IHCs

Regulatory Capital Reporting for Institutions Subject to the Advanced Capital Adequacy Framework

FFIEC101_202006_si_draft

IHCs

OMB: 7100-0319

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DRAFT
I. CBLR Supplemental Instructions (Call Report)
Background:
The Community Bank Leverage Ratio (CBLR) framework provides a simple measure of capital adequacy
for certain qualifying community banking organizations. In November 2019, the agencies issued a final
rule establishing the CBLR framework, which became effective January 1, 2020.
On April 23, 2020, the agencies published two interim final rules to provide temporary relief to community
banking organizations with respect to the CBLR framework. The statutory interim final rule implements
Section 4012 of the Coronavirus Aid, Relief, and Economic Security (CARES) Act, which requires the
agencies to temporarily lower the community bank leverage ratio qualifying criterion to 8 percent. The
temporary changes to the community bank leverage ratio framework implemented by the statutory interim
final rule will cease to be effective as of the earlier of the termination date of the national emergency
concerning the coronavirus disease declared by the President on March 13, 2020, under the National
Emergencies Act, or December 31, 2020. After this date, the transition interim final rule becomes effective
and provides community banking organizations with a clear and gradual transition, by January 1, 2022,
back to the greater than 9 percent leverage ratio qualifying criterion previously established by the
agencies. The other qualifying criteria in the CBLR framework have not been modified by the interim final
rules.
The agencies have also published interim final rules related to the Money Market Mutual Fund Liquidity
Facility (MMLF) and Paycheck Protection Program Liquidity Facility (PPPLF). Assets purchased under
the MMLF and Paycheck Protection Program (PPP) covered loans pledged under the PPPLF are
deducted from a banking organization’s measure of average total consolidated assets for purposes of the
leverage ratio calculation. However, such assets must be included in the banking organization’s measure
of total consolidated assets for purposes of determining a banking organization’s eligibility to elect the
CBLR framework. Specifically, no deduction for these assets would be made to Schedule RC, Item 12.
Banking organizations participating in the MMLF or the PPPLF should refer to the specific supplemental
instructions for those facilities.
General Instructions:
Temporary Change to the Leverage Ratio Requirement under the CBLR Framework (statutory interim
final rule):
Effective the second quarter of 2020, a banking organization may qualify for the CBLR framework if its
leverage ratio is equal to or greater than 8 percent (as reported in Schedule RC-R, Part I, item 31) and
meets the qualifying criteria as follows; it has less than $10 billion in total consolidated assets (Schedule
RC-R, Part I, item 32); is not part of an advanced approaches banking organization; has total trading
assets and trading liabilities of 5 percent or less of total consolidated assets (Schedule RC-R, Part I, item
33); and has total off-balance sheet exposures (excluding derivatives other than sold credit derivatives
and unconditionally cancelable commitments) of 25 percent or less of total consolidated assets (Schedule
RC-R, Part I, item 34). As noted in the Background section, this temporary change provision will cease to
be effective as of the earlier of the termination date of the national emergency concerning the coronavirus
disease declared by the President on March 13, 2020, under the National Emergencies Act, or December
31, 2020. The statutory interim final rule also includes a grace period. When this rule is in effect, the
minimum leverage ratio under the grace period is equal to or greater than 7 percent.
Transition Provisions (transition interim final rule):
Upon the expiration of the statutory interim final rule, the transition interim final rule will become effective.
Under the provisions of the transition interim final rule, a banking organization may qualify for the CBLR
framework if its leverage ratio is greater than 8 percent in the second through fourth quarters of calendar
year 2020 (if applicable), greater than 8.5 percent in calendar year 2021, and greater than 9 percent in
calendar year 2022, and thereafter. Also, the two-quarter grace period for a qualifying community

