,
which may not coincide with the reporting date for the Call Report. The FR 2644 collects data
on loans, securities, and borrowings from a small sample of banks on a weekly basis, which may
not coincide with the reporting date for the Call Report. The FDIC’s Summary of Deposits
survey collects data on deposits stratified by branch location from institutions with branch
offices annually as of each June 30. Deposit data categorized by branch location is not available
elsewhere. The Federal Home Loan Banks are not government agencies, and any data they may
collect in connection with various lending programs are not readily available for use by FFIEC
member entities.
Proposed Call Report Revisions to the FFIEC 031 and the FFIEC 041
The agencies proposed revisions to some of the schedules in the FFIEC 031 and
FFIEC 041 Call Reports in response to the findings of the first three user surveys at FFIEC
member entities conducted under the Full Review. Specifically, the following schedules in the
FFIEC 031 and FFIEC 041 versions of the Call Report would have data items removed or
subject to new or higher reporting thresholds as a result of these surveys (see Appendices C and
D for a complete listing of the affected data items based on the September 30, 2016, FFIEC 031
and FFIEC 041 Call Reports, respectively):
• Schedule RI – Income Statement
• Schedule RI-B – Charge-offs and Recoveries on Loans and Leases and Changes in
Allowance for Loan and Lease Losses
• Schedule RC-C – Loans and Lease Financing Receivables
• Schedule RC-E – Deposit Liabilities
• Schedule RC-M – Memoranda
• Schedule RC-N – Past Due and Nonaccrual Loans, Leases, and Other Assets
The agencies did not receive any comments on the specific changes to the FFIEC 031 and
FFIEC 041 in the proposal, and plan to implement those changes as proposed.
Additional Suggested Revisions
Twelve commenters recommended additional specific changes for the agencies to
consider on various schedules of the Call Report. Many of these commenters did not direct their
comments at a specific version of the Call Report, so the agencies considered these comments to
improve both the existing FFIEC 031 and FFIEC 041 Call Reports and proposed FFIEC 051.
One commenter suggested the agencies revise Schedule RI-C (Disaggregated Data on the
Allowance for Loan and Lease Losses) to align with the loan categories reported on Schedule
RC-C, Part I. The agencies did not adopt this suggestion. Aligning the categories would require
collecting additional granular data on Schedule RI C, adding approximately 20 categories and 60
total items. The agencies proposed collecting disaggregated ALLL data for key Schedule RC-C,
25

Summary of Deposits (OMB No. 3064-0061).

26

Part I, loan categories when they proposed to add Schedule RI-C to the Call Report in 2011.
However, commenters on that proposal questioned the reporting of ALLL data for these key Call
Report loan categories. They recommended reducing the number of loan categories and using
broader portfolio segments that would better align with their loan loss allowance methodologies,
which the agencies did in the final implementation of Schedule RI-C in 2013. The agencies do
not believe that changing the schedule to require additional granularity of data is necessary for
the supervision of the institutions to which this schedule is currently applicable. In this regard,
the agencies do not collect Schedule RI-C from institutions with assets less than $1 billion and it
would not be included in the FFIEC 051.
Three commenters suggested revisions to Schedule RI-E (Explanations). One commenter
suggested adjusting the criteria to separately disclose individual components of other noninterest
income and other noninterest expense. The agencies’ current criteria require separate disclosure
if a component within one of those income statement categories is greater than $100,000 and 3
percent of the total balance of that category.26 The commenter suggested adjusting the criteria to
the greater of $100,000 and 5 to 7 percent of the total balance. Another commenter suggested
reporting Schedule RI-E detail on other noninterest income and other noninterest expense
annually on the December 31 Call Report, as the commenter stated the data are primarily useful
on an annual rather than quarterly basis. Another commenter suggested providing definitions for
each of the components of other noninterest income and other noninterest expense for which
preprinted captions are provided in Schedule RI-E. The agencies plan to review the threshold for
separately disclosing individual components and the frequency of the data collection as part of
the ongoing Full Review. The agencies do not plan to provide specific definitions for the
components of other noninterest income and other noninterest expense represented by preprinted
captions. The agencies added preprinted captions for these components to assist all institutions,
including community institutions, as they were the most frequently disclosed components. Not
having preprinted captions for such components would necessitate each institution manually
entering its own captions for those components of other noninterest income and other noninterest
expense exceeding the reporting threshold. However, the agencies do not want to impose a
regulatory definition for these individual components, which could require institutions to adjust
their internal definitions to line up with the agencies’ definitions. The agencies use this
information primarily for the supervision of individual institutions rather than for peer group
comparison, so imposing uniform definitions across institutions is not necessary for supervisory
review. Detailed lists of components of other noninterest income and other noninterest expense
can be found in the instructions for Schedule RI, items 5.1 and 7.d, respectively. The agencies
plan to clarify the instructions for these two Schedule RI data items to better indicate the linkage
between the components of other noninterest income and other noninterest expense listed in
these instructions and the preprinted captions provided in Schedule RI-E.
One commenter suggested the agencies review the intangible asset breakout on Schedule
RC, item 10, and Schedule RC-M, item 2, and suggested combining goodwill and other
26

Prior to 2001, the agencies required separate disclosure of components greater than 10 percent of all other
noninterest income or other noninterest expense. In 2001, the agencies revised the threshold to 1 percent of total
interest income plus total noninterest income. In 2008, the agencies changed the threshold to 3 percent of other
noninterest income or other noninterest expense with a $25,000 floor. The floor was raised to $100,000 effective
September 30, 2016, while retaining the percentage threshold.

27

intangible assets on Schedule RC. The agencies need additional time to consider this request,
and will consider it within the next set of proposed Call Report revisions.
Six commenters stated that Schedule RC-E (Deposit Liabilities) and RC-O (Other Data
for Deposit Insurance and FICO Assessments) were particularly burdensome and suggested
simplifying or consolidating the deposit data on these schedules. Some commenters specifically
noted the breakout of deposit information by source, use, and balance as time-consuming,
especially for Memorandum items 1 through 4 on Schedule RC-E. Two commenters noted that
the FDIC’s deposit insurance assessments currently are calculated based on average total assets
and average tangible equity, so the deposit data is not necessary for the vast majority of banks.27
Three commenters also questioned why the agencies maintain a stratification of certain deposits
in Schedule RC-E into those with balances less than $100,000, $100,000 through $250,000, and
more than $250,000 even though the deposit insurance limit is currently $250,000, and stated
this stratification was particularly burdensome as it required a significant amount of manual
intervention. Two commenters stated that separating out Individual Retirement Accounts (IRA)
data from general deposits on Schedule RC-O was particularly burdensome, with one commenter
noting their bank had to further identify and separate out Coverdell Education Savings Accounts
(formerly called Education IRAs) from the bank’s other IRA account balances to add back to the
non-retirement accounts.
Schedule RC-E categorizes deposits based on source (brokered or non-brokered) and type
of account (time deposit, demand deposit, savings deposit), and by deposit size within certain of
those categories. The reporting of deposit data for some of these categories is required by
statute.28 Reporting of time deposits with balances less than $100,000 in Schedule RC-E,
including certain Memorandum items to adjust that amount, is tied to the Board’s measurement
of the money supply.29 Schedule RC-O, Memorandum item 1, categorizes deposits based on
purpose (for retirement or not for retirement) and subdivided by deposit size, as the deposit
insurance limit applies separately to retirement and non-retirement accounts. These deposit data
also are necessary for the FDIC to calculate the reserve ratio each quarter, which is the ratio of
the net worth of the Deposit Insurance Fund (DIF) to the aggregate estimated insured deposits. 30
The agencies previously approved revisions to Schedule RC-E (and Schedules RI and RC-K) to
replace most segmentations of deposits less than $250,000 that are not needed to calculate the
money supply with segmentations based on deposits of more than $250,000 for consistency with
the deposit insurance limits currently in effect. These revisions will be implemented beginning
with the reports reflecting the March 31, 2017, report date, with submissions on or after April 1,
2017.31 The agencies are not making any revisions to the classification of Coverdell accounts, as
the reporting of deposits by purpose is tied to the FDIC’s provision of deposit insurance.
One commenter stated that the data on Schedules RC-F (Other Assets) and RC-G (Other
Liabilities) did not change significantly for community banks from quarter to quarter and should
be reported annually instead. The agencies did propose reducing the frequency by which
27
28
29
30
31

Deposit data affects the assessments at certain institutions, such as bankers’ banks and custodial banks.
For example, 12 U.S.C. 1817(a)(5) and (9).
See definition of M2, https://www.federalreserve.gov/faqs/money_12845.htm.
See 12 U.S.C. 1813(y)(3).
See 81 FR 45357 (July 13, 2016).

28

institutions must report the significant components of all other assets and all other liabilities on
these two schedules to semiannual in the FFIEC 051 in the August 2016 notice. The agencies
will be considering both the data items and frequency of reporting for these two schedules for all
versions of the Call Report in the Full Review, and will consider the commenter’s suggestions in
that process.
One commenter stated that Schedule RC-K (Quarterly Averages) was particularly
burdensome, as the bank’s general ledger provides point-in-time amounts and manual
intervention is needed to calculate quarterly averages. The agencies note that average total assets
is necessary for various purposes, including prompt corrective action and deposit insurance
assessments.32 The agencies will be considering both the data items and frequency of reporting
for this schedule in the Full Review, and will consider the commenter’s suggestions in that
process.
Three commenters stated that Schedule RC-L (Derivatives and Off-Balance Sheet Items)
was particularly difficult to complete, as some items defined in that schedule do not align with
definitions for similar items in Schedule RC-R, particularly for over-the-counter (OTC)
derivatives. The commenters also noted certain items included in Schedule RC-L, such as
“commitments to make a commitment,” are difficult to define and track. One commenter
suggested lining up the loan commitment categories on Schedule RC-L with the loan categories
on Schedule RC-C, Part I. The agencies are investigating alternatives to the current definitions
in Schedule RC-L, and whether they can be more closely aligned with definitions used in the
agencies’ regulatory capital rules, which is the basis for Schedule RC-R, for inclusion in a future
notice. The agencies do not plan to align the loan categories between Schedules RC-L and RCC, Part I. The loan categories on Schedule RC-C, Part I, are much more granular than in
Schedule RC L. Reducing the granularity of categories on Schedule RC-C, Part I, would impair
the agencies’ ability to use that data for safety and soundness monitoring, while increasing the
granularity on Schedule RC-L would impose additional burden to collect items the agencies do
not believe are necessary.
One commenter recommended reducing the frequency of certain data items in Schedule
RC-M (Memoranda) to annual. Specifically, items 7 through 9, 11, and 12 do not change from
quarter to quarter at the commenter’s bank. Item 7 collects data on assets under management in
proprietary mutual funds and annuities. Item 8 collects information on an institution’s internet
website addresses and trade names. Item 9 asks about internet website transactional capability.
Items 11 and 12 collect information on certain bank powers. The agencies proposed in the
August 2016 notice to reduce the frequency for items 7, 9, 11, and 12 from quarterly to annual.
The agencies will continue collecting item 8 on a quarterly basis to provide more accurate,
timely, and complete information to the FDIC, depositors, and the general public on the insured
status of entities identifying themselves as FDIC-insured depository institutions than would
occur through annual reporting.
One commenter requested that the agencies add control totals to Schedule RC-N for past
due and nonaccrual loans, leases, and other assets to allow easier validation of the accuracy of
the reported data to the institution’s own records. The agencies also noted during their on-site
32

See 12 U.S.C. 1831o and 12 CFR 327.5.

