FFIEC031_FFIEC041_FFIEC051_suppinst_202103

FFIEC
Federal Financial Institutions Examination Council
Arlington, VA 22226

CALL REPORT DATE: March 31, 2021
FIRST 2021 CALL, NUMBER 295

SUPPLEMENTAL INSTRUCTIONS
March 2021 Call Report Materials
New Call Report data items take effect this quarter in the following FFIEC 031, FFIEC 041, or FFIEC 051 Call
Report schedules:
• Schedule RI-B, Part II, Changes in Allowances for Credit Losses, to provide information about an
institution’s allowances for credit losses once it has adopted the current expected credit losses
methodology (CECL);
• Schedule RC-C, Part I, Loans and Lease Financing Receivables, regarding home equity lines of
credit that have converted from revolving to non-revolving status; and
• Schedule RC-M, Memoranda, reporting of international remittance transfers offered to customers.
A new topic has been added to the Supplemental Instructions for March 2021 on the “U.S. Department of the
Treasury Department Emergency Capital Investment Program (ECIP).”
The following topics have been removed from the Supplemental Instructions this quarter since information
pertaining to them have been included in the Call Report instruction book updates for March 2021:
• Banking Agencies’ Recent COVID-19-Related Activities Affecting the Call Report
• Nonaccrual Treatment for Purchased Credit-Deteriorated (PCD) Assets
• Presentation of Provisions for Credit Losses on Off-Balance Sheet Credit Exposures
• Home Equity Lines of Credit That Convert From Revolving to Non-Revolving Status
• Appendix I: Section 4013, Temporary Relief from Troubled Debt Restructurings (TDRs).
In addition, the remaining topics that were included in Appendix I and II in the December 31, 2020,
Supplemental Instructions have been moved into the body of the March 31, 2021, Supplemental Instructions in
the following sections: “Section 2303, Modifications for Net Operating Losses,” “Section 4014, Optional
Temporary Relief from Current Expected Credit Losses,” included under the “Credit Losses on Financial
Instruments” section, and “Temporary Adjustment to the Measurement Date for Certain Total Asset
Thresholds in the Call Reports.”
Furthermore, there are additional changes to the Call Report instruction book for Schedule RC-E, Deposit
Liabilities and the Glossary entry for “Deposits,” related to amendments to Regulation D 1 to clarify the
differences in the definition of “savings account” between Regulation D and the Call Report.
In general, institutions with domestic offices only and total assets less than $5 billion as of June 30, 2020, are
eligible to file the FFIEC 051 Call Report as of March 31, 2021, but such institutions have the option to file the
FFIEC 041 Call Report instead as of that date. 2 Institutions are expected to file the same report form, either
the FFIEC 051 or the FFIEC 041, for each quarterly report date during 2021.
Separate updates to the instruction book for the FFIEC 051 Call Report and the instruction book for the
FFIEC 031 and FFIEC 041 Call Reports for March 2021 soon will be available for printing and downloading
from the FFIEC’s website (https://www.ffiec.gov/ffiec_report_forms.htm) and the FDIC’s website
(https://www.fdic.gov/callreports). Sample FFIEC 051, FFIEC 041, and FFIEC 031 Call Report forms,
including the cover (signature) page, for March 2021 also can be printed and downloaded from these
websites. In addition, institutions that use Call Report software generally can print paper copies of blank forms

1

85 FR 23445 (April 28, 2020).
In response to the financial market disruptions from COVID-19, the banking agencies have adjusted the measurement
date for certain total asset thresholds that trigger additional reporting requirements in the Call Reports, including the $5
billion asset threshold eligibility criteria for filing the FFIEC 051, for report dates in 2021 only. See section “Temporary
Adjustment to the Measurement Date for Certain Total Asset Thresholds in the Call Reports” for details.

2

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from their software. Please ensure that the individual responsible for preparing the Call Report at your
institution has been notified about the electronic availability of the March 2021 report forms, instruction book
updates, and these Supplemental Instructions. The locations of changes to the text of the previous quarter’s
Supplemental Instructions (except references to the quarter-end report date) are identified by a vertical line
in the right margin.
Submission of Completed Reports
Each institution’s Call Report data must be submitted to the FFIEC's Central Data Repository (CDR), an
Internet-based system for data collection (https://cdr.ffiec.gov/cdr/), using one of the two methods described
in the banking agencies' Financial Institution Letter (FIL) for the March 31, 2021, report date. The CDR Help
Desk is available from 9:00 a.m. until 8:00 p.m., Eastern Time, Monday through Friday to provide assistance
with user accounts, passwords, and other CDR system-related issues. The CDR Help Desk can be reached
by telephone at (888) CDR-3111, by fax at (703) 774-3946, or by e-mail at [email protected].
Institutions are required to maintain in their files a signed and attested hard-copy record of the Call Report data
file submitted to the CDR. (See the next section for information on the Call Report signature requirement.)
The appearance of this hard-copy record of the submitted data file need not match exactly the appearance of
the sample report forms on the FFIEC’s website, but the hard-copy record should show at least the caption of
each Call Report item and the reported amount. A copy of the cover page printed from Call Report software or
from the FFIEC’s website should be used to fulfill the signature and attestation requirement. The signed cover
page should be attached to the hard-copy record of the Call Report data file that must be placed in the
institution's files.
Currently, Call Report preparation software products marketed by (in alphabetical order) Axiom Software
Laboratories, Inc.; DBI Financial Systems, Inc.; Fed Reporter, Inc.; FIS Compliance Solutions; FiServ, Inc.;
KPMG LLP; SHAZAM Core Services; Vermeg; and Wolters Kluwer Financial Services meet the technical
specifications for producing Call Report data files that are able to be processed by the CDR. Contact
information for these vendors is provided on the final page of these Supplemental Instructions.
Call Report Signature Requirement and COVID-19
Generally, each Call Report submission must be signed by the Chief Financial Officer (or equivalent) and three
directors (two for state nonmember banks). 3 While the Call Report data submission occurs electronically, the
current Call Report instructions require that the signed cover page must be attached to a printout or copy of
the Call Report forms or data reported to the agencies. The agencies note that while the instructions refer to a
single page, the required signatures may be obtained on separate cover pages from each required signer,
rather than by obtaining all signatures on a single cover page.
Business disruptions related to the Coronavirus Disease 2019 (COVID-19), including distancing requirements
and remote work, may make it operationally challenging for an institution to obtain original ink signatures from
all required signers in order to submit the Call Report on a timely basis. Therefore, for the duration of the
COVID-19 disruptions, including for the March 31, 2021, Call Report, the agencies will permit an institution to
use electronic signatures in lieu of ink signatures to fulfill the Call Report attestation requirement. The
institution should follow appropriate governance procedures for collecting and retaining electronic signatures:
• The signature is executed by the required signer with the intent to sign;
• The signature is digitally attached to or associated with a copy of the Call Report;
• The signature or process identifies and authenticates the required signer; and
• The institution maintains the electronically signed Call Report and has it available for subsequent examiner
review.
One acceptable method during the COVID-19 disruption could include obtaining written attestation via e-mail
from the required signer to the person submitting the Call Report data, provided the e-mail included an
attached electronic version of the Call Report data and indicating the attestation is based on the attached
information. That e-mail should be retained in the institution’s records to support that the Call Report was
appropriately attested to by the required signer. Institutions should discuss any concerns regarding the
attestation with their primary federal regulator.