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banking organization will take into account the graduated increase in the community bank leverage ratio
requirement qualifying criterion. In order to maintain eligibility for the CBLR framework during the
transition period, a banking organization’s leverage ratio cannot fall more than one percentage point
below the community bank leverage ratio requirement qualifying criterion.
Table 1 – Schedule of Community Bank Leverage Ratio Requirement
(transition interim final rule)
Minimum Leverage
Ratio under the
Calendar Year
applicable grace
period (percent)
2020 (2Q-4Q)*
> 8.0
> 7.0
2021
> 8.5
> 7.5
2022
> 9.0
> 8.0
* Table 1 reflects the leverage ratio requirement under the transition interim final rule. Effective the
second quarter of 2020, when the statutory interim final rule is in effect, the community bank leverage
ratio qualifying criterion is equal to or greater than 8 percent. Similarly, the minimum leverage ratio under
the grace period when the statutory interim final rule is in effect is equal to or greater than 7 percent.
Community Bank
Leverage Ratio
(percent)

Ceasing to meet the leverage ratio requirement under the CBLR framework or failing to meet any
of the other CBLR qualifying criteria
A qualifying banking organization that temporarily fails to meet any of the qualifying criteria, including the
leverage ratio requirement, generally would still be deemed well-capitalized so long as the banking
organization maintains a leverage ratio that does not fall more than one percentage point below the
leverage ratio requirement during the two-quarter grace period. At the end of the grace period (see below
for an example), the banking organization must meet all of the qualifying criteria to remain in the CBLR
framework or otherwise must apply and report under the generally applicable rule. Similarly, a banking
organization with a leverage ratio that is not within one percentage point of the leverage ratio requirement
qualifying criterion under the CBLR framework is not eligible for the grace period and must comply with
the generally applicable rule, by completing all of Schedule RC-R, Parts I and II, as applicable excluding
RC-R, Part I, items 32 through 38.c.
Under the CBLR framework, the grace period will begin as of the end of the calendar quarter in which the
electing banking organization ceases to satisfy any of the qualifying criteria and has a maximum period of
two consecutive calendar quarters. For example, if the electing banking organization had met all of the
qualifying criteria as of March 31, 2020 but no longer meets one of the qualifying criteria as of May 15,
2020 and still does not meet all of the criteria as of the end of that quarter, the grace period for such a
banking organization will begin as of the end of the quarter ending June 30, 2020. The banking
organization may continue to use the CBLR framework as of September 30, 2020, but will need to comply
fully with the generally applicable rule (including the associated reporting requirements) as of December
31, 2020, unless the banking organization once again meets all of the qualifying criteria of the CBLR
framework, including the leverage ratio requirement qualifying criterion, before that time.
If an electing banking organization is in the grace period when the required community bank leverage
ratio increases, the banking organization would be subject, as of that change, to both the higher
community bank leverage ratio requirement and higher grace period leverage ratio requirement. For
example, if the electing banking organization that had met all of the qualifying criteria as of September 30,
2020, has a 7.2 percent community bank leverage ratio (but meets all of the other qualifying criteria) as of
the end of December 31, 2020, the grace period for such a banking organization will begin as of the end
of the fourth quarter. The banking organization may continue to use the community bank leverage ratio
framework as of March 31, 2021, if the banking organization has a leverage ratio of greater than 7.5
percent, and will need to comply fully with the generally applicable rule (including the associated reporting
requirements) as of June 30, 2021, unless the banking organization has a leverage ratio of greater than
8.5 percent (and meets all of the other qualifying criteria) by that date. In this example, if the banking