29

banker outreach efforts that some institutions appended their own control totals on this form.
The agencies agree with the suggestion, and plan to revise Schedule RC-N on the FFIEC 031,
FFIEC 041, and FFIEC 051. For the same reason, the agencies will also revise Schedule RC-C,
Part I, and Schedule RC-N to add control totals for troubled debt restructurings in Memorandum
item 1 of each schedule. While these changes would add additional data items to these two
schedules, the data items would be simple mathematical totals of existing data items and would
not require the institution to obtain any additional data.
Five commenters requested that the agencies improve the clarity and usefulness of the
Call Report instructions and highlight any changes made to the instructions each quarter. One
commenter also recommended improving internal consistency within the Call Report. The
agencies agree that the current Call Report instructions could be made more useful, and will start
by incorporating hyperlinks to cited documents in the instructions for the FFIEC 051.33 In
addition, the agencies will post “redlined” documents on the FFIEC website that clearly indicate
any changes to the instructions made since the previous quarter in both versions of the Call
Report instructions. The agencies note that the description in the Call Report forms and
instructions for “loans and leases, net of unearned income” and “loans and leases held for
investment” are intended to have the same reported amounts. Accordingly, the agencies will
replace the former description with the latter description in affected data item captions and
related instructions for clarity and internal consistency. The agencies will continue to consider
additional changes to improve the clarity and usefulness of the Call Report instructions and the
internal consistency of the report.
Burden Estimates
The agencies received ten comments on the burden estimates. One commenter
recommended including time to review instructions for the applicable form, even if data items in
that form are not applicable to the institution. The agencies also received comments from
institutions with estimates of the time it takes their institutions to prepare the current FFIEC 041
Call Report. The majority of these estimates ranged from 40-80 hours per quarter, with one
response of 268 hours per quarter. Three commenters stated that preparing the Call Report costs
approximately $1,000 annually for software. In response to the comments on methodology, the
agencies have revised their calculation for their burden estimates. In addition to the estimated
time for gathering and maintaining data in the required form and completing those Call Report
data items for which an institution has a reportable (nonzero) amount, which have been included
in the agencies’ burden estimates, the revised methodology incorporates time for reviewing
instructions for all items, even if the institution determines it does not have a reportable amount.
The agencies have also added estimated burden hours for verifying the accuracy of amounts
reported in the Call Report. As stated earlier, the agencies are also separating the estimated
burden by type of report, to highlight the estimated burden reduction between the FFIEC 041 and
FFIEC 051 reports. While the agencies’ burden estimates are on the lower end of the ranges
provided by commenters, these estimates are based on average times to complete each data item
factoring in the varying levels of automation versus manual interventions that exist across
institutions for every data item.
33

The agencies have already begun to add such hyperlinks to the existing set of instructions for the FFIEC 031 and
FFIEC 041.

30

One commenter estimated that the incremental burden associated with the one-time
conversion from the FFIEC 041 to the FFIEC 051 would be approximately 160 hours, primarily
for training, and approximately $350 for software. Due to the various factors that could affect
the time and cost of switching to the FFIEC 051, including training needs, the type of existing
systems and automation at an institution, and any cost from software vendors to enable an
institution to file the new form, the agencies have not provided an estimate of this conversion
burden. The agencies reiterate that adopting the FFIEC 051 form is optional, and each institution
should weigh the estimated time savings from using that form with the one-time burden to switch
to the FFIEC 051 from the FFIEC 041.
On January 9, 2017, the agencies published a final notice in the Federal Register
(82 FR 2444).
Estimate of Respondent Burden
The current annual reporting burden for the Call Report is estimated to be 197,637 hours
and would decrease to 178,200 hours as shown in the following table. The average estimated
hours per response for Call Report filers would decrease from 59.89 hours to 54.00 hours due to
the proposed changes. The estimated average burden hours collectively reflect the estimates for
the FFIEC 031, the FFIEC 041, and the proposed FFIEC 051 reports. When the estimates are
calculated by type of report across the agencies, the estimated average burden hours per quarter
are 128.05 (FFIEC 031), 74.88 (FFIEC 041) and 44.94 (FFIEC 051). Furthermore, the estimated
burden per response for the quarterly filings of the Call Report is an average that varies 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 1.4 percent of the total
Federal Reserve paperwork burden.
Number of
respondents34

Annual
frequency

Estimated
average hours
per response

Estimated
annual burden
hours

Current

825

4

59.89

197,637

Proposed

825

4

54.00

178,200

FFIEC 031,
FFIEC 041, and
FFIEC 051

Change

(19,437)

34

Of these respondents, 581 respondents are considered a small entity as defined by the Small Business
Administration (i.e., entities with $550 million or less in total assets) www.sba.gov/contracting/getting-startedcontractor/make-sure-you-meet-sba-size-standards/table-small-business-size-standards.

31

The current total annual cost to state member banks is estimated to be $10,504,407 and
with the proposed revisions would decrease to $9,471,330.35 This estimate represents costs
associated with recurring salary and employee benefits, and expenses associated with software,
data processing, and bank records that are not used internally for management purposes but are
necessary to complete the Call Reports.
Sensitive Questions
This collection of information contains no questions of a sensitive nature, as defined by
OMB guidelines.
Estimate of Cost to the Federal Reserve System
The proposed cost to the Federal Reserve System for collecting and processing the
FFIEC 031, FFIEC 041, and FFIEC 051 is estimated to be $2,280,455 per year, an increase of
$79,900 from the current cost of $2,200,555. The one-time cost to implement the revised reports
is estimated to be $61,700.

35

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 $17, 45% Financial Managers at
$65, 15% Lawyers at $66, and 10% Chief Executives at $89). 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 2015, published March 30, 2016 www.bls.gov/news.release/ocwage.t01.htm. Occupations are defined using
the BLS Occupational Classification System, www.bls.gov/soc/.

32

Appendix A
Summary of the FFIEC Member Entities’ Uses of the Data Items in the Call Report
Schedules in Full Review Surveys 1 through 3
Schedule RC (Balance Sheet)
Schedule RC collects high-level information on various balance sheet categories,
including assets, liabilities, and equity accounts every quarter. These categories are aligned with
the categories typically reported on a basic balance sheet prepared under U.S. generally accepted
accounting principles (GAAP).
Schedule RI (Income Statement)
Schedule RI collects information on various income and expense categories every
quarter. In general, these categories are aligned with the categories typically reported on a basic
income statement and in the notes to the financial statements prepared under U.S. GAAP.
The Memorandum items collect an assortment of information on items related to the
income statement. Some items provide additional detail for certain categories of income or
expense, while other items are not directly tied to earnings measures. Memorandum items on taxexempt income and nondeductible interest expense are used to convert components of reported
earnings to a tax-equivalent basis to improve the comparability of income statement information
across institutions for purposes of analyzing institutions’ earnings. An institution’s Subchapter S
status for federal income tax purposes assists examiners and other users in understanding the
amounts, if any, reported for applicable income taxes. It also serves as a flag for adjusting aftertax earnings when measuring return on assets to improve the comparability of this ratio across
institutions with differing tax statuses. The count of full-time equivalent employees is used to
calculate efficiency ratios and average personnel expenses per employee to identify institutions
with higher expense levels for further review. The existence of other-than-temporary
impairment losses on debt securities recognized in earnings provides an indication of heightened
credit risk in an institution’s investment securities, which may warrant supervisory follow-up,
and assists in the scoping of the review of the securities portfolio during on-site examinations.
Data on the composition of trading revenue is used in evaluating the variability and volatility of
this revenue source for institutions with significant trading activity in off-site reviews and for
pre-examination planning and as part of industry analysis of trading activity.
Schedule RC-C, Part I (Loans and Lease Financing Receivables)
Schedule RC-C, Part I, requests information on loan and lease financing activities,
segmented into detailed loan categories. The memoranda items request additional information,
including scheduled maturities and repricing dates for certain loan types and fair value estimates.
Schedule RC-C details loan volumes, segmentations, and structures, all of which
facilitate the assessment of an institution’s inherent risk, performance risk, and structure risk in
its primary earning assets and its primary source of credit risk. Schedule RC-C is often reviewed
in conjunction with Schedules RI, RI-B, and RC-N. This granular data enables examiners to