3

See, e.g., 12 U.S.C. §§ 161(a) and 1817(a)(3).

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U.S. Department of the Treasury Department Emergency Capital Investment Program
On March 22, 2021, the agencies published in the Federal Register an interim final rule (IFR) 4 that supports
the U. S. Department of the Treasury (Treasury Department) implementation of the Emergency Capital
Investment Program (ECIP) established by Congress to make capital investments in minority depository
institutions and community development financial institutions. The program will support the efforts of these
financial institutions to provide loans, grants, and forbearance to small businesses, minority-owned
businesses, and consumers, especially in low-income and underserved communities, which may be
disproportionately affected by COVID-19. Under the program, the Treasury Department will purchase
preferred stock or subordinated debt from qualifying minority depository institutions and community
development financial institutions, with the corresponding dividend or interest rate based on the institution
meeting lending targets. To facilitate implementation of ECIP, the agencies are revising their capital rules to
provide that the Treasury Department’s investments under the program qualify as regulatory capital of insured
depository institutions and holding companies.
As described in the terms published by the Treasury Department, Senior Preferred Stock issued under ECIP
will be noncumulative, perpetual preferred stock that is senior to the issuer’s common stock and pari passu
with (or, in some cases, senior to) the issuer’s most senior class of existing preferred stock. Subordinated Debt
issued under ECIP will be unsecured subordinated debt. The Subordinated Debt will rank junior to all other
debt of the issuer except that it will rank senior to mutual capital certificates or similar instruments issued by a
mutual banking organization and to any equity instruments issued by an S corporation.
The noncumulative perpetual preferred stock issued under the Treasury Department’s ECIP should be
reported on the Call Report balance sheet (Schedule RC) in item 23, “Perpetual preferred stock and related
surplus.” For regulatory capital purposes, the noncumulative perpetual preferred stock issued under the
Treasury Department’s ECIP qualifies as additional Tier 1 capital, 5 reported in Schedule RC-R, Part I, line item
20 and should be included in the amount reported for “Tier 1 capital” in Schedule RC-R, Part I, line item 26.
The full amount of all subordinated debt instruments issued under the Treasury Department’s ECIP should be
reported in Schedule RC, item 19, “Subordinated notes and debentures.” For regulatory capital purposes, an
institution would report these subordinated debt instruments in Schedule RC-R, item 39, “Tier 2 capital
instruments plus related surplus,” as applicable.
Section 2303, Modifications for Net Operating Losses
Section 2303 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) 6 makes two changes to
sections of the Internal Revenue Code that were impacted by the Tax Cuts and Jobs Act, which was enacted
on December 22, 2017, related to (1) net operating loss (NOL) carryforwards and (2) NOL carrybacks. As
stated in the Glossary entry for “Income Taxes” in the Call Report instructions, when an institution’s deductions
exceed its income for income tax purposes, it has sustained an NOL. To the extent permitted under a taxing
authority’s laws and regulations, an NOL that occurs in a year following periods when an institution had
taxable income may be carried back to recover income taxes previously paid. Generally, an NOL that occurs
when loss carrybacks are not available becomes an NOL carryforward.
The CARES Act (1) repeals the 80 percent taxable income limitation for NOL carryback and carryforward
deductions in tax years beginning before 2021, and (2) for NOL carrybacks under federal law, allows an
institution to apply up to 100 percent of a carryback for up to five years for any NOLs incurred in taxable years
2018, 2019, and 2020. Although the Glossary entry for “Income Taxes” currently refers to federal law prior to
the CARES Act (e.g., indicating that, “for years beginning on or after January 1, 2018, a bank may no longer
carry back operating losses to recover taxes paid in prior tax years”), institutions should use the newly enacted
provisions of federal law within the CARES Act when determining the extent to which NOLs may be carried
forward or back.

4 86 FR 15076 (March 22, 2021).
5
6

See 12 CFR 3.20 (OCC); 12 CFR 217.20 (Board); 12 CFR 324.20 (FDIC).
Pub. L. 116-136.