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organization has a leverage ratio equal to or less than 7.5 percent as of March 31, 2021, it would not be
eligible to use the community bank leverage ratio framework and would be subject immediately to the
requirements of the generally applicable rule.
II. Notice of Proposed Rulemaking to mitigate the deposit insurance assessment effects of
participation in the Paycheck Protection Program (PPP), the PPP Liquidity Facility (PPPLF), and
the Money Market Mutual Fund Liquidity Facility (MMLF); PPPLF Interim Final Rule, and CARES
Act Section 1102 (Call Report, FFIEC 101, FFIEC 002)
On May 12, 2020, the FDIC approved a notice of proposed rulemaking to mitigate the deposit insurance
assessment effects of participation in the PPP, the PPPLF, and the MMLF. The proposed changes would
(1) remove the effect of participation in the PPP and PPPLF on various risk measures used to calculate
an insured depository institution’s (IDI’s) assessment rate; (2) remove the effect of participation in the
PPPLF and MMLF programs on certain adjustments to an IDI’s assessment rate; (3) provide an offset to
an IDI’s assessment for the increase to its assessment base attributable to participation in the MMLF and
PPPLF; and (4) remove the effect of participation in the PPPLF and MMLF programs when classifying
IDIs as small, large, or highly complex for assessment purposes. The FDIC has proposed an effective
date by June 30, 2020, and an application date of April 1, 2020, in order to provide assessment relief
starting with the second quarter of 2020.
Under the proposal, the FDIC, in calculating an IDI’s deposit insurance assessment rate, would exclude
PPP loans held by an IDI (including loans pledged to the PPPLF) from its loan portfolio. Also, under the
proposal, in calculating an IDI’s deposit insurance assessment rate, the FDIC would exclude PPP loans
pledged to the PPPLF from total assets and would exclude borrowings from the Federal Reserve Banks
under the PPPLF from total liabilities when calculating an IDI’s deposit insurance assessment rate.
Because certain adjustments to an IDI’s deposit insurance assessment rate are calculated using average
total assets as reported in Schedule RC-K, item 9 “Total assets” (with certain exceptions), the FDIC would
also exclude the quarterly average amount of PPP loans pledged to the PPPLF and the quarterly average
amount of assets purchased under the MMLF from the calculation of those adjustments.
Further, because participation in the PPPLF and MMLF is expected to increase an IDI’s assessment
base, the FDIC would provide an offset to an IDI’s total assessment amount attributable to the inclusion of
(1) the quarterly average amount of PPP loans pledged to the PPPLF and (2) the quarterly average
amount of assets purchased under the MMLF in its assessment base. For purposes of calculating riskbased deposit insurance assessments, PPP loans would be considered eligible for exclusion from the
loan portfolio as of the date that the PPP loan was originated or purchased [provided the PPP loan
remains outstanding as of the quarter end reporting date]. In addition, in calculating deposit-insurance
assessments, (1) PPP loans pledged to the PPPLF would be considered eligible to be excluded from total
assets as of the date pledged to the PPPLF and (2) assets purchased under the MMLF would be
[considered] eligible to be excluded from total assets as of the date that the IDI purchased the asset from
a money market mutual fund (MMF).
Accordingly, a PPP loan that has not been pledged as collateral in connection with an extension of credit
under the PPPLF and an asset purchased from an MMF outside the auspices of the MMLF program
would continue to be included in the calculation of the IDI’s total assets. Therefore, the FDIC would
continue to include the resulting loans and assets in the calculation of an IDI’s deposit insurance
assessment amount.
[No new extensions of credit will be made under the PPPLF after September 30, 2020, unless extended
by the Board of Governors and the Department of the Treasury. The MMLF is scheduled to terminate on
September 30, 2020, unless extended by the Board of Governors.]

Reporting Needs for Deposit Insurance Assessments
General Guidance
Consistent with U.S. generally accepted accounting principles (U.S. GAAP), the agencies would expect

