These quarterly reporting requirements
were established by the Federal Financial Institutions Examination
Council (FFIEC) for banks that quality for and adopt the Advanced
Capital Adequacy Framework or are in the parallel run state of
qualifying for the framework. The revisions to the FFIEC 101 report
are limited to removing two credit valuation adjustment (CVA) items
from the exposure at default (EAD) column on FFIEC 101 Schedule B,
Summary Risk-Weighted Asset Information for Banks Approved to Use
Advanced Internal Ratings-Based and Advanced Measurement Approaches
for Regulatory Capital Purposes (items 31.a and 31.b, column D).
These revisions take effect as of the September 30, 2017, report
date. However, reporting entities would be advised that they may
elect to adopt the changes by ceasing to report column D of items
31.a and 31.b on FFIEC 101 Schedule B as of the June 30, 2017,
report date.
The agencies propose
under the emergency clearance provisions of OMB’s regulations to
revise the FFIEC 101 for the June 30, 2018, report date. The
agencies have determined that (1) the collection of information
within the scope of this request is needed prior to the expiration
of time periods established under 5 CFR 1320.10, (2) this
collection of information is essential to the mission of the
agencies, and (3) the agencies cannot reasonably comply with the
normal clearance procedures because an unanticipated event has
occurred and the use of normal clearance procedures is reasonably
likely to prevent or disrupt the collection of information. These
revisions arise from Congressional enactment of the EGRRCPA.
Section 214 of EGRRCPA requires the agencies to revise the
definition of HVCRE exposures that institutions use to calculate
risk-based capital. This provision became effective automatically
when the law was signed on May 24, 2018. The agencies must receive
data from the quarterly FFIEC 101 report to assess and monitor the
levels and components of each reporting entity’s risk-based capital
requirements and the adequacy of the entity’s capital under the
framework. The next reports are due at varying dates through the
end of August 2018, based on information as of June 30, 2018. In
order for the agencies to implement Section 214 as required by law,
the agencies cannot comply with the normal clearance process and
still receive the June 30, 2018, financial data in a timely manner.
With respect to the HVCRE exposures that are the subject of this
submission, Section 214 of EGRRCPA adds a new Section 51 to the
Federal Deposit Insurance Act governing the requirements for
certain acquisition, development, or construction (ADC) loans. The
agencies may only require a depository institution to assign a
heightened risk weight to an HVCRE exposure if such exposure is an
“HVCRE ADC Loan,” as defined in Section 214 of EGRRCPA. To avoid
the regulatory burden associated with applying different
definitions for HVCRE exposures across the FFIEC 101, Call Report,
and FR Y-9C within a single organization, the agencies propose to
allow an institution subject to the advanced approaches rule to
estimate and report HVCRE exposures on Schedules B and G of the
FFIEC 101 using the definition under Section 214 effective for the
June 30, 2018, report date. Alternatively, institutions may report
HVCRE exposures using the prior definition contained in the
agencies’ regulatory capital rules until the agencies take further
action.
On behalf of this Federal agency, I certify that
the collection of information encompassed by this request complies
with 5 CFR 1320.9 and the related provisions of 5 CFR
1320.8(b)(3).
The following is a summary of the topics, regarding
the proposed collection of information, that the certification
covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a
benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control
number;
If you are unable to certify compliance with any of
these provisions, identify the item by leaving the box unchecked
and explain the reason in the Supporting Statement.
Form FFIEC 101 Advanced Capital Adequacy Framework Regulatory Reporting Requirments
SPST-0159 Advanced Capital Adequacy Framework FFIEC 101 073118.docx
Interagency Statement.pdf
Advanced Capital Adequacy Framework Regulatory Reporting Requirments