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Additionally, deferred tax assets (DTAs) are recognized for NOL carryforwards as well as deductible temporary
differences, subject to estimated realizability. As a result, an institution can recognize the tax benefit of an
NOL for accounting and reporting purposes to the extent the institution determines that a valuation allowance
is not considered necessary (i.e., realization of the tax benefit is more likely than not). U.S. generally accepted
accounting principles (GAAP) require the effect of changes in tax laws or rates to be recognized in the period
in which the legislation is enacted. Thus, in accordance with Accounting Standards Codification (ASC) Topic
740, Income Taxes, the effects of the CARES Act should have been recorded in an institution’s Call Report for
March 31, 2020, because the CARES Act was enacted during that reporting period. Changes in DTAs and
deferred tax liabilities (DTLs) resulting from the change in tax law for NOL carrybacks and carryforwards and
other applicable provisions of the CARES Act will be reflected in an institution’s income tax expense in the
period of enactment, i.e., the March 31, 2020, Call Report.
As mentioned above, the CARES Act restores NOL carryback potential for federal income tax purposes to
NOLs incurred in taxable years 2018, 2019, and 2020. Consequently, institutions should note that DTAs
arising from temporary differences that could be realized through NOL carrybacks are not subject to deduction
for regulatory capital purposes. Instead, except for institutions that have a community bank leverage ratio
framework election in effect, such DTAs are assigned a risk weight of 100 percent. Only those DTAs arising
from temporary differences that could not be realized through NOL carrybacks, net of related valuation
allowances and net of DTLs, that exceed the thresholds described in Call Report Schedule RC-R, Part I, items
15, 15.a, and 15.b, as applicable, and item 16, if applicable, are deducted from common equity tier 1 capital.
Section 4014, Optional Temporary Relief from Current Expected Credit Losses
Section 4014 of the CARES Act, as amended by the Consolidated Appropriations Act, 2021, 7 allows an
institution to delay the adoption of Accounting Standards Update (ASU) 2016-13, Financial Instruments –
Credit Losses (Topic 326), Measurement of Credit Losses on Financial Instruments, until the earlier of (1)
January 1, 2022, or (2) the first day of the institution’s fiscal year that begins after the date of the termination of
the National Emergency.
Temporary Adjustment to the Measurement Date for Certain Total Asset Thresholds in the Call Reports
During 2020, relief measures enacted by Congress through the CARES Act in response to the strains on the
U.S. economy and disruptions to the financial markets as a result of coronavirus disease 2019 (COVID-19)
have led to unprecedented growth at many institutions, including loans made through the Paycheck Protection
Program (PPP). This rapid growth caused the assets of some institutions to rise above certain asset-based
thresholds. Much of this growth, especially growth related to PPP lending, is likely to be temporary, and the
increase in assets currently held by an institution may not reflect a change in the institution’s longer-term risk
profile. To provide reporting relief due to institutions’ asset growth in 2020 related to participation in various
COVID-19-related stimulus activities, the agencies have adjusted the measurement date for certain total asset
thresholds that trigger additional reporting requirements in the Call Reports for report dates in 2021 only, as
discussed below.
First, on December 2, 2020, the agencies published in the Federal Register an IFR that, among other
provisions, revise their rules on FFIEC 051 Call Report eligibility 8 to permit an institution to use the lesser of
the total consolidated assets reported in its Call Report as of December 31, 2019, or June 30, 2020, when
evaluating eligibility to use the FFIEC 051 for report dates in calendar year 2021 only. 9 The institution still
must meet the other criteria for eligibility to file the FFIEC 051 in the Call Report instructions. In addition, the
banking agencies also reserve the right to require an institution otherwise eligible to use the FFIEC 051 to file
the FFIEC 041 Call Report instead based on supervisory needs.
For example, if an institution has $5.3 billion in total consolidated assets as of June 30, 2020, but had
$4.8 billion as of December 31, 2019, and meets the other criteria for eligibility for the FFIEC 051 in the
Call Report instructions, it could choose to file the FFIEC 051 for the March 31, 2021, report date. Unless a
change of status event occurs as described in the Call Report General Instructions or as directed by its
7

Pub. L. 116-260
See definition of covered depository institutions. 12 CFR 52.2 (OCC); 12 CFR 208.121 (Board); 12 CFR 304.12 (FDIC).
9 85 FR 77345 (December 2, 2020).
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primary regulatory agency, the institution would continue to file the FFIEC 051 Call Report for the remaining
three quarters of calendar year 2021.
Secondly, the agencies’ capital rules permit institutions that meet certain criteria to use the community bank
leverage ratio (CBLR) framework to measure their regulatory capital. 10 The agencies’ IFR also revises these
capital rules to allow institutions that temporarily exceed the $10 billion total asset threshold in those rules to
use the CBLR framework from December 31, 2020, to December 31, 2021, provided they meet the other
qualifying criteria for this framework. 11 An institution that elects to use the CBLR framework under this
temporary relief would report CBLR information in Call Report Schedule RC-R, Part I, as reflected in the
Call Report instruction book, except that the institution should:
•

Report the lesser of its total assets as of December 31, 2019, or as of the current quarter-end report date,
which must be less than $10 billion, in Schedule RC-R, Part I, item 32, “Total assets.”

•

Use its total assets as reported in Schedule RC, item 12, as of the current quarter-end report date
when reporting (1) the sum of trading assets and trading liabilities as a percentage of total assets, which
must be 5 percent or less, in Schedule RC-R, item 33, column B, and (2) total off-balance sheet exposures
as a percentage of total assets, which must be 25 percent or less, in Schedule RC-R, Part I, item 34.d,
column B.

In addition, on November 30, 2020, the agencies proposed to permit an institution to use the lesser of the total
consolidated assets reported in its Call Report as of December 31, 2019, or June 30, 2020, when determining
whether the institution has crossed a total asset threshold to report certain additional data items in its Call
Reports for report dates in calendar year 2021. 12 The Office of Management and Budget approved these
revisions on March 25, 2021. The Call Report forms’ thresholds footnotes for these affected items have been
updated as of the March 31, 2021, report date, to reflect this temporary change in measurement dates.
Certain items that apply to institutions with less than $300 million in total consolidated assets are also based
on whether an institution had agricultural loans (Schedule RC-C, Part I, item 3) exceeding 5 percent of total
loans and leases (Schedule RC-C, Part I, item 12) reported as of June 30 of the prior calendar year. For these
items, if an institution’s total consolidated assets are less than $300 million as of December 31, 2019, but are
$300 million or more as of June 30, 2020 (or vice versa), the institution would determine whether it exceeded
the 5 percent threshold as of the same date as of which its total consolidated assets are less than $300
million.
For example, if an institution’s total consolidated assets exceeded the $300 million total asset threshold as of
the June 30, 2020, report date, but not as of the December 31, 2019, report date, the institution would use
December 31, 2019, as its measurement date for determining whether it exceeded the 5 percent activity
threshold for agricultural loans.
However, if an institution’s total consolidated assets are less than $300 million as of both December 31, 2019,
and June 30, 2020, the institution has not crossed the $300 million total asset threshold as it would be
measured under the agencies’ reporting relief proposal. Accordingly, the institution would measure the 5
percent activity threshold as of June 30, 2020, consistent with the existing Call Report instructions.
See Appendix II of the December 31, 2020, Supplemental Instructions for a full listing of items that the
alternate measurement date may be used during 2021 only.
Reference Rate Reform
In March 2020, the FASB issued ASU No. 2020-04, “Reference Rate Reform (Topic 848): Facilitation of the
Effects of Reference Rate Reform on Financial Reporting.” The ASU states that “[r]eference rates such as the
London Interbank Offered Rate (LIBOR) are widely used in a broad range of financial instruments and other
agreements. Regulators and market participants in various jurisdictions have undertaken efforts, generally
10