33

analyze and assess the institution’s loan portfolio diversification, credit quality, concentration
exposure, and overall risk profile. These schedules are critical to the credit quality analysis
performed by examiners to identify early warning signs of deterioration in the financial condition
of institutions. Asset quality ratios from the Uniform Bank Performance Report (UBPR) that are
calculated using data from Schedule RC-C and related loan schedules are also helpful to
examiners in determining how an institution is performing relative to its peers and relative to its
own risk profile based on its loan portfolio composition. In addition, these ratios are useful to
examiners in assessing the institution’s credit risk management practices relative to its peers.
Elevated charge-offs or increases in nonaccrual loans in relation to loan balances provide
information to users of the data on potential weak underwriting in prior periods, deterioration of
asset quality, or the indication that the institution is recovering from a period of stress. If there
are concerns about the allowance for loan and lease losses (ALLL) methodology or the
appropriateness of the ALLL level, then there is a focus on the provision expense relative to the
charge-offs as well as to the growth and quality of certain portfolios, depending on the
institution’s risk characteristics. All of these inputs are essential in the review of the balance
sheet, the liquidity of the institution, and the asset-liability management of the institution.
The data on Schedule RC-C are needed for on-site and off-site examination purposes and
also are used in the systemic analysis of the banking system. Because the loan portfolio is the
primary source of credit risk in institutions, the breakdown of the portfolio by loan type is
essential in the review of asset quality. An understanding of an institution's lending activity is
needed to ensure the safety and soundness of the financial institution by indicating whether the
institution is increasing concentrations or incorporating a change to its lending strategy. The
loan segmentation information is essential for planning and staffing examinations by considering
each institution’s lending activities. The information also allows the examination teams to
determine if the lending volume constitutes a concentration of credit, which could require
additional monitoring, measuring, and risk mitigation strategies by bank management. In
addition, the loan detail is important for loan scoping and trend analysis of the entire portfolio,
which are essential in determining an institution's risk profile. On a broader perspective, the loan
segmentation allows regulatory staff to identify concentration risks across institutions.
Along with related data in Schedule RC-N, information about troubled debt restructurings
in compliance with their modified terms can assist the assessment of management’s ability to
work out different categories of problem loans.
Maturity and repricing information on loans and leases, together with the maturity and
repricing information collected in other schedules for other types of assets and liabilities, are
needed to evaluate the liquidity and interest rate risk of the institution and to aid in evaluating the
strategies institutions take to mitigate these risks. Liquidity and interest rate risk indicators that
are calculated by agency models from an institution’s Call Report data and exceed specified
parameters or change significantly between examinations are red flags that call for timely
examiner off-site review. The institution’s risk profile in these areas is considered during preexamination planning to determine the appropriate scoping and staffing for examinations.
In addition, Schedule RC-C and related loan schedules assisted the Consumer Financial
Protection Bureau’s (CFPB) efforts to develop required estimates for various Title XIV mortgage

34

reform rulemakings under the Dodd-Frank Wall Street Reform and Consumer Protection Act
(Pub. L. 111-203) (Dodd-Frank Act). Going forward, data items in these schedules are critical
for continuous monitoring of the mortgage market. The CFPB uses these items to understand the
intricacies of the mortgage market that are essential to assessing institutional participation in
regulated consumer financial services markets and to assess regulatory impact associated with
recent and proposed policies, as required by that agency’s statutory mandate.
Finally, loan and lease information assists the agencies in fulfilling their specific
missions. The Board, as part of its monetary policy mission, relies on institution-specific Call
Report data to provide information on credit availability and lending conditions not available
elsewhere. Loan and lease detail at all sizes of institutions is necessary for monitoring economic
conditions.
Reducing loan detail or data frequency for smaller institutions would limit the ability to
monitor credit availability and lending conditions widely, including changes in credit and
lending related to changes in monetary policy. At times, loan availability and lending conditions
may be different at smaller institutions than at larger institutions. Furthermore, Schedule RC-C,
Part I, data are used to benchmark weekly loan data collected by the Board from a sample of
both small and large institutions; the weekly data are used to estimate weekly loan aggregates for
the banking sector as a whole to provide a more timely input for purposes of monitoring the
macroeconomy.
The FDIC’s deposit insurance assessment system for “established small banks” relies on
information reported by individual institutions for the Schedule RC-C, Part I, standardized loan
categories in the determination of the loan mix index in the financial ratios method, as recently
amended, which is used to determine assessment rates for such institutions.
Schedule RC-C, Part II (Loans to Small Businesses and Small Farms)
Schedule RC-C, Part II, requests data on loans to small businesses and small farms,
including stratification by original loan amount.
Call Report small business and small farm lending data are an invaluable resource for
understanding credit conditions facing these sectors of the economy. Quarterly collection of
these data improves the Board’s ability to monitor credit conditions facing small businesses and
small farms and significantly contributes to its ability to develop policies intended to address any
problems that arise in credit markets. The institution-level Call Report data provide information
that cannot be obtained from other indicators of small business and small farm credit conditions.
For example, during a period of credit contraction, the Call Report data can be used to identify
which types of institutions are reducing the volume of their loans to small businesses and small
farms. This is important information for the Board, as having detailed data on the characteristics
of affected institutions is crucial to building a sufficiently informative picture of the strength of
economic activity. Moreover, there is evidence that small business lending by small institutions
does not correlate with lending by larger institutions.
Monetary policymaking benefits importantly from timely information on small business

35

credit conditions and flows. To determine how best to adjust the federal funds rate over time, the
Board must continuously assess the prospects for real economic activity and inflation in coming
quarters. Credit conditions have an important bearing on the evolution of those prospects over
time, and so the Board pays close attention to data from Call Reports and other sources. In
trying to understand the implications of aggregate credit data for the macroeconomic outlook, it
is helpful to be able to distinguish between conditions facing small firms and those affecting
other businesses, for several reasons. First, small businesses comprise a substantial portion of
the nonfinancial business sector, and so their hiring and investment decisions have an important
influence on overall real activity. Second, because small businesses tend to depend more heavily
on depository institutions for external financing, they likely experience material swings in their
ability to obtain credit relative to larger firms. Third, the relative opacity of small businesses and
their consequent need to provide collateral for loans is thought to create a “credit” channel for
monetary policy to influence real activity. Specifically, changes in monetary policy may alter
the value of assets used as collateral for loans, thereby affecting the ability of small businesses to
obtain credit, abstracting from the effects of any changes in loan rates. Finally, the credit
conditions facing small businesses and small farms differ substantially from those facing large
businesses, making it necessary to collect indicators that are specific to these borrowers. Large
businesses may access credit from a number of different sources, including the corporate bond
market and the commercial paper market. In contrast, small businesses and small farms rely
more heavily on credit provided through depository institutions. The dependence of small
businesses and small farms on lending by depository institutions—particularly from smaller
institutions—highlights the importance of Call Report data.
Schedule RC-N (Past Due and Nonaccrual Loans, Leases, and Other Assets)
Schedule RC-N requests data on past due and nonaccrual assets by detailed categories for
loans and leases and, on a combined basis, for debt securities and other assets.
Data collected on Schedule RC-N is essential to the oversight function of the FFIEC
member entities. The loan portfolio is the largest asset type and the primary source of credit risk
at most financial institutions. Past due and nonaccrual loan information provides significant
insights into the overall credit quality of a financial institution’s loan portfolio and potential areas
of credit quality concerns on which to focus for monitoring and assessing the credit risk
management and overall safety and soundness of an institution. A high level of past due or
nonaccrual loans often precedes adverse changes in an institution’s earnings, liquidity, and
capital adequacy. This information can also have an impact on consumer protection law
compliance and agency rulemaking.
Information collected on Schedule RC-N is integral to both on-site and off-site review
processes at the FFIEC member entities. Trends in past due and nonaccrual loans alert
examiners to possible weaknesses in bank management's loan underwriting and credit
administration practices. This information is a significant factor in assessing the portfolio's
collectability and in estimating the appropriate level for an institution’s ALLL, as well as the
adequacy of its capital levels. The ability to compare results and trends across financial
institutions is important to distinguish systemic issues from institution-specific concerns. Past
due and nonaccrual loan information can serve as an indicator of areas of increasing credit risk

36

within the loan portfolio. The segmentation of past due and nonaccrual information by loan
category is necessary to pinpoint where the credit risk in an institution’s loan portfolio exists.
Comparing the past due level in different loan portfolios to other risk characteristics in that
portfolio such as concentration, charge-offs, or growth can help to determine the overall level of
risk to the safety and soundness of an institution. This data can also provide more insight on
credit risks or weak underwriting practices associated with a specific loan category, which helps
direct the scope of an exam.
Memorandum items in Schedule RC-N also provide important information about credit
risk management, including the past due or nonaccrual status of troubled debt restructurings,
which can assist the assessment of management’s ability to work out different categories of
problem loans. Data regarding delinquent derivative contracts provides important information
for assessing a financial institution’s asset quality, capital level, earnings, market risk, and
operational risk.
Past due and nonaccrual information is also utilized in the assessment of compliance with
consumer protection laws and regulations. Items reported on Schedule RC-N are used to inform
rule writing and policy efforts, including the CFPB’s Title XIV mortgage reform rulemakings
under the Dodd-Frank Act. Past due information can identify potential areas of disparate
treatment in relation to the Fair Housing Act (Pub. L. 90-284). Additionally, past due levels can
highlight areas of potential unfair practices under the principles in section 1031 of the DoddFrank Act, which are similar to those under section 5 of the Federal Trade Commission Act
(15 U.S.C. 45).
Schedule RI-B, Parts I and II (Charge-offs and Recoveries on Loans and Leases and Changes in
Allowance for Loan and Lease Losses)
Schedule RI-B, Part I, collects information on charge-offs and recoveries on loans and
leases, while Part II collects information on changes in the ALLL during the year-to-date
reporting period in a manner consistent with the disclosure of the activity in the allowance
required under U.S. GAAP.
The data items on Schedule RI-B provide information critical to the missions of the
FFIEC member entities. Charge-off amounts, in conjunction with any associated recoveries, for
the various loan categories are needed to assess the safety and soundness of the financial
institution by indicating the credit quality of the loan portfolio and the potential credit risk of the
institution. The data items are also used to assess the strength of the institution’s credit
administration practices, along with the institution’s loan underwriting practices. The data items
also support the agencies’ rule writing and policy efforts.
Schedule RI-B data play an integral role in reviewing the asset quality of an institution.
The net charge-offs help in the assessment of the level of credit risk in the loan portfolio, both in
aggregate and by loan type. Above average or increasing net charge-offs may be a signal of
weak underwriting in prior periods, which in turn may be an indicator of future risks to earnings
and capital. In addition, the separate reporting of gross charge-offs and recoveries allows users
of the data to evaluate whether high recovery rates are masking underlying loss levels and trends,