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IDIs to report PPP loans on their balance sheets. Starting with the June 30, 2020, report date, IDIs would
include the outstanding balance of PPP loans (inclusive of PPP loans pledged to the PPPLF) in
Schedules RC, RC-C, RC-D, and RC-R, as appropriate. PPP loans not held for trading that are pledged
to the PPPLF would be reported as pledged loans in Schedule RC-C, Memorandum item 14, “Pledged
loans and leases.” Any PPP loans held for trading that are pledged to the PPPLF would be included in
Schedule RC-D, Memorandum item 4.b, “Pledged loans,” on the FFIEC 031 by institutions required to
complete this schedule.
Borrowings from the Federal Reserve Banks under both the PPPLF and the MMLF would be included in
(1) Schedule RC, item 16, “Other borrowed money,” (2) the relevant sub–item(s) of Schedule RC-M, item
5.b, “Other borrowings,” and (3) Schedule RC-M, item 10.b, “Amount of ‘Other borrowings’ that are
secured.”
Beginning with the March 31, 2020, report date, IDIs would include the outstanding balance of assets
purchased from money market mutual funds under the MMLF in Schedules RC, RC-A, RC-B, RC-D, and
RC-R, as appropriate.
New items for Call Report
Starting with the June 30, 2020, report date, IDIs are required to separately report in Schedule RC-M,
Memorandum items 17.a, 17.b, 17.c, 17.d.(1), 17.d.(2), and 17.e, the quarter-end number of PPP loans
outstanding, the quarter-end outstanding balance of PPP loans, the quarter-end outstanding balance of
loans pledged to the PPPLF, the quarter-end outstanding balance of borrowings from Federal Reserve
Banks under the PPPLF with a remaining maturity of one year or less, the quarter-end outstanding
balance of borrowings from Federal Reserve Banks under the PPPLF with a remaining maturity of more
than one year, and the quarterly average amount of PPP loans pledged to the PPPLF and excluded from
“Total assets for the leverage ratio” reported in Schedule RC-R, Part I, item 30, respectively. IDIs are also
required to separately report in Schedule RC-M, Memorandum items 18.a and 18.b, the quarter-end total
outstanding balance of assets purchased under the MMLF and the quarterly average amount of assets
purchased under the MMLF and excluded from “Total assets for the leverage ratio” reported in Schedule
RC-R, Part I, item 30, respectively.
New items for FFIEC 002
Starting with the June 30, 2020 reporting period, FDIC-insured branches are required to separately report
in Schedule O, memorandum item 6, the quarterly average amount of PPP loans pledged to the PPPLF.
FDIC-insured branches are also required to separately report in Schedule O, memorandum item 7, the
quarterly average amount of assets purchased from MMFs under the MMLF
Interim Final Rule for Paycheck Protection Program Liquidity Facility (PPPLF) and Paycheck Protection
Program (PPP) Loans
To enhance the liquidity to small business lenders and improve the functioning of the broader credit
markets, the Federal Reserve Board authorized each of the Federal Reserve Banks to participate in the
Paycheck Protection Program Liquidity Facility (PPPLF). On April 13, 2020, the agencies published an
interim final rule, which permits banking organizations to exclude from regulatory capital requirements
Paycheck Protection Program (PPP)1 covered loans pledged under the PPPLF. The interim final rule also
clarifies that PPP covered loans as defined in section 7(a)(36) of the Small Business Act (15 U.S.C.
636(a)(36)) receive a zero percent risk weight.
The interim final rule modifies the agencies’ capital rule and allows PPPLF-eligible banking organizations
to neutralize the regulatory effects of PPP covered loans on their risk-based capital ratios, as well as PPP
1

The Paycheck Protection Program was established by Section 1102 of the 2020 Coronavirus Aid, Relief,
and Economic Security Act.