See 12 CFR 3.12 (OCC); 12 CFR 217.12 (Board); 12 CFR 324.12 (FDIC).
See footnote 9.
12 85 FR 76658 (November 30, 2020).
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referred to as reference rate reform, to eliminate certain reference rates and introduce new reference rates
that are based on a larger and more liquid population of observable transactions. As a result of this initiative,
certain widely used reference rates such as LIBOR are expected to be discontinued.”
The ASU provides optional expedients for a limited period of time to ease the potential burden in accounting
for (or recognizing the effects of) reference rate reform on financial reporting. In particular, the expedients in
the ASU are available to be elected by all institutions, subject to meeting certain criteria, for contracts, hedging
relationships, and other transactions that reference LIBOR or another reference rate expected to be
discontinued because of reference rate reform.
With respect to contracts, the ASU applies to contract modifications that replace a reference rate affected by
reference rate reform (including rates referenced in fallback provisions) and contemporaneous modifications of
other contract terms related to the replacement of the reference rate (including contract modifications to add or
change fallback provisions). The ASU provides optional expedients for applying Accounting Standards
Codification (ASC) requirements in the following areas:
• ASC Topics 310, Receivables, and 470, Debt: Modifications of contracts within the scope of these topics
should be accounted for by prospectively adjusting the effective interest rate.
• ASC Topics 840, Leases, and 842, Leases: Modifications of contracts within the scope of these topics
should be accounted for as a continuation of the existing contracts with no reassessments of the lease
classification and the discount rate (for example, the incremental borrowing rate) or remeasurements of
lease payments that otherwise would be required under these topics for modifications not accounted for as
separate contracts.
• ASC Subtopic 815-15, Derivatives and Hedging—Embedded Derivatives: Modifications of contracts do
not require an entity to reassess its original conclusion about whether that contract contains an embedded
derivative that is clearly and closely related to the economic characteristics and risks of the host contract
under this subtopic.
For other topics in the ASC, the ASU states a general principle that permits an institution to consider contract
modifications due to reference rate reform to be an event that does not require contract remeasurement at the
modification date or reassessment of a previous accounting determination. When elected, an institution must
apply the optional expedients for contract modifications consistently for all eligible contracts or eligible
transactions within the relevant ASC topic that contains the guidance that otherwise would be required to be
applied.
In addition, the ASU provides exceptions to the guidance in Topic 815, Derivatives and Hedging, related to
changes to the critical terms of a hedging relationship due to reference rate reform. The ASU includes
examples of changes to these terms that should not result in the dedesignation of the hedging relationship if
certain criteria are met. The ASU also provides optional expedients for fair value hedging relationships, cash
flow hedging relationships, and net investment hedging relationships for which the component excluded from
the assessment of hedge effectiveness is affected by reference rate reform. If certain criteria are met, other
optional expedients apply to cash flow hedging relationships affected by reference rate reform and to fair value
hedging relationships for which the derivative designated as the hedging instrument is affected by reference
rate reform. The optional expedients for hedging relationships may be elected on an individual hedging
relationship basis.
Finally, the ASU permits institutions to make a one-time election to sell, transfer, or both sell and transfer
held-to-maturity debt securities that reference a rate affected by reference rate reform and were classified as
held-to-maturity before January 1, 2020.
The ASU is effective for all institutions as of March 12, 2020, through December 31, 2022. For additional
information, institutions should refer to ASU 2020-04, which is available at
https://www.fasb.org/jsp/FASB/Document_C/DocumentPage?cid=1176174318625&acceptedDisclaimer=true.
Goodwill Impairment Testing
In January 2017, the FASB issued ASU No. 2017-04, “Simplifying the Test for Goodwill Impairment,”
to address concerns over the cost and complexity of the two-step goodwill impairment test in ASC
Subtopic 350-20, Intangibles‒Goodwill and Other ‒ Goodwill, that applies to an entity that has not elected
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the private company alternative for goodwill (which is discussed in the Glossary entry for “Goodwill” in the
Call Report instructions). Thus, the ASU simplifies the subsequent measurement of goodwill by eliminating
the second step from the test, which involves the computation of the implied fair value of a reporting unit’s
goodwill. Instead, under the ASU, when an entity tests goodwill for impairment, which must take place at least
annually, the entity should compare the fair value of a reporting unit with its carrying amount. In general, the
entity should recognize an impairment charge for the amount, if any, by which the reporting unit’s carrying
amount exceeds its fair value. However, the loss recognized should not exceed the total amount of goodwill
allocated to that reporting unit. This one-step approach to assessing goodwill impairment applies to all
reporting units, including those with a zero or negative carrying amount. An entity retains the option to perform
the qualitative assessment for a reporting unit described in ASC Subtopic 350-20 to determine whether it is
necessary to perform the quantitative goodwill impairment test.
For an institution that is a public business entity and is also a U.S. Securities and Exchange Commission
(SEC) filer, as both terms are defined in U.S. GAAP, the ASU is effective for goodwill impairment tests in fiscal
years beginning after December 15, 2019. For a public business entity that is not an SEC filer, the ASU is
effective for goodwill impairment tests in fiscal years beginning after December 15, 2020. For all other
institutions, the ASU is effective for goodwill impairment tests in fiscal years beginning after December 15,
2021. Early adoption is permitted for goodwill impairment tests performed on testing dates after January 1,
2017. For Call Report purposes, an institution should apply the provisions of ASU 2017-04 to goodwill
impairment tests on a prospective basis in accordance with the applicable effective date of the ASU. An
institution that early adopts ASU 2017-04 for U.S. GAAP financial reporting purposes should early adopt the
ASU in the same period for Call Report purposes.
For additional information, institutions should refer to ASU 2017-04, which is available at
https://www.fasb.org/jsp/FASB/Document_C/DocumentPage?cid=1176168778106&acceptedDisclaimer=true.
Credit Losses on Financial Instruments