37

which may have future earnings implications, and the charge-off and recovery data also aid in
the planning of on-site examinations and in the scoping of the loan review to be conducted
during these examinations.
Schedule RI-B is also important in assessing the strength of an institution’s underwriting
and credit administration practices. The data items allow for the agencies to highlight loan
categories with a large or sudden change in charge-off rates, which is often a key indicator of
weaknesses in these areas, while information on recoveries provides support in evaluating an
institution’s ability to collect on prior charge-offs.
The segmentation of the charge-off and recovery data by loan category in Schedule RI-B
is essential for many reasons. Consistent segmentation by loan category allows for
comparability between institutions, as well as within an institution from quarter to quarter,
allowing for the evaluation of changes and trends in charge-offs and recoveries that may or may
not be institution-specific. This evaluation facilitates on-site examination planning. It also
allows for better off-site monitoring of the existing types of lending and shifts in types of
lending. The granularity and consistency of data items helps in the determination of whether
weaknesses are confined to a particular portfolio segment and are unique to the institution or
whether they are representative of a more widespread systemic weakness in a particular loan
category. The detail by loan category is critical as losses in certain portfolios vary based on
several factors and aggregating the data items would impair the ability to analyze data by loan
category. The Memorandum items request further detail on charge-offs and recoveries or
additional loan categories, which assists in the assessment of credit risk in these areas.
Schedule RI-B data items are used in rule writing and policy efforts. In particular, the
items are used to assess institutional participation in regulated consumer financial services
markets and to assess regulatory impact associated with recent and proposed policies, as required
by the CFPB’s mandate. Also, the information reported in Schedule RI-B, Part I, was integral in
various Title XIV mortgage reform rulemakings under the Dodd-Frank Act and continues to be
critical for the continuous monitoring of the mortgage markets.
Schedule RC-E, Parts I and II (Deposit Liabilities)
Schedule RC-E, Part I, requests data on deposits, segmented between transaction and
nontransaction accounts. The Memoranda section of the schedule requests additional detail on
retirement account deposits, brokered deposits, deposit size, and time deposit maturity and
repricing dates. Schedule RC-E, Part II, requests data on foreign deposits and is included only in
the FFIEC 031.
Schedule RC-E, Part I, provides detail necessary for supervisory purposes, including for
identifying material deposit elements and providing detail needed to analyze cost of funds.
Deposit detail as to the type, nature, and maturity of deposits, including deposits from non-core
sources, is critical to the agencies’ asset-liability management, interest rate risk, and liquidity
analyses. A number of agency analysis tools routinely use quarterly deposit data for trend
analysis and timely identification of deposit shifts, including changes in an institution’s use of
brokered and listing service deposits. Schedule RC-E, Part I, data are also used to estimate the

38

contribution to the U.S. monetary aggregates for over 1,000 depository institutions that do not
file these data directly to the Board.
The Schedule RC-E, Part I, Memorandum items provide information needed for off-site
monitoring and pre-examination planning, particularly for analyses related to brokered deposits
and time deposits, the results of which may signal the existence of higher-risk funding strategies.
The resolution process for failed institutions requires sufficient deposit detail to estimate the least
costly alternative to liquidation. Brokered deposit data are used as inputs in the calculation of
deposit insurance assessment rates and to assure compliance with safety and soundness
regulations tied to limits on those types of deposits.
Maturity and repricing information on time deposits, together with the maturity and
repricing information collected in other schedules for other types of assets and liabilities, are
needed to evaluate the liquidity and interest rate risk of the institution and to aid in evaluating the
strategies institutions take to mitigate these risks. Liquidity and interest rate risk indicators that
are calculated by agency models from an institution’s Call Report data and exceed specified
parameters or change significantly between examinations are red flags that call for timely
examiner off-site review. The institution’s risk profile in these areas is considered during preexamination planning to determine the appropriate scoping and staffing for examinations.
Schedule RC-E, Part II, data on foreign deposits provides the extent of and exposure to
such balances, and is used in similar analyses for institutions with foreign operations.
Schedule RC-O (Other Data for Deposit Insurance and FICO Assessments)
Schedule RC-O requests data for deposit insurance purposes and serves three primary
purposes for the FDIC: calculating the FDIC’s DIF reserve ratio, calculating the assessment base
of FDIC-insured institutions, and calculating the risk-based assessment rate of FDIC-insured
institutions.
Schedule RC-O data are collected in the Call Report to provide unique information used
in the calculation of the FDIC’s reserve ratio to satisfy the statutory requirements related to
maintaining the DIF. Information related to deposit liabilities on Schedule RC-O is needed to
estimate insured deposits. Schedule RC-O is the only place on the Call Report where
information is available to estimate insured and uninsured deposits for individual institutions and
equivalent data items are not readily available from other sources.
Schedule RC-O data that are not available elsewhere enable the FDIC to calculate the
quarterly deposit insurance assessment base for each FDIC-insured institution. Pursuant to the
Dodd-Frank Act, the assessment base is defined as average consolidated total assets minus
average tangible equity, both of which are reported in Schedule RC-O. Custodial banks and
banker’s banks also receive an additional adjustment to the assessment base using Schedule RCO data. The FDIC must be able to calculate the assessment base in order to meet the statutory
requirements for collecting quarterly insurance assessments from all FDIC-insured institutions.

39

Most of the data reported on Schedule RC-O is used to determine the risk-based
insurance assessment for individual institutions in accordance with FDIC regulations
implementing the statutory requirement for risk-based assessments first enacted in 1991. With
the adoption of the risk-based scorecards for large and highly complex institutions, additional
reporting is required on Schedule RC-O in data items applicable only to these institutions. In
addition, some Schedule RC-O data items are used for determining the assessment rate of all
FDIC-insured institutions.
Supervisory uses of Schedule RC-O data include incorporating the data on the maturity
structure of external borrowings in agency interest rate risk models to determine the impact of
interest rate movements on income and economic value of equity. Interest rate risk indicators
that exceed specified parameters or change significantly between examinations are triggers for
timely off-site review. The indicated level of interest rate risk is considered during preexamination planning to determine the appropriate scoping and staffing for examinations. Data
on reciprocal brokered deposits supplements on- and off-site analyses of liquidity ratios,
including the net non-core funding dependence and net short-term non-core funding dependence,
both of which include brokered deposits in their calculation, because reciprocal brokered
deposits may have characteristics that differ from other brokered deposits.

40

Appendix B
Proposed FFIEC 051 for March 31, 2017: Changes Made to the FFIEC 041
(based on the FFIEC 041 for September 30, 2016)
Schedules Replaced by Schedule SU – Supplemental Information:
Schedule RC-D – Trading Assets and Liabilities
Schedule RC-P – 1-4 Family Residential Mortgage Banking Activities
Schedule RC-Q – Assets and Liabilities Measured at Fair Value on a Recurring Basis
Schedule RC-S – Servicing, Securitization, and Asset Sale Activities
Schedule RC-V – Variable Interest Entities
Schedules with a Change in Frequency of Collection:
1. Schedule RC-C, Part II – Loans to Small Businesses and Small Farms – For all institutions
that file the FFIEC 051, the frequency of collection will move from quarterly to semiannual
(June and December).
2. Schedule RC-A – Cash and Balances Due from Depository Institutions – Institutions with
less than $300 million in total assets are already exempt from completing this schedule. For
all other FFIEC 051 filers, the frequency of collection will move from quarterly to
semiannual (June and December).
Data Items Removed:
NOTE: In the following list of “Data Items Removed” from the proposed FFIEC 051, existing
FFIEC 041 data items that institutions with less than $1 billion in total assets are currently
exempt from reporting are marked with an asterisk (“*”). In addition, the list excludes two Call
Report data items that have been approved for removal by OMB effective March 31, 2017, in
accordance with the agencies’ July 13, 2016, Federal Register notice (81 FR 45357): Schedule
RI, Memorandum items 14.a and 14.b.
Schedule
RI

Item
1.a.(4)

RI
RI

1.e
2.c

RI

2.d

RI
RI
RI

5.c
5.e
M2*

Item Name
Loans to foreign governments and
official institutions
Interest income from trading assets
Interest on trading liabilities and
other borrowed money
Interest on subordinated notes and
debentures
Note: Items 2.c and 2.d of
Schedule RI will be combined into
one data item for “Other interest
expense.”
Trading revenue
Venture capital revenue
Income from the sale and servicing
of mutual funds and annuities
(included in Schedule RI, item 8)

41

MDRM Number
RIAD4056
RIAD4069
RIAD4185
RIAD4200

RIADA220
RIADB491
RIAD8431

Schedule
RI
RI
RI

Item
M8.a
M8.b
M8.c

RI
RI
RI

M8.d
M8.e
M8.f*

RI

M8.g*

RI

M9.a

RI

M9.b

RI
RI

M10
M13.a.(1)

RI

M13.b.(1)

RI

M15.a*

RI

M15.b*

Item Name
Interest rate exposures
Foreign exchange exposures
Equity security and index
exposures
Commodity and other exposures
Credit exposures
Impact on trading revenue of
changes in the creditworthiness of
the bank's derivatives
counterparties on the bank's
derivative assets (included in
Memorandum items 8.a through
8.e)
Impact on trading revenue of
changes in the creditworthiness of
the bank on the bank's derivative
liabilities (included in
Memorandum items 8.a through
8.e).
Net gains (losses) on credit
derivatives held for trading
Net gains (losses) on credit
derivatives held for purposes other
than trading
Credit losses on derivatives
Estimated net gains (losses) on
loans attributable to changes in
instrument-specific credit risk
Estimated net gains (losses) on
liabilities attributable to changes in
instrument-specific credit risk
Consumer overdraft-related
service charges levied on those
transaction account and nontransaction savings account
deposit products intended
primarily for individuals for
personal, household, or family use
Consumer account periodic
maintenance charges levied on
those transaction account and nontransaction savings account
deposit products intended
primarily for individuals for

42

MDRM Number
RIAD8757
RIAD8758
RIAD8759
RIAD8760
RIADF186
RIADK090

RIADK094

RIADC889
RIADC890

RIADA251
RIADF552

RIADF554

RIADH032

RIADH033

Schedule

Item

Item Name
personal, household, or family use

MDRM Number

RI

M15.c*

RIADH034

RI

M15.d*

RI-B, Part
I

2

RI-B, Part
I

6

RI-B, Part
I

M2.a

RI-B, Part
I

M2.b

RI-B, Part
I

M2.c

RI-B, Part
I

M2.d

RI-B, Part
II

M1

RI-C

1.a*

Consumer customer automated
teller machine (ATM) fees levied
on those transaction account and
non-transaction savings account
deposit products intended
primarily for individuals for
personal, household, or family use
All other service charges on
deposit accounts
Loans to depository institutions
and acceptances of other banks
(Columns A and B)
Loans to foreign governments and
official institutions (Columns A
and B)
Loans secured by real estate to
non-U.S. addressees (domicile)
(included in Schedule RI-B, part I,
item 1) (Columns A and B)
Loans to and acceptances of
foreign banks (included in
Schedule RI-B, part I, item 2)
(Columns A and B)
Commercial and industrial loans to
non-U.S. addressees (domicile)
(included in Schedule RI-B, part I,
item 4) (Columns A and B)
Leases to individuals for
household, family, and other
personal expenditures (included in
Schedule RI-B, part I, item 8)
(Columns A and B)
Allocated transfer risk reserve
included in Schedule RI-B, part II,
item 7
Construction loans (Columns A
through F)