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covered loans pledged under the PPPLF on their leverage capital ratios. When calculating leverage
capital ratios, a banking organization may exclude from average total consolidated assets and, as
applicable, total leverage exposure a PPP covered loan as of the date that it has been pledged under the
PPPL Facility. Accordingly, a PPP covered loan that has not been pledged as collateral in connection with
an extension of credit under the PPPLF would be included in the calculation of the firm’s average total
consolidated assets and, as applicable, total leverage exposure. This treatment extends to the community
bank leverage ratio. No new extensions of credit will be made under the Facility after September 30,
2020, unless the Federal Reserve Board and U.S. Department of Treasury jointly determine to extend the
Facility.
Consistent with U.S. generally accepted accounting principles (U.S. GAAP), the agencies would expect
banking organizations to report PPP covered loans on their balance sheets. Starting with the June 30,
2020, reporting date, banking organizations would include the amount of PPP covered loan exposures in
Schedules RC, RC-C, RC-D, and RC-R, as appropriate. PPP covered loans not held for trading that are
pledged to the PPPLF would be reported as pledged loans in Schedule RC-C, Memorandum item 14,
“Pledged loans and leases.” Any PPP covered loans held for trading that are pledged to the PPPLF
would be included in Schedule RC-D, Memorandum item 4.b, “Pledged loans,” on the FFIEC 031 by
institutions required to complete this schedule.
Borrowings from the Federal Reserve Banks would be included in Schedule RC, item 16, “Other
borrowed money,” in the relevant sub-item under Schedule RC-M, item 5.b, “Other borrowings” and
Schedule RC-M, item 10.b, “Amount of ‘Other borrowings’ that are secured.”
For regulatory capital reporting, PPP covered loan exposures, regardless of whether they are pledged
under the PPPL Facility, should be reported in Schedule RC-R, Part II, 4.d., “Loans and leases held for
sale: All other exposures” or Schedule RC-R, Part II, 5.d., “Loans and leases held for investment: All
other exposures” as appropriate, in both Column A (Totals) and Column C (0% risk-weight category).2
PPP covered loan exposures that are past due 90 days or more or on nonaccrual should be reported in
Schedule RC-R, Part II, 4.c, “Loans and leases held for sale: Exposures past due 90 days or more or on
nonaccrual” or Schedule RC-R, Part II, 5.c., “Loans and leases held for investment: Exposures past due
90 days or more or on nonaccrual” as appropriate, in both Column A (Totals) and Column C (0% riskweight category).3 The quarterly average of PPP covered loans pledged under the PPPLF would be
reported in Schedule RC-R, part I, item 29, “LESS: Other deductions from (additions to) assets for
leverage ratio purposes,” and thus excluded from Schedule RC-R, item 30, “Total assets for the leverage
ratio.”
Advanced approaches banking organizations should not include PPP covered loans in “Total riskweighted assets (RWAs)” reported in the FFIEC 101, Schedule A, item 60 or Schedule, RC-R, Part I, item
48.b. For banking organizations subject to the supplementary leverage ratio requirement, PPP covered
loans pledged under the PPPLF would receive similar treatment as under the leverage ratio and should
be reported in the FFIEC 101, Schedule A, SLR Tables. Specifically, PPP covered loans pledged under
the PPPLF should be reported in SLR Table 1, item 1.7.c, “Adjustments for deductions of qualifying
central bank deposits for custodial banking organizations” and the mean of the amount of assets
calculated as of each day of the reporting quarter should be reported in SLR Table 2, item 2.2.b,
“Deductions of qualifying central bank deposits from total on-balance sheet exposures for custodial
banking organizations,” even if a banking organization is not a custodial banking organization. Banking
organizations would report their adjusted “Total leverage exposure” and “Supplementary leverage ratio” in
Schedule RC-R, Part I, item 55.a and 55.b.
Banking organizations are required to separately report in Schedule RC-M, memorandum item 17, the
number of outstanding PPP covered loans, quarter end outstanding dollar amount of PPP covered loans,
2