In June 2016, the FASB issued ASU No. 2016-13, “Measurement of Credit Losses on Financial Instruments,”
which introduces CECL for estimating allowances for credit losses. Under CECL, an allowance for credit
losses is a valuation account, measured as the difference between the financial assets’ amortized cost basis
and the net amount expected to be collected on the financial assets (i.e., lifetime credit losses). To estimate
expected credit losses under CECL, institutions will use a broader range of data than under existing U.S.
GAAP. These data include information about past events, current conditions, and reasonable and supportable
forecasts relevant to assessing the collectability of the cash flows of financial assets.
The ASU is applicable to all financial instruments measured at amortized cost (including loans held for
investment and held-to-maturity debt securities, as well as trade receivables, reinsurance recoverables, and
receivables that relate to repurchase agreements and securities lending agreements), a lessor’s net
investments in leases, and off-balance-sheet credit exposures not accounted for as insurance, including loan
commitments, standby letters of credit, and financial guarantees. The new standard does not apply to trading
assets, loans held for sale, financial assets for which the fair value option has been elected, or loans and
receivables between entities under common control.
The ASU also modifies the treatment of credit impairment on available-for-sale (AFS) debt securities. Under
the new standard, institutions will recognize a credit loss on an AFS debt security through an allowance for
credit losses, rather than the current practice required by U.S. GAAP of write-downs of individual securities for
other-than-temporary impairment.
On November 15, 2019, the FASB issued ASU No. 2019-10 to defer the effective dates of ASU 2016-13 for
certain institutions. Under this ASU, for institutions that are SEC filers, except those that are “smaller reporting
companies” as defined in the SEC’s rules, ASU 2016-13 continues to be effective for fiscal years beginning
after December 15, 2019, including interim periods within those fiscal years, i.e., January 1, 2020, for such
entities with calendar year fiscal years. For all other entities, including those SEC filers that are eligible to be
smaller reporting companies, ASU 2016-13 now will take effect for fiscal years beginning after December 15,
2022, including interim periods within those fiscal years, i.e., January 1, 2023, for such entities with calendar
year fiscal years. For all institutions, early application of the new credit losses standard is permitted for fiscal
years beginning after December 15, 2018, including interim periods within those fiscal years.
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Institutions must apply ASU 2016-13 for Call Report purposes in accordance with the effective dates set forth
in the ASU as amended in November 2019. An institution that early adopts ASU 2016-13 for U.S. GAAP
financial reporting purposes should also early adopt the ASU in the same period for Call Report purposes.
However, Section 4014 of the CARES Act, as amended by section 540 of the Consolidated Appropriations
Act, 2021, allows an institution to delay the adoption of ASU 2016-13 until the earlier of (1) January 1, 2022, or
(2) the first day of the institution’s fiscal year that begins after the date of the termination of the national
emergency concerning the coronavirus outbreak declared by the President on March 13, 2020, under the
National Emergencies Act.
For additional information, institutions should refer to the agencies’ Interagency Policy Statement on
Allowances for Credit Losses, which was published June 1, 2020. Since the issuance of ASU 2016-13, the
FASB has published the following amendments to the new credit losses accounting standard:
• ASU 2018-19, “Codification Improvements to Topic 326, Financial Instruments—Credit Losses,” available
at https://www.fasb.org/jsp/FASB/Document_C/DocumentPage?cid=1176171644373&acceptedDisclaimer=true;
• ASU 2019-04, “Codification Improvements to Topic 326, Financial Instruments—Credit Losses, Topic 815,
Derivatives and Hedging, and Topic 825, Financial Instruments,” available at
https://www.fasb.org/jsp/FASB/Document_C/DocumentPage?cid=1176172541591&acceptedDisclaimer=true;
• ASU 2019-05, “Financial Instruments – Credit Losses (Topic 326): Targeted Transition Relief,” available
at https://www.fasb.org/jsp/FASB/Document_C/DocumentPage?cid=1176172668879&acceptedDisclaimer=true;
• ASU 2019-10, “Financial Instruments‒Credit Losses (Topic 326), Derivatives and Hedging (Topic 815),
and Leases (Topic 842): Effective Dates,” available at
https://www.fasb.org/jsp/FASB/Document_C/DocumentPage?cid=1176173775344&acceptedDisclaimer=true;
• ASU 2019-11, “Codification Improvements to Topic 326, Financial Instruments – Credit Losses,” available
at
https://www.fasb.org/jsp/FASB/Document_C/DocumentPage?cid=1176173831330&acceptedDisclaimer=tr
ue; and
• ASU 2020-03, “Codification Improvements to Financial Instruments,” available at
https://www.fasb.org/jsp/FASB/Document_C/DocumentPage?cid=1176174290619&acceptedDisclaimer=tr
ue.
Accounting for Hedging Activities
In August 2017, the FASB issued ASU No. 2017-12, “Targeted Improvements to Accounting for Hedging
Activities.” This ASU amends ASC Topic 815, Derivatives and Hedging, to “better align an entity’s risk
management activities and financial reporting for hedging relationships through changes to both the
designation and measurement guidance for qualifying hedging relationships and the presentation of hedge
results.”
For institutions that are public business entities, as defined under U.S. GAAP, ASU 2017-12 is currently in
effect. For institutions that are not public business entities (i.e., that are private companies), the FASB issued
ASU 2019-10 on November 15, 2019, to defer the effective date of ASU 2017-12 by one year. As amended
by ASU 2019-10, ASU 2017-12 will take effect for entities that are not public business entities for fiscal years
beginning after December 15, 2020, and interim periods within fiscal years beginning after December 15,
2021.
Early application of ASU 2017-12 is permitted for all institutions in any interim period or fiscal year before the
effective date of the ASU. Further, ASU 2017-12 specifies transition requirements and offers transition
elections for hedging relationships existing on the date of adoption (i.e., hedging relationships in which the
hedging instrument has not expired, been sold, terminated, or exercised or for which the institution has not
removed the designation of the hedging relationship). These transition requirements and elections should be
applied on the date of adoption of ASU 2017-12 and the effect of adoption should be reflected as of the
beginning of the fiscal year of adoption (i.e., the initial application date). Thus, if an institution early adopts the
ASU in an interim period, any adjustments shall be reflected as of the beginning of the fiscal year that includes
the interim period of adoption, e.g., as of January 1 for a calendar year institution. An institution that early
adopts ASU 2017-12 in an interim period for U.S. GAAP financial reporting purposes should also early adopt
the ASU in the same period for Call Report purposes.