43

RIADH035
RIAD4481, RIAD4482

RIAD4643, RIAD4627

RIAD4652, RIAD4662

RIAD4654, RIAD4664

RIAD4646, RIAD4618

RIADF185, RIADF187

RIADC435

RCONM708,
RCONM709,
RCONM710,RCONM711
,
RCONM712,RCONM713

Schedule
RI-C

Item
1.b*

Item Name
Commercial real estate loans
(Columns A through F)

RI-C

1.c*

Residential real estate loans
(Columns A through F)

RI-C

2*

Commercial loans (Columns A
through F)

RI-C

3*

Credit cards (Columns A through
F)

RI-C

4*

Other consumer loans (Columns A
through F)

RI-C
RI-C

5*
6*

Unallocated, if any
Total (for each column, sum of
items 1.a through 5) (Columns A
through F)

RC-B

M5.a*

RC-B

M5.b*

RC-B

M5.c*

Credit card receivables (Columns
A through D)
Home equity lines (Columns A
through D)
Automobile loans (Columns A
through D)

44

MDRM Number
RCONM714,
RCONM715,
RCONM716,
RCONM717,
RCONM719,
RCONM720
RCONM721,
RCONM722,
RCONM723,
RCONM724,
RCONM725,
RCONM726
RCONM727,
RCONM728,
RCONM729,
RCONM730,
RCONM731,
RCONM732
RCONM733,
RCONM734,
RCONM735,
RCONM736,
RCONM737,
RCONM738
RCONM739,
RCONM740,
RCONM741,
RCONM742,
RCONM743,
RCONM744
RCONM745
RCONM746,
RCONM747,
RCONM748,
RCONM749,
RCONM750,
RCONM751
RCONB838, RCONB839,
RCONB840, RCONB841
RCONB842, RCONB843,
RCONB844, RCONB845
RCONB846, RCONB847,
RCONB848, RCONB849

Schedule
RC-B

Item
M5.d*

RC-B

M5.e*

RC-B

M5.f*

RC-C,
Part I
RC-C,
Part I
RC-C,
Part I
RC-C,
Part I
RC-C,
Part I
RC-C,
Part I
RC-C,
Part I
RC-C,
Part I

2a.(1)

RC-C,
Part I
RC-C,
Part I
RC-C,
Part I

9.b.(1)

RC-C,
Part I
RC-C,
Part I
RC-C,
Part I
RC-C,
Part I
RC-C,
Part I
RC-C,
Part I

Item Name
Other consumer loans (Columns A
through D)
Commercial and industrial loans
(Columns A through D)
Other (Columns A through D)

MDRM Number
RCONB850, RCONB851,
RCONB852, RCONB853
RCONB854, RCONB855,
RCONB856, RCONB857
RCONB858, RCONB859,
RCONB860, RCONB861
RCONB532

2.c.(2)

To U.S. branches and agencies of
foreign banks
To other commercial banks in the
U.S.
To other depository institutions in
the U.S.
To foreign branches of other U.S.
banks
To other banks in foreign countries

4.a

To U.S. addressees (domicile)

RCON1763

4.b

To non-U.S. addressees (domicile)

RCON1764

7

RCON2081

10.b

Loans to foreign governments and
official institutions (including
foreign central banks)
Loans for purchasing or carrying
securities (secured and unsecured)
All other loans (exclude consumer
loans)
Leases to individuals for
household, family, and other
personal expenditures (i.e.,
consumer leases)
All other leases

M1.e.(1)

To U.S. addressees (domicile)

RCONK163

M1.e.(2)

To non-U.S. addressees (domicile)

RCONK164

M5

Loans secured by real estate to non RCONB837
U.S. addressees (domicile)
Construction, land development,
RCONF578
and other land loans
Secured by farmland (including
RCONF579
farm residential and other
improvements)

2a.(2)
2.b
2.c.(1)

9.b.(2)
10.a

M10.a.(1)
M10.a.(2)

45

RCONB533
RCONB534
RCONB536
RCONB537

RCON1545
RCONJ451
RCONF162

RCONF163

Schedule
RC-C,
Part I

Item
M10.a.(3)(a)

RC-C,
Part I
RC-C,
Part I
RC-C,
Part I
RC-C,
Part I
RC-C,
Part I
RC-C,
Part I
RC-C,
Part I
RC-C,
Part I
RC-C,
Part I
RC-C,
Part I
RC-C,
Part I
RC-C,
Part I

M10.a.(3)(b)(1
)
M10.a.(3)(b)(2
)
M10.a.(4)

RC-C,
Part I

M11.a.(3)(a)

RC-C,
Part I
RC-C,
Part I
RC-C,
Part I
RC-C,
Part I
RC-C,
Part I
RC-C,
Part I

M11.a.(3)(b)(1
)
M11.a.(3)(b)(2
)
M11.a.(4)

Item Name
MDRM Number
Revolving, open-end loans secured RCONF580
by 1-4 family residential
properties and extended under
lines of credit
Secured by first liens
RCONF581
Secured by junior liens

RCONF582

M10.b

Secured by multifamily (5 or
RCONF583
more) residential properties
Secured by nonfarm nonresidential RCONF584
properties
Commercial and industrial loans
RCONF585

M10.c.(1)

Credit cards

RCONF586

M10.c.(2)

Other revolving credit plans

RCONF587

M10.c.(3)

Automobile loans

RCONK196

M10.c.(4)

Other consumer loans

RCONK208

M10.d

Other loans

RCONF589

M11.a.(1)

Construction, land development,
and other land loans
Secured by farmland (including
farm residential and other
improvements)
Revolving, open-end loans secured
by 1-4 family residential
properties and extended under
lines of credit
Secured by first liens

RCONF590

Secured by junior liens

RCONF594

M10.a.(5)

M11.a.(2)

RCONF591

RCONF592

RCONF593

M11.b

Secured by multifamily (5 or
RCONF595
more) residential properties
Secured by nonfarm nonresidential RCONF596
properties
Commercial and industrial loans
RCONF597

M11.c.(1)

Credit cards

M11.a.(5)

RCONF598

46

Schedule
RC-C,
Part I
RC-C,
Part I
RC-C,
Part I
RC-C,
Part I
RC-C,
Part I
RC-C,
Part I
RC-C,
Part I

Item
M11.c.(2)

Item Name
Other revolving credit plans

MDRM Number
RCONF599

M11.c.(3)

Automobile loans

RCONK195

M11.c.(4)

Other consumer loans

RCONK209

M11.d

Other loans

RCONF601

M12.a

RCONG091,
RCONG092, RCONG093
RCONG094,
RCONG095, RCONG096
RCONG097,
RCONG098, RCONG099

RC-C,
Part I

M12.d

RC-E

M6.a*

RC-E

M6.b*

RC-E

M6.c*

RC-E

M7.a.(1)*

RC-E

M7.a.(2)*

Loans secured by real estate
(Columns A through C)
Commercial and industrial loans
(Columns A through C)
Loans to individuals for
household, family and other
personal expenditures (Columns A
through C)
All other loans and all leases
(Columns A through C)
Note: Memorandum items 12.a
through 12.d of Schedule RC-C,
Part I, will be combined into data
items for “Total loans and leases”
(Columns A through C).
Total deposits in those noninterestbearing transaction account
deposit products intended
primarily for individuals for
personal, household, or family use
Total deposits in those interestbearing transaction account
deposit products intended
primarily for individuals for
personal, household, or family use
Total deposits in all other
transaction accounts of
individuals, partnerships, and
corporations
Total deposits in those MMDA
deposit products intended
primarily for individuals for
personal, household, or family use
Deposits in all other MMDAs of
individuals, partnerships, and
corporations

M12.b
M12.c

47

RCONG100,
RCONG101, RCONG102

RCONP753

RCONP754

RCONP755

RCONP756

RCONP757

Schedule
RC-E

Item
M7.b.(1)*

RC-E

M7.b.(2)*

RC-L

1.a.(1)

RC-L

1.a.(2)

RC-L

2.a*

RC-L

3.a*

RC-L

7.a.(1)

RC-L

7.a.(2)

RC-L
RC-L

7.a.(3)
7.a.(4)

RC-L

7.b.(1)

RC-L

7.b.(2)

RC-L
RC-L
RC-L
RC-L

7.c.(1)(a)
7.c.(1)(b)
7.c.(2)(a)
7.c.(2)(b)

RC-L

7.c.(2)(c)

RC-L

7.d.(1)(a)

Item Name
Total deposits in those other
savings deposit account deposit
products intended primarily for
individuals for personal,
household, or family use
Deposits in all other savings
deposit accounts of individuals,
partnerships, and corporations
Unused commitments for Home
Equity Conversion Mortgage
(HECM) reverse mortgages
outstanding that are held for
investment (included in item 1.a
above)
Unused commitments for
proprietary reverse mortgages
outstanding that are held for
investment (included in item 1.a)
Amount of financial standby
letters of credit conveyed to others
Amount of performance standby
letters of credit conveyed to others
Credit default swaps (Columns A
and B)
Total return swaps (Columns A
and B)
Credit options (Columns A and B)
Other credit derivatives (Columns
A and B)
Gross positive fair value (Columns
A and B)
Gross negative fair value
(Columns A and B)
Sold protection
Purchased protection
Sold protection
Purchased protection that is
recognized as a guarantee for
regulatory capital purposes
Purchased protection that is not
recognized as a guarantee for
regulatory capital purposes
Investment grade (Columns A
through C)

48

MDRM Number
RCONP758

RCONP759

RCONJ477

RCONJ478

RCON3820
RCON3822
RCONC968, RCONC969
RCONC970, RCONC971
RCONC972, RCONC973
RCONC974, RCONC975
RCONC219, RCONC221
RCONC220, RCONC222
RCONG401
RCONG402
RCONG403
RCONG404