Reporting in Schedule RC-R, Part II, only applies to non CBLR banking institutions.
The agencies issued an interagency statement to provide information to financial institutions that are
working with borrowers affected by the coronavirus:
https://www.fdic.gov/news/news/press/2020/pr20049a.pdf
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the quarter end outstanding dollar amount of PPP covered loans that are pledged under the PPPL
Facility, and the quarterly average dollar amount of PPP covered loans pledged as collateral under the
PPPLF that were excluded from Schedule RC-R, item 30.
III. Interim Final Rules for Temporary Exclusion of U.S. Treasury Securities and Deposits at
Federal Reserve Banks from the Supplementary Leverage Ratio (Call Report, FFIEC 101)
To ease strains in the Treasury market and depository institutions’ ability to provide credit to households
and businesses, on April 13, 2020, the Board published an interim final rule to temporarily exclude U.S.
Treasury Securities (Treasuries) and deposits in their accounts at Federal Reserve Banks (deposits at
Federal Reserve Banks) from total leverage exposure for bank holding companies, savings and loan
holding companies, and intermediate holding companies subject to the supplementary leverage ratio
through March 31, 2021.
On May 15, 2020, the agencies issued an interim final rule to provide depository institutions subject to the
supplementary leverage ratio the ability to temporarily exclude Treasuries and deposits at Federal
Reserve Banks from total leverage exposure. A depository institution that opts into this treatment (electing
depository institution) is required to obtain prior approval of distributions from its primary Federal banking
regulator. The prior approval requirement applies to distributions to be paid beginning in the third quarter
of 2020. The interim final rule will terminate after March 31, 2021.
Depository institutions subject to the supplementary leverage ratio report Treasuries and deposits at
Federal Reserve Banks in Schedule RC-B, item 1, “U.S. Treasury Securities” and Schedule RC-A, item 4,
“Balances due from Federal Reserve Banks,” respectively.
Advanced approaches and Category III electing depository institutions would exclude amounts reported in
Schedule RC-B, item I, and Schedule RC-A, item 4, from Schedule RC- R, Part 1, item 55.a, “Total
leverage exposure.” Custodial banking organizations will also be able to exclude from total leverage
exposure deposits with qualifying foreign central banks as reported as a part of Schedule RC-A, item 3,
“Balances due from banks in foreign countries and foreign central banks,” subject to the limits in the
Section 402 rule4, in addition to the deductions under this interim final rule. For purposes of reporting the
supplementary leverage ratio as of June 30, 2020, depository institutions may reflect the exclusion of
Treasuries and deposits at Federal Reserve Banks from total leverage exposure, as if this interim final
rule had been in effect for the entire second quarter of 2020. The temporary exclusions from total
leverage exposure are through the March 31, 2021, report date.
For top-tier advanced approaches and Category III bank holding companies, savings and loan holding
companies, and intermediate holding companies (and top-tier advanced approaches and Category III
electing depository), Treasuries and deposits at Federal Reserve Banks should be reported in the FFIEC
101, Schedule A, SLR Tables. Custodial banking organizations will also be able to exclude from the SLR
Tables deposits with qualifying foreign central banks subject to the limits in the Section 402 rule 5, in
addition to the deductions under this interim final rule. Specifically, Treasuries and deposits at Federal
Reserve Banks should be reported in SLR Table 1, item 1.7.c, “Adjustments for deductions of qualifying
central bank deposits for custodial banking organizations” and SLR Table 2, item 2.2.b, “Deductions of
qualifying central bank deposits from total on-balance sheet exposures for custodial banking
organizations,” even if a banking organization is not a custodial banking organization. For purposes of
reporting the supplementary leverage ratio as of June 30, 2020, banking organizations may reflect the
exclusion of Treasuries and deposits at Federal Reserve Banks from total leverage exposure, as if these
interim final rules had been in effect for the entire second quarter of 2020. The temporary exclusions from
total leverage exposure are through the March 31, 2021, report date.
4

The agencies recently issued a final rule, effective April 1, 2020, which implements section 402 of the Economic
Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA) by amending the capital rule to allow a
banking organization that qualifies as a custodial banking organization to exclude from total leverage exposure
deposits at qualifying central banks, subject to limits (402 rule). 85 FR 4569 (January 27, 2020).
5
See footnote 1.