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SUPPLEMENTAL INSTRUCTIONS – MARCH 2021

The Call Report instructions, including the Glossary entry for “Derivative Contracts,” will be revised to conform
to the ASU at a future date.
For additional information, institutions should refer to ASU 2017-12, which is available at
http://www.fasb.org/jsp/FASB/Document_C/DocumentPage?cid=1176169282347&acceptedDisclaimer=true;
and ASU 2019-10, “Financial Instruments‒Credit Losses (Topic 326), Derivatives and Hedging (Topic 815),
and Leases (Topic 842): Effective Dates,” which is available at
https://www.fasb.org/jsp/FASB/Document_C/DocumentPage?cid=1176173775344&acceptedDisclaimer=true.
New Revenue Recognition Accounting Standard
In May 2014, the FASB issued ASU No. 2014-09, “Revenue from Contracts with Customers,” which added
ASC Topic 606, Revenue from Contracts with Customers. The core principle of Topic 606 is that an entity
should recognize revenue at an amount that reflects the consideration to which it expects to be entitled
in exchange for transferring goods or services to a customer as part of the entity’s ordinary activities.
ASU 2014-09 also added Topic 610, Other Income, which applies to income recognition that is not within the
scope of Topic 606, other Topics (such as Topic 840 on leases), or other revenue or income guidance. As
discussed in the following section of these Supplemental Instructions, Topic 610 applies to an institution’s
sales of repossessed nonfinancial assets, such as other real estate owned (OREO). The sale of repossessed
nonfinancial assets is not considered an “ordinary activity” because institutions do not typically invest in
nonfinancial assets. ASU 2014-09 and subsequent amendments are collectively referred to herein as the
“revenue recognition standard.” For additional information on this accounting standard and the revenue
streams to which it does and does not apply, please refer to the Glossary entry for “Revenue from Contracts
with Customers” in the Call Report instruction books.
The revenue recognition standard is currently in effect for all institutions, unless ASU 2020-05, “Effective Dates
for Certain Entities,” applies. To provide immediate, near-term relief because of the unique challenges
resulting from the COVID-19 pandemic, the FASB issued ASU No. 2020-05, “Effective Dates for Certain
Entities,” on June 3, 2020, to defer, for one year, the required effective date of the revenue recognition
standard for certain institutions that are private companies. More specifically, institutions that are private
companies with a non-calendar fiscal year that ended after March 31, 2020, but before January 1, 2021 (e.g.,
a fiscal year that ended June 30, 2020, or September 30, 2020), and had not yet been required to file a Call
Report reflecting the adoption of the revenue recognition standard as of March 31, 2020, were provided the
option to elect to either (1) adopt this revenue recognition standard for annual reporting periods beginning after
December 15, 2019, and for interim reporting periods within annual reporting periods beginning after
December 15, 2020, or (2) follow the revenue recognition standard’s original effective date and begin to report
revenue in accordance with the standard in annual reporting periods beginning after December 15, 2018, and
interim reporting periods within annual reporting periods beginning after December 15, 2019. For example, an
institution that is a private company with a fiscal year that ends September 30 (that did not early adopt the
revenue recognition standard) could have elected to begin to report revenue in accordance with the standard
in its Call Report for September 30, 2020, or defer reporting to September 30, 2021.
For Call Report purposes, an institution must apply the revenue recognition standard on a modified
retrospective basis as of the original or deferred effective date of the standard. When applying the modified
retrospective method in the Call Report, an institution that is a private company with a fiscal year that begins
November 1, for example, and elected to defer the adoption of the new standard from its original effective date
must determine the effect on its retained earnings as of January 1, 2021, of adopting the revenue recognition
standard as of November 1, 2020. The institution should report the effect of this change in accounting
principle, net of applicable income taxes, as a direct adjustment to equity capital in Schedule RI-A, item 2, in
the Call Report for December 31, 2021. The institution also must report calendar year-to-date revenue in its
Call Report income statement in accordance with this new standard beginning as of January 1, 2021.
For additional information, institutions should refer to the revenue recognition standard, which is available at
http://www.fasb.org/jsp/FASB/Page/SectionPage&cid=1176156316498.

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SUPPLEMENTAL INSTRUCTIONS – MARCH 2021