RCONG405

RCONG406,
RCONG407, RCONG408

Schedule
RC-L

Item
7.d.(1)(b)

RC-L

7.d.(2)(a)

RC-L

7.d.(2)(b)

RC-L
RC-L

8
9.b

RC-L

10.a

RC-L

12.a

RC-L

12.b

RC-L

12.c.(1)

RC-L

12.c.(2)

RC-L

12.d.(1)

RC-L

12.d.(2)

RC-L

12.e

RC-L

13

RC-L

14

RC-L

14.a

RC-L

15.a.(1)

RC-L

15.a.(2)

RC-L

15.b.(1)

RC-L

15.b.(2)

Item Name
Sub-investment grade (Columns A
through C)
Investment grade (Columns A
through C)
Sub-investment grade (Columns A
through C)
Spot foreign exchange contracts
Commitments to purchase whenissued securities
Commitments to sell when-issued
securities
Futures contracts (Columns A
through D)
Forward contracts (Columns A
through D)
Written options (Columns A
through D)
Purchased options (Columns A
through D)
Written options (Columns A
through D)
Purchased options (Columns A
through D)
Swaps (Columns A through D)
Total gross notional amount of
derivative contracts held for
trading (Columns B through D)
Total gross notional amount of
derivative contracts held for
purposes other than trading
(Columns B through D)
Interest rate swaps where the bank
has agreed to pay a fixed rate
Gross positive fair value (Columns
A through D)
Gross negative fair value
(Columns A through D)
Gross positive fair value (Columns
A through D)
Gross negative fair value
(Columns A through D)
49

MDRM Number
RCONG409,
RCONG410, RCONG411
RCONG412,
RCONG413, RCONG414
RCONG415,
RCONG416, RCONG417
RCON8765
RCON3434
RCON3435
RCON8693, RCON8694,
RCON8695, RCON8696
RCON8697, RCON8698,
RCON8699, RCON8700
RCON8701, RCON8702,
RCON8703, RCON8704
RCON8705, RCON8706,
RCON8707, RCON8708
RCON8709, RCON8710,
RCON8711, RCON8712
RCON8713, RCON8714,
RCON8715, RCON8716
RCON3450, RCON3826,
RCON8719, RCON8720
RCONA127, RCON8723,
RCON8724
RCON8726, RCON8727,
RCON8728

RCONA589
RCON8733, RCON8734,
RCON8735, RCON8736
RCON8737, RCON8738,
RCON8739, RCON8740
RCON8741, RCON8742,
RCON8743, RCON8744
RCON8745, RCON8746,
RCON8747, RCON8748

Schedule
RC-L

Item
16.a*

Item Name
Net current credit exposure
(Columns A through E)

RC-L

16.b.(1)*

Cash - U.S. dollar (Columns A
through E)

RC-L

16.b.(2)*

Cash - Other currencies (Columns
A through E)

RC-L

16.b.(3)*

U.S. Treasury securities (Columns
A through E)

RC-L

16.b.(4)*

RC-L

16.b.(5)*

U.S. Government agency and U.S.
Government-sponsored agency
debt securities (Columns A
through E)
Corporate bonds (Columns A
through E)

RC-L

16.b.(6)*

Equity securities (Columns A
through E)

RC-L

16.b.(7)*

All other collateral (Columns A
through E)

RC-L

16.b.(8)*

Total fair value of collateral (sum
of items 16.b.(1) through (7))
(Columns A through E)

RC-M

13.a.(1)(a)(1)

RC-M

13.a.(1)(a)(2)

RC-M
RC-M

13.a.(1)(b)
13.a.(1)(c)(1)

1-4 family residential construction
loans
Other construction loans and all
RCONK170
land development and other land
loans
Secured by farmland
RCONK171
Revolving, open-end loans secured RCONK172
by 1-4 family residential
properties and extended under
50

MDRM Number
RCONG418,
RCONG419,
RCONG420,
RCONG421, RCONG422
RCONG423,
RCONG424,
RCONG425,
RCONG426, RCONG427
RCONG428,
RCONG429,
RCONG430,
RCONG431, RCONG432
RCONG433,
RCONG434,
RCONG435,
RCONG436, RCONG437
RCONG438,
RCONG439,
RCONG440,
RCONG441, RCONG442
RCONG443,
RCONG444,
RCONG445,
RCONG446, RCONG447
RCONG448,
RCONG449,
RCONG450,
RCONG451, RCONG452
RCONG453,
RCONG454,
RCONG455,
RCONG456, RCONG457
RCONG458,
RCONG459,
RCONG460,
RCONG461, RCONG462
RCONK169

Schedule

Item

RC-M

13.a.(1)(c)(2)(a Secured by first liens
)
13.a.(1)(c)(2)(b Secured by junior liens
)
13.a.(1)(d)
Secured by multifamily (5 or
more) residential properties
13.a.(1)(e)(1)
Loans secured by owner-occupied
nonfarm nonresidential properties
13.a.(1)(e)(2)
Loans secured by other nonfarm
nonresidential properties
13.a.(3)
Commercial and industrial loans
13.a.(4)(a)
Credit cards
13.a.(4)(b)
Automobile loans
13.a.(4)(c)
Other (includes revolving credit
plans other than credit cards and
other consumer loans)
13.a.(5)
All other loans and all leases
13.b.(1)
Construction, land development,
and other land
13.b.(2)
Farmland
13.b.(3)
1-4 family residential properties
13.b.(4)
Multifamily (5 or more) residential
properties
13.b.(5)
Nonfarm nonresidential properties
13.c
Debt securities (included in
Schedule RC, items 2.a and 2.b)
13.d
Other assets (exclude FDIC losssharing indemnification assets)
6
Loans to foreign governments and
official institutions (Columns A
through C)
11a.(1)(a)
1-4 family residential construction
loans (Columns A through C)
11.a.(1)(b)
Other construction loans and all
land development and other land
loans (Columns A through C)
11.a.(2)
Secured by farmland (Columns A
through C)
11.a.(3)(a)
Revolving, open-end loans secured
by 1-4 family residential
properties and extended under

RC-M
RC-M
RC-M
RC-M
RC-M
RC-M
RC-M
RC-M

RC-M
RC-M
RC-M
RC-M
RC-M
RC-M
RC-M
RC-M
RC-N

RC-N
RC-N

RC-N
RC-N

Item Name
lines of credit

MDRM Number

51

RCONK173
RCONK174
RCONK175
RCONK176
RCONK177
RCONK179
RCONK180
RCONK181
RCONK182

RCONK183
RCONK187
RCONK188
RCONK189
RCONK190
RCONK191
RCONJ461
RCONJ462
RCON5389, RCON5390,
RCON5391
RCONK045,
RCONK046, RCONK047
RCONK048,
RCONK049, RCONK050
RCONK051,
RCONK052, RCONK053
RCONK054,
RCONK055, RCONK056

Schedule

Item

RC-N

11.a.(3)(b)(1)

RC-N

11.a.(3)(b)(2)

RC-N

11.a.(4)

RC-N

11.a.(5)(a)

RC-N

11.a.(5)(b)

RC-N

11.c

RC-N

11.d.(1)

RC-N

11.d.(2)

RC-N

11.d.(3)

RC-N

11.e

RC-N

M1.e.(1)

RC-N

M1.e.(2)

RC-N

M3.a

RC-N

M3.b

RC-N

M3.c

Item Name
lines of credit (Columns A through
C)
Secured by first liens (Columns A
through C)
Secured by junior liens (Columns
A through C)
Secured by multifamily (5 or
more) residential properties
(Columns A through C)
Loans secured by owner-occupied
nonfarm nonresidential properties
(Columns A through C)
Loans secured by other nonfarm
nonresidential properties
(Columns A through C)
Commercial and industrial loans
(Columns A through C)
Credit cards (Columns A through
C)
Automobile loans (Columns A
through C)
Other (includes revolving credit
plans other than credit cards and
other consumer loans) (Columns A
through C)
All other loans and all leases
(Columns A through C)
To U.S. addressees (domicile)
(Columns A through C)
To non-U.S. addressees (domicile)
(Columns A through C)
Loans secured by real estate to
non-U.S. addressees (domicile)
(included in Schedule RC-N, item
1) (Columns A through C)
Loans to and acceptances of
foreign banks (included in
Schedule RC-N, item 2) (Columns
A through C)
Commercial and industrial loans to
non-U.S. addressees (domicile)
(included in Schedule RC-N, item
4) (Columns A through C)

52

MDRM Number

RCONK057,
RCONK058, RCONK059
RCONK060,
RCONK061, RCONK062
RCONK063,
RCONK064, RCONK065
RCONK066,
RCONK067, RCONK068
RCONK069,
RCONK070, RCONK071
RCONK075,
RCONK076, RCONK077
RCONK078,
RCONK079, RCONK080
RCONK081,
RCONK082, RCONK083
RCONK084,
RCONK085, RCONK086

RCONK087,
RCONK088, RCONK089
RCONK120,
RCONK121, RCONK122
RCONK123,
RCONK124, RCONK125
RCON1248, RCON1249,
RCON1250

RCON5380, RCON5381,
RCON5382

RCON1254, RCON1255,
RCON1256

Schedule
RC-N

Item
M3.d

RC-N

M5.b.(1)

RC-N

M5.b.(2)

RC-N

M6

RC-O

M2*

RC-O
RC-O
RC-O
RC-O
RC-O

M6.a*
M6.b*
M6.c*
M6.d*
M7.a*

RC-O

M7.b*

RC-O
RC-O

M8.a*
M8.b*

RC-O

M9.a*

RC-O

M9.b*

RC-O
RC-O

M10.a*
M10.b*

RC-O

M11*

RC-O

M12*

Item Name
Leases to individuals for
household, family, and other
personal expenditures (included in
Schedule RC-N, item 8) (Columns
A through C)
Loans measured at fair value: Fair
value (Columns A through C)
Loans measured at fair value:
Unpaid principal balance
(Columns A through C)
Derivative contracts: Fair value of
amounts carried as assets
(Columns A and B)
Estimated amount of uninsured
deposits, including related interest
accrued and unpaid
Special mention
Substandard
Doubtful
Loss
Nontraditional 1-4 family
residential mortgage loans
Securitizations of nontraditional 14 family residential mortgage
loans
Higher-risk consumer loans
Securitizations of higher-risk
consumer loans
Higher-risk commercial and
industrial loans and securities
Securitizations of higher-risk
commercial and industrial loans
and securities
Total unfunded commitments
Portion of unfunded commitments
guaranteed or insured by the U.S.
government (including the FDIC)
Amount of other real estate owned
recoverable from the U.S.
government under guarantee or
insurance provisions (excluding
FDIC loss-sharing agreements)
Nonbrokered time deposits of
more than $250,000 (included in
53