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IV. Regulation D (Call Report, FFIEC 002) – See separate PDF files with redline edits
V. Interim Final Rule for Loans to Executive Officers, Directors, and Principal Shareholders of
Member Banks (Call Report)
On April 22, 2020, the Board issued an interim final rule that excepts certain loans that are guaranteed
under the Small Business Administration's Paycheck Protection Program (PPP) from the requirements of
section 22(h) of the Federal Reserve Act and the corresponding provisions of the Board's Regulation O.
The PPP loans will not be subject to section 22(h) or the corresponding provisions of Regulation O if they
are not prohibited by the SBA lending restrictions as defined in the interim rule. PPP applies to loans
made between February 15 and June 30, 2020. Similarly, the exception in the interim final rule only
applies to loans made during the same time period. PPP loans excepted from the requirements of
section 22(h) of the Federal Reserve Act and the corresponding provisions of the Board's Regulation O
should not be reported in Schedule RC-M Memoranda items 1.a and 1.b.
VI. Sec. 4013, Temporary Relief from Troubled Debt Restructurings (TDR) (Call Report)
As provided for under the CARES Act, a financial institution may account for an eligible loan modification
either under Sec. 4013 or in accordance with ASC Subtopic 310-40.2 If a loan modification is not eligible
under Sec. 4013, or if the institution elects not to account for the loan modification under Sec. 4013, the
financial institution should evaluate whether the modified loan is a TDR.
To be an eligible loan under Sec. 4013 (section 4013 loan), a loan modification must be (1) related to
COVID-19; (2) executed on a loan that was not more than 30 days past due as of December 31, 2019;
and (3) executed between March 1, 2020, and the earlier of (A) 60 days after the date of termination of
the national emergency concerning the COVID-19 outbreak declared by the President on March 13,
2020, under the National Emergencies Act (National Emergency) or (B) December 31, 2020.
Financial institutions accounting for eligible loans under Sec. 4013 are not required to apply ASC
Subtopic 310-40 to the section 4013 loans for the term of the loan modification. Financial institutions do
not have to report section 4013 loans as TDRs in regulatory reports. However, consistent with the statute,
the agencies are collecting information about the volume of loans modified under Section 4013. Financial
institutions should report the total number of loans outstanding that have been modified under Section
4013 and the outstanding balance of these loans in Schedule RC-C, Part I, Loans and Lease Financing
Receivables, Memorandum items 17.a and 17.b, respectively. These two items are being collected on a
confidential basis at the institution level.




Institutions should continue to follow reporting instructions and U.S. GAAP for section 4013 loans,
including:
Appropriately reporting past due and nonaccrual status;
Maintaining an appropriate allowance for loan and lease losses in accordance with ASC Subtopic
450-20 or ASC Subtopic 310-10, or an appropriate allowance for credit losses in accordance with
ASC Subtopic 326-20, as applicable.

Institutions are not required to report section 4013 loans in the following Call Report items:
 Schedule RC-C, Part I, Memorandum item 1, “Loans restructured in troubled debt restructurings that
are in compliance with their modified terms.”
 Schedule RC-N, Memorandum item 1, “Loans restructured in troubled debt restructurings included in
 Schedule RC-N, items 1 through 7, above.”
 Schedule RC-O, Memorandum item 16, “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” (which is applicable only to “large institutions” and “highly complex institutions” for
deposit insurance assessment purposes).

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One-to-four family residential mortgages will not be considered restructured or modified for the purposes
of the agencies’ risk-based capital rules solely due to a short-term modification made on a good faith
basis in response to COVID-19, provided that the loans are prudently underwritten and not 90 days or
more past due or carried in nonaccrual status. Loans meeting these requirements that received a 50
percent risk weight prior to such a modification may continue receiving that risk weight.
VII. Money Market Mutual Fund Liquidity Facility (MMLF) (Call Report)– See consolidated instructions
under Section II, above.

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