Revenue Recognition: Accounting for Sales of OREO
As stated in the preceding section, Topic 610 applies to an institution’s sale of repossessed nonfinancial
assets, such as OREO. When the revenue recognition standard becomes effective at the dates discussed
above, Topic 610 will eliminate the prescriptive criteria and methods for sale accounting and gain recognition
for dispositions of OREO currently set forth in Subtopic 360-20, Property, Plant, and Equipment – Real Estate
Sales. Under the new standard, an institution will recognize the entire gain or loss, if any, and derecognize the
OREO at the time of sale if the transaction meets certain requirements of Topic 606. Otherwise, an institution
will generally record any payments received as a deposit liability to the buyer and continue reporting the
OREO as an asset at the time of the transaction.
The following paragraphs highlight key aspects of Topic 610 that will apply to seller-financed sales of OREO
once the new standard takes effect. When implementing the new standard, an institution will need to exercise
judgment in determining whether a contract (within the meaning of Topic 606) exists for the sale or transfer of
OREO, whether the institution has performed its obligations identified in the contract, and what the transaction
price is for calculation of the amount of gain or loss. For additional information, please refer to the Glossary
entry for “Foreclosed Assets” in the Call Report instruction books, which provides guidance on the application
of the new standard to sales of OREO.
Under Topic 610, when an institution does not have a controlling financial interest in the OREO buyer under
Topic 810, Consolidation, the institution’s first step in assessing whether it can derecognize an OREO asset
and recognize revenue upon the sale or transfer of the OREO is to determine whether a contract exists under
the provisions of Topic 606. In order for a transaction to be a contract under Topic 606, it must meet five
criteria. Although all five criteria require careful analysis for seller-financed sales of OREO, two criteria in
particular may require significant judgment. These criteria are the commitment of the parties to the transaction
to perform their respective obligations and the collectability of the transaction price. To evaluate whether a
transaction meets the collectability criterion, a selling institution must determine whether it is probable that it
will collect substantially all of the consideration to which it is entitled in exchange for the transfer of the OREO,
i.e., the transaction price. To make this determination, as well as the determination that the buyer of the
OREO is committed to perform its obligations, a selling institution should consider all facts and circumstances
related to the buyer’s ability and intent to pay the transaction price. As with the current accounting standards
governing seller-financed sales of OREO, the amount and character of a buyer’s initial equity in the property
(typically the cash down payment) and recourse provisions remain important factors to evaluate. Other factors
to consider may include, but are not limited to, the financing terms of the loan (including amortization and any
balloon payment), the credit standing of the buyer, the cash flow from the property, and the selling institution’s
continuing involvement with the property following the transaction.
If the five contract criteria in Topic 606 have not been met, the institution generally may not derecognize the
OREO asset or recognize revenue (gain or loss) as an accounting sale has not occurred. In contrast, if an
institution determines the contract criteria in Topic 606 have been met, it must then determine whether it has
satisfied its performance obligations as identified in the contract by transferring control of the asset to the
buyer. For seller-financed sales of OREO, the transfer of control generally occurs on the closing date of the
sale when the institution obtains the right to receive payment for the property and transfers legal title to the
buyer. However, an institution must consider all relevant facts and circumstances to determine whether
control of the OREO has transferred.
When a contract exists and an institution has transferred control of the asset, the institution should
derecognize the OREO asset and recognize a gain or loss for the difference between the transaction price and
the carrying amount of the OREO asset. Generally, the transaction price in a sale of OREO will be the
contract amount in the purchase/sale agreement, including for a seller-financed sale at market terms.
However, the transaction price may differ from the amount stated in the contract due to the existence of offmarket terms on the financing. In this situation, to determine the transaction price, the contract amount should
be adjusted for the time value of money by using as the discount rate a market rate of interest considering the
credit characteristics of the buyer and the terms of the financing.
As stated in the preceding section, an institution must apply the revenue recognition standard, including the
change in accounting for seller-financed OREO sales, on a modified retrospective basis for Call Report
purposes. An institution that is a private company with a fiscal year other than the calendar year, such as an
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SUPPLEMENTAL INSTRUCTIONS – MARCH 2021

institution with a fiscal year that begins November 1 that elected to defer reporting revenue in accordance with
the new standard in the Call Report for December 31, 2021, should follow the guidance for applying the
modified retrospective method in the preceding section to its seller-financed OREO sales.
Accounting for Leases
In February 2016, the FASB issued ASU No. 2016-02, “Leases,” which added ASC Topic 842, Leases. Once
effective, this guidance, as amended by certain subsequent ASUs, supersedes ASC Topic 840, Leases.
Topic 842 does not fundamentally change lessor accounting; however, it aligns terminology between lessee
and lessor accounting and brings key aspects of lessor accounting into alignment with the FASB’s revenue
recognition standard. As a result, the classification difference between direct financing leases and sales-type
leases for lessors moves from a risk-and-rewards principle to a transfer of control principle. Additionally, there
is no longer a distinction in the treatment of real estate and non-real estate leases by lessors.
The most significant change that Topic 842 makes is to lessee accounting. Under existing accounting
standards, lessees recognize lease assets and lease liabilities on the balance sheet for capital leases, but do
not recognize operating leases on the balance sheet. The lessee accounting model under Topic 842 retains
the distinction between operating leases and capital leases, which the new standard labels finance leases.
However, the new standard requires lessees to record a right-of-use (ROU) asset and a lease liability on the
balance sheet for operating leases. (For finance leases, a lessee’s lease asset also is designated an ROU
asset.) In general, the new standard permits a lessee to make an accounting policy election to exempt leases
with a term of one year or less at their commencement date from on-balance sheet recognition. The lease
term generally includes the noncancellable period of a lease as well as purchase options and renewal options
reasonably certain to be exercised by the lessee, renewal options controlled by the lessor, and any other
economic incentive for the lessee to extend the lease. An economic incentive may include a related-party
commitment. When preparing to implement Topic 842, lessees will need to analyze their existing lease
contracts to determine the entries to record on adoption of this new standard.
For a sale-leaseback transaction to qualify for sales treatment, Topic 842 requires certain criteria within
Topic 606 to be met. Topic 606 focuses on the transfer of control of the leased asset from the seller/lessee to
the buyer/lessor. A sale-leaseback transaction that does not transfer control is accounted for as a financing
arrangement. For a transaction currently accounted for as a sale-leaseback under existing U.S. GAAP, an
entity is not required to reassess whether the transaction would have qualified as a sale and a leaseback
under Topic 842 when it adopts the new standard.
Leases classified as leveraged leases prior to the adoption of Topic 842 may continue to be accounted for
under Topic 840 unless subsequently modified. Topic 842 eliminates leveraged lease accounting for leases
that commence after an institution adopts the new accounting standard.
For institutions that are public business entities, as defined under U.S. GAAP, ASU 2016-02 is currently in
effect. For institutions that are not public business entities (i.e., that are private companies), ASU 2016-02,
as amended in 2019, was scheduled to take effect for fiscal years beginning after December 15, 2020, and
interim reporting periods within fiscal years beginning after December 15, 2021. However, to provide
immediate, near-term relief because of the significant business disruptions caused by the COVID-19
pandemic, the FASB issued ASU No. 2020-05, “Effective Dates for Certain Entities,” on June 3, 2020, to defer,
for one year, the required effective date of the new lease accounting standard for entities not yet required to
adopt ASU 2016-02. As a result, ASU 2016-02 will now take effect for institutions that are private companies
for fiscal years beginning after December 15, 2021, and to interim periods within fiscal years beginning after
December 15, 2022. Early application of ASU 2016-02 continues to be permitted. An institution that early
adopts the new standard must apply it in its entirety to all lease-related transactions. If an institution chooses
to early adopt the new standard for financial reporting purposes, the institution should implement the new
standard in its Call Report for the same quarter-end report date.
Under ASU 2016-02, an institution must apply the new leases standard on a modified retrospective basis for
financial reporting purposes. Under the modified retrospective method, an institution should apply the leases
standard and the related cumulative-effect adjustments to affected accounts existing as of the beginning of the
earliest period presented in the financial statements. However, as explained in the “Changes in accounting
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SUPPLEMENTAL INSTRUCTIONS – MARCH 2021

principles” section of the Glossary entry for “Accounting Changes” in the Call Report instructions, when a new
accounting standard (such as the leases standard) requires the use of a retrospective application method,
institutions should instead report the cumulative effect of adopting the new standard on the amount of retained
earnings at the beginning of the year in which the new standard is first adopted for Call Report purposes (net
of applicable income taxes, if any) as a direct adjustment to equity capital in the Call Report. For the adoption
of the new leases standard, the cumulative-effect adjustment to bank equity capital for this change in
accounting principle should be reported in Schedule RI-A, item 2, and disclosed in Schedule RI-E, item 4.b,
“Effect of adoption of lease accounting standard - ASC Topic 842.” In July 2018, the FASB issued
ASU 2018-11, “Targeted Improvements,” which provides an additional and “optional transition method” for
comparative reporting purposes at adoption of the new leases standard. Under this optional transition method,
an institution initially applies the new leases standard at the adoption date (e.g., January 1, 2022, for an
institution that is a private company with a calendar year fiscal year) and, for Call Report purposes, the
institution should recognize and report a cumulative-effect adjustment to the opening balance of retained
earnings in the period of adoption consistent with the Glossary instructions described above.
For Call Report purposes, all ROU assets for operating leases and finance leases, including ROU assets for
operating leases recorded upon adoption of ASU 2016-02, should be reflected in Schedule RC, item 6,
“Premises and fixed assets.”
Institutions that have adopted ASU 2016-02 should report the lease liability for operating leases on the
Call Report balance sheet in Schedule RC, item 20, ‘‘Other liabilities.’’ In Schedule RC-G, Other Liabilities,
operating lease liabilities should be reported in item 4, “All other liabilities.” In addition, institutions should
report the amount of operating lease liabilities in Schedule RC-G, item 4.e, if this amount is greater than
$100,000 and exceeds 25 percent of the total amount reported in Schedule RC-G, item 4. Lease liabilities for
finance leases should be reported in Schedule RC-M, items 5.b, “Other borrowings,” and 10.b, “Amount of
‘Other borrowings’ that are secured.”
For an operating lease, a lessee should report a single lease cost for the lease in the Call Report income
statement, calculated so that the cost of the lease is allocated over the lease term on a generally straight-line
basis, in Schedule RI, item 7.b, “Expenses of premises and fixed assets.” For a finance lease, a lessee should
report interest expense on the lease liability separately from the amortization expense on the ROU asset.
The interest expense should be reported on Schedule RI in item 2.c, “Other interest expense,” on the
FFIEC 051 and in item 2.c, “Interest on trading liabilities and other borrowed money,” on the FFIEC 031
and the FFIEC 041. The amortization expense should be reported on Schedule RI in item 7.b, “Expenses of
premises and fixed assets.”
To the extent an ROU asset arises due to a lessee’s lease of a tangible asset (e.g., building or equipment), the
ROU asset should be treated as a tangible asset not subject to deduction from regulatory capital. Except for
institutions that have a community bank leverage ratio framework election in effect, an ROU asset not subject
to deduction must be risk weighted at 100 percent in accordance with the agencies’ regulatory capital rules
and included in a lessee institution’s calculations of total risk-weighted assets. In addition, an ROU asset must
be included in a lessee institution’s total assets for leverage capital purposes.
For additional information on ASU 2016-02, institutions should refer to the FASB’s website at
https://www.fasb.org/leases, which includes a link to the lease accounting standard and subsequent
amendments to this standard. Institutions may also refer to the Glossary entry for “Lease Accounting” in the
Call Report instruction books, which was updated as of September 30, 2020, in response to the changes in the
accounting for leases summarized above.
Amending Previously Submitted Report Data
Should your institution find that it needs to revise previously submitted Call Report data, please make the
appropriate changes to the data, ensure that the revised data passes the FFIEC-published validation criteria,
and submit the revised data file to the CDR using one of the two methods described in the banking agencies'
FIL for the March 31, 2021, report date. For technical assistance with the submission of amendments to the
CDR, please contact the CDR Help Desk by telephone at (888) CDR-3111, by fax at (703) 774-3946, or by
e-mail at [email protected].

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SUPPLEMENTAL INSTRUCTIONS – MARCH 2021

Other Reporting Matters
For the following topics, institutions should continue to follow the guidance in the specified Call Report
Supplemental Instructions:
•
•
•
•
•
•
•
•
•
•

True-up Liability under an FDIC Loss-Sharing Agreement – Supplemental Instructions for June 30, 2015
(https://www.ffiec.gov/PDF/FFIEC_forms/FFIEC031_FFIEC041_suppinst_201506.pdf)
Troubled Debt Restructurings, Current Market Interest Rates, and ASU No. 2011-02 – Supplemental
Instructions for December 31, 2014
(https://www.ffiec.gov/PDF/FFIEC_forms/FFIEC031_FFIEC041_suppinst_201412.pdf)
Determining the Fair Value of Derivatives – Supplemental Instructions for June 30, 2014
(https://www.ffiec.gov/PDF/FFIEC_forms/FFIEC031_FFIEC041