MDRM Number
RCONF166, RCONF167,
RCONF168

RCONF664, RCONF665,
RCONF666
RCONF667, RCONF668,
RCONF669
RCON3529, RCON3530

RCON5597

RCONK663
RCONK664
RCONK665
RCONK666
RCONN025
RCONN026

RCONN027
RCONN028
RCONN029
RCONN030

RCONK676
RCONK677

RCONK669

RCONK678

Schedule

Item

RC-O

M13.a*

RC-O

M13.b*

RC-O

M13.c*

RC-O

M13.d*

RC-O
RC-O

M13.e*
M13.f*

RC-O

M13.g*

RC-O

M13.h*

RC-O

M14*

RC-O

M15*

RC-O

M16*

RC-O

M17.a*

Item Name
Schedule RC-E, Memorandum
item 2.d)
Construction, land development,
and other land loans secured by
real estate
Loans secured by multifamily
residential and nonfarm
nonresidential properties
Closed-end loans secured by first
liens on 1-4 family residential
properties
Closed-end loans secured by
junior liens on 1-4 family
residential properties and
revolving, open-end loans secured
by 1-4 family residential
properties and extended under
lines of credit
Commercial and industrial loans
Credit card loans to individuals for
household, family, and other
personal expenditures
All other loans to individuals for
household, family, and other
personal expenditures
Non-agency residential mortgagebacked securities
Amount of the institution's largest
counterparty exposure
Total amount of the institution's 20
largest counterparty exposures
Portion of loans restructured in
troubled debt restructurings that
are in compliance with their
modified terms and are guaranteed
or insured by the U.S. government
(including the FDIC) (included in
Schedule RC-C, part I,
Memorandum item 1)
Total deposit liabilities before
exclusions (gross) as defined in
Section 3(l) of the Federal Deposit
Insurance Act and FDIC
regulations

54

MDRM Number

RCONN177

RCONN178

RCONN179

RCONN180

RCONN181
RCONN182

RCONN183

RCONM963
RCONK673
RCONK674
RCONL189

RCONL194

Schedule
RC-O

Item
M17.b*

Item Name
Total allowable exclusions,
including interest accrued and
unpaid on allowable exclusions
Unsecured "Other borrowings"
with a remaining maturity of one
year or less
Estimated amount of uninsured
deposits, including related interest
accrued and unpaid
"Nontraditional 1-4 family
residential mortgage loans" as
defined for assessment purposes
only in FDIC regulations
(Columns A through O)

RC-O

M17.c*

RC-O

M17.d*

RC-O

M18.a*

RC-O

M18.b*

Closed-end loans secured by first
liens on 1-4 family residential
properties (Columns A through O)

RC-O

M18.c*

Closed-end loans secured by
junior liens on 1-4 family
residential properties (Columns A
through O)

55

MDRM Number
RCONL195

RCONL196

RCONL197

RCONM964,
RCONM965,
RCONM966,
RCONM967,
RCONM968,
RCONM969,
RCONM970,
RCONM971,
RCONM972,
RCONM973,
RCONM974,
RCONM975,
RCONM976,
RCONM977,
RCONM978
RCONM979,
RCONM980,
RCONM981,
RCONM982,
RCONM983,
RCONM984,
RCONM985,
RCONM986,
RCONM987,
RCONM988,
RCONM989,
RCONM990,
RCONM991,
RCONM992,
RCONM993
RCONM994,
RCONM995,
RCONM996,
RCONM997,
RCONM998,
RCONM999,

Schedule

Item

RC-O

M18.d*

RC-O

M18.e*

RC-O

M18.f*

Item Name

MDRM Number
RCONN001,
RCONN002,
RCONN003,
RCONN004,
RCONN005,
RCONN006,
RCONN007,
RCONN008, RCONN009
Revolving, open-end loans secured RCONN010,
by 1-4 family residential
RCONN011,
properties and extended under
RCONN012,
lines of credit (Columns A through RCONN013,
O)
RCONN014,
RCONN015,
RCONN016,
RCONN017,
RCONN018,
RCONN019,
RCONN020,
RCONN021,
RCONN022,
RCONN023, RCONN024
Credit cards (Columns A through
RCONN040,
O)
RCONN041,
RCONN042,
RCONN043,
RCONN044,
RCONN045,
RCONN046,
RCONN047,
RCONN048,
RCONN049,
RCONN050,
RCONN051,
RCONN052,
RCONN053, RCONN054
Automobile loans (Columns A
RCONN055,
through O)
RCONN056,
RCONN057,
RCONN058,
RCONN059,
RCONN060,
RCONN061,
RCONN062,
RCONN063,

56

Schedule

Item

Item Name

RC-O

M18.g*

Student loans (Columns A through
O)

RC-O

M18.h*

Other consumer loans and
revolving credit plans other than
credit cards (Columns A through
O)

RC-O

M18.i*

Consumer leases (Columns A
through O)

57

MDRM Number
RCONN064,
RCONN065,
RCONN066,
RCONN067,
RCONN068, RCONN069
RCONN070,
RCONN071,
RCONN072,
RCONN073,
RCONN074,
RCONN075,
RCONN076,
RCONN077,
RCONN078,
RCONN079,
RCONN080,
RCONN081,
RCONN082,
RCONN083, RCONN084
RCONN085,
RCONN086,
RCONN087,
RCONN088,
RCONN089,
RCONN090,
RCONN091,
RCONN092,
RCONN093,
RCONN094,
RCONN095,
RCONN096,
RCONN097,
RCONN098, RCONN099
RCONN100,
RCONN101,
RCONN102,
RCONN103,
RCONN104,
RCONN105,
RCONN106,
RCONN107,
RCONN108,
RCONN109,
RCONN110,
RCONN111,

Schedule

Item

Item Name

MDRM Number
RCONN112,
RCONN113, RCONN114

RC-O

M18.j*

Total (Columns A through N)

RCONN115,
RCONN116,
RCONN117,
RCONN118,
RCONN119,
RCONN120,
RCONN121,
RCONN122,
RCONN123,
RCONN124,
RCONN125,
RCONN126,
RCONN127, RCONN128

Data Items with a Change in Frequency of Collection:
Semiannual Reporting (June and December)
Schedule Item
Item Name
RC-B
M6.a
Structured financial products by underlying
through collateral or reference assets (Columns A
M6.g
through D)

58

MDRM Number
RCONG348,
RCONG349,
RCONG350,
RCONG351,
RCONG352,
RCONG353,
RCONG354,
RCONG355,
RCONG356,
RCONG357,
RCONG358,
RCONG359,
RCONG360,
RCONG361,
RCONG362,
RCONG363,
RCONG364,
RCONG365,
RCONG366,
RCONG367,
RCONG368,
RCONG369,
RCONG370,
RCONG371,

Schedule Item

Item Name

MDRM Number
RCONG372,
RCONG373,
RCONG374,
RCONG375

RC-C,
Part I

M4

RCON5370

RC-F

6.a
through
6.i

Adjustable-rate closed-end loans secured by
first liens on 1–4 family residential
properties (included in Schedule RC-C, Part
I, item 1.c.(2)(a), column B)
All other assets: itemized items greater than
$100,000 that exceed 25 percent of this item

RC-G

4.a
through
4.g

RC-L

9.c
through
9.f

RC-L

10.b
through
10.e

RC-N

M5.a

RCON2166,
RCON1578,
RCONC010,
RCONC436,
RCONJ448,
RCON3549,
RCON3550,
RCON3551
All other liabilities: itemized items greater
RCON3066,
than $100,000 that exceed 25 percent of this RCONC011,
item
RCON2932,
RCONC012,
RCON3552,
RCON3553,
RCON3554
All other off-balance sheet liabilities
RCONC978,
(exclude derivatives): itemized items over
RCON3555,
25 percent of Schedule RC, item 27.a. "Total RCON3556,
bank equity capital"
RCON3557
All other off-balance sheet assets (exclude
RCONC5592,
derivatives): itemized items over 25 percent RCON5593,
of Schedule RC, item 27.a. "Total bank
RCON5594,
equity capital"
RCON5595
Loans and leases held for sale (Columns A
RCONC240,
through C)
RCONC241,
RCONC226

59

Annual Reporting (December)
Schedule Item
Item Name
RI
M12
Noncash income from negative amortization
on closed-end loans secured by 1-4 family
residential properties (included in Schedule
RI, item 1.a.(1)(a))
RC-C,
M8.b
Total maximum remaining amount of
Part I
negative amortization contractually
permitted on closed-end loans secured by 1–
4 family residential properties.
RC-C,
M8.c
Total amount of negative amortization on
Part I
closed-end loans secured by 1–4 family
residential properties included in the amount
reported in Memorandum item 8.a
RC-M
6
Does the reporting bank sell private label or
third-party mutual funds and annuities?
RC-M
7
Assets under the reporting bank’s
management in proprietary mutual funds and
annuities
RC-M
9
Do any of the bank’s Internet websites have
transactional capability, i.e., allow the
bank’s customers to execute transactions on
their accounts through the website?
RC-M
11
Does the bank act as trustee or custodian for
Individual Retirement Accounts, Health
Savings Accounts, and other similar
accounts?
RC-M
12
Does the bank provide custody, safekeeping,
or other services involving the acceptance of
order for the sale or purchase of securities?
RC-M
14.a
Total assets of captive insurance subsidiaries
RC-M
14.b
Total assets of captive reinsurance
subsidiaries

60

MDRM Number
RIADF228

RCONF231

RCONF232

RCONB569
RCONB570

RCON4088

RCONG463

RCONG464

RCONK193
RCONK194

Data Items Moved to Schedule SU – Supplemental Information:
Schedule Item
RI
M13.a

Item Name
Net gains (losses) on assets

MDRM Number
RIADF551

RI

M13.b

Net gains (losses) on liabilities

RIADF553

RI-B,
Part I

M4

RIADC388

RI-B,
Part II

M2

RI-B,
Part II

M3

RC-C,
Part I

M6

RC-L

13

RC-L

14

RC-M

13.b.(7)

RC-N

11.f

RC-S

M4

Uncollectible retail credit card fees and
finance charges reversed against
income (i.e., not included in chargeoffs against the allowance for loan and
lease losses)
Separate valuation allowance for
uncollectible retail credit card fees and
finance charges
Amount of allowance for loan and
lease losses attributable to retail credit
card fees and finance charges
Outstanding credit card fees and
finance charges included in Schedule
RC-C, part I, item 6.a
Total gross notional amount of
derivative contracts held for trading
(Column A)
Total gross notional amount of
derivative contracts held for purposes
other than trading (Columns A)
Portion of covered other real estate
owned included in items 13.b.(1)
through (5) that is protected by FDIC
loss-sharing agreements
Portion of covered loans and leases
included in items 11.a through 11.e that
is protected by FDIC loss-sharing
agreements (Columns A through C)
Outstanding fees and credit card
charges included in Schedule RC-S,
item 1, column C

61

RIADC389

RIADC390

RCONC391

RCONA126

RCON8725

RCONK192

RCONK102,
RCONK103,
RCONK104
RCONC407

Appendix C
FFIEC 031 for March 31, 2017: Data Items Removed or Change in Reporting Threshold
Data Items Removed
Schedule
Item
RI-B, Part 2.a
I
RI-B, Part
I
RC-C, Part
II

RC-C, Part
II
RC-C, Part
II
RC-C, Part
II

RC-C, Part
II
RC-C, Part
II
RC-E, Part
I
RC-M

RC-M
RC-M
RC-M
RC-M

Item Name
Loans to and acceptances of U.S. banks
and other U.S. depository institutions
(Column A and Column B)
2.b
Loans to and acceptances of foreign banks
(Column A and Column B)
1
Yes/No indicator whether all or
substantially all of the dollar volume of
‘loans secured by nonfarm nonresidential
properties’ and ‘commercial and industrial
loans to U.S. addressees’ have original
amounts of $100,000 or less
2.a
Total number of loans secured by nonfarm
nonresidential properties currently
outstanding
2.b
Total number of commercial and industrial
loans to U.S. addressees currently
outstanding
5
Yes/No indicator whether all or
substantially all of the dollar volume of
‘Loans secured by farmland’ and ‘Loans
to finance agricultural production and
other loans to farmers’ have original
amounts of $100,000 or less
6.a
Total number of loans secured by
farmland currently outstanding
6.b
Total number of loans to finance
agricultural production and other loans to
farmers currently outstanding
M6.c
Total deposits in all other transaction
accounts of individuals, partnerships, and
corporations
13.a.(2)
Loans to finance agricultural production
and other loans to farmers covered by
loss-sharing agreements with the FDIC
13.a.(3)
Commercial and industrial loans covered
by loss-sharing agreements with the FDIC
13.a.(4)(a) Credit card loans covered by loss-sharing
agreements with the FDIC
13.a.(4)(b) Automobile loans covered by loss-sharing
agreements with the FDIC
13.a.(4)(c) All other consumer loans covered by loss62

MDRM Number
RIAD4653,
RIAD4663
RIAD4654,
RIAD4664
RCON6999

RCON5562

RCON5563

RCON6860

RCON5576
RCON5577

RCONP755

RCFDK178

RCFDK179
RCFDK180
RCFDK181
RCFDK182

Schedule

Item

RC-N

11.b

RC-N

11.c

RC-N

11.d.(1)

RC-N

11.d.(2)

RC-N

11.d.(3)

Item Name
sharing agreements with the FDIC
Loans to finance agricultural production
and other loans to farmers covered by
loss-sharing agreements with the FDIC
(Column A through Column C)
Commercial and industrial loans covered
by loss-sharing agreements with the FDIC
(Column A through Column C)
Credit card loans covered by loss-sharing
agreements with the FDIC (Column A
through Column C)
Automobile loans covered by loss-sharing
agreements with the FDIC (Column A
through Column C)
All other consumer loans covered by losssharing agreements with the FDIC
(Column A through Column C)

MDRM Number
RCFDK072,
RCFDK073,
RCFDK074
RCFDK075,
RCFDK076,
RCFDK077
RCFDK078,
RCFDK079,
RCFDK080
RCFDK081,
RCFDK082,
RCFDK083
RCFDK084,
RCFDK085,
RCFDK086

Change in Reporting Threshold
To be completed by banks with $10 billion or more in total assets
Schedule
Item
Item Name
RI
M9.a
Net gains (losses) on credit derivatives held
for trading
RI
M9.b
Net gains (losses) on credit derivatives held
for purposes other than trading
RC-E, Part 1
Deposits of Individuals, partnerships, and
II
corporations (include all certified and
official checks)
RC-E, Part 2
Deposits of U.S. banks and other U.S.
II
depository institutions in foreign offices
RC-E, Part 3
Deposits of foreign banks in foreign offices
II
RC-E, Part 4
Deposits of foreign governments and
II
official institutions in foreign offices
RC-E, Part 5
Deposits of U.S. Government and states and
II
political subdivisions in the U.S in foreign
offices
RC-E, Part 6
Total deposits in foreign offices
II

MDRM Number
RIADC889
RIADC890
RCFNB553

RCFNB554
RCFN2625
RCFN2650
RCFNB555

RCFN2200

NOTE: The preceding list of “Data Items Removed” from the FFIEC 031 excludes two Call
Report data items that have been approved for removal by OMB effective March 31, 2017, in
accordance with the agencies’ July 13, 2016, Federal Register notice (81 FR 45357): Schedule

63

RI, Memorandum items 14.a and 14.b.

Change in Reporting Threshold
To be completed by banks with $10 million or more in average trading assets
Schedule
Item
Item Name
MDRM Number
RI
M8.a
Trading revenue from interest rate
RIAD8757
exposures
RI
M8.b
Trading revenue from foreign exchange
RIAD8758
exposures
RI
M8.c
Trading revenue from equity security and
RIAD8759
index exposures
RI
M8.d
Trading revenue from commodity and other RIAD8760
exposures
RI
M8.e
Trading revenue from credit exposures
RIADF186

64

Appendix D
FFIEC 041 for March 31, 2017: Data Items Removed or Change in Reporting Threshold
Data Items Removed
Schedule
Item
RI
1.a.(4)
RI
RI-B, Part
I
RI-B, Part
I
RC-C, Part
I
RC-C, Part
I

RC-C, Part
I
RC-C, Part
I

RC-C, Part
I
RC-E

RC-M
RC-M
RC-M
RC-M
RC-N

Item Name
Interest on loans to foreign governments
and official institutions
1.e
Interest income from trading assets
2
Loans to depository institutions and
acceptances of other banks (Column A
through Column B)
6
Loans to foreign governments and official
institutions (Column A through Column B)
2.a.(1)
Loans to U.S. branches and agencies of
foreign banks
2.a.(2)
Loans to other commercial banks in the
U.S.
Note: Items 2.a.(1) and 2.a.(2) of Schedule
RC-C, Part I, will be combined into one
data item for total loans to commercial
banks in the U.S.
2.c.(1)
Loans to foreign branches of other U.S.
banks
2.c.(2)
Loans to other banks in foreign countries
Note: Items 2.c.(1) and 2.c.(2) of Schedule
RC-C, Part I, will be combined into one
data item for total loans to banks in foreign
countries.
7
Loans to foreign governments and official
institutions (including foreign central
banks)
M6.c
Total deposits in all other transaction
accounts of individuals, partnerships, and
corporations
13.a.(3)
Commercial and industrial loans covered
by loss-sharing agreements with the FDIC
13.a.(4)(a) Credit card loans covered by loss-sharing
agreements with the FDIC
13.a.(4)(b) Automobile loans covered by loss-sharing
agreements with the FDIC
13.a.(4)(c) All other consumer loans covered by losssharing agreements with the FDIC
6
Loans to foreign governments and official
institutions (Column A through Column C)

65

MDRM Number
RIAD4056
RIAD4069
RIAD4481,
RIAD4482
RIAD4643,
RIAD4627
RCONB532
RCONB533

RCONB536
RCONB537

RCON2081

RCONP755

RCONK179
RCONK180
RCONK181
RCONK182
RCON5389,
RCON5390,
RCON5391

Schedule
RC-N

Item
11.c

RC-N

11.d.(1)

RC-N

11.d.(2)

RC-N

11.d.(3)

RC-N

M6

Item Name
Commercial and industrial loans covered
by loss-sharing agreements with the FDIC
(Column A through Column C)
Credit card loans covered by loss-sharing
agreements with the FDIC (Column A
through Column C)
Automobile loans covered by loss-sharing
agreements with the FDIC (Column A
through Column C)
All other consumer loans covered by losssharing agreements with the FDIC
(Column A through Column C)
Derivative contracts: fair value of amounts
carried as assets (Column A through
Column B)

MDRM Number
RCONK075,
RCONK076,
RCONK077
RCONK078,
RCONK079,
RCONK080
RCONK081,
RCONK082,
RCONK083
RCONK084,
RCONK085,
RCONK086
RCON3529,
RCON3530

NOTE: The preceding list of “Data Items Removed” from the FFIEC 041 excludes two Call
Report data items that have been approved for removal by OMB effective March 31, 2017, in
accordance with the agencies’ July 13, 2016, Federal Register notice (81 FR 45357): Schedule
RI, Memorandum items 14.a and 14.b.
Change in Reporting Threshold
To be completed by banks with $10 billion or more in total assets
Schedule
Item
Item Name
MDRM Number
RI
M9.a
Net gains (losses) on credit derivatives held RIADC889
for trading
RI
M9.b
Net gains (losses) on credit derivatives held RIADC890
for purposes other than trading
Change in Reporting Threshold
To be completed by banks with $10 million or more in average trading assets
Schedule
Item
Item Name
MDRM Number
RI
M8.a
Trading revenue from interest rate
RIAD8757
exposures
RI
M8.b
Trading revenue from foreign exchange
RIAD8758
exposures
RI
M8.c
Trading revenue from equity security and
RIAD8759
index exposures
RI
M8.d
Trading revenue from commodity and
RIAD8760
other exposures
RI
M8.e
Trading revenue from credit exposures
RIADF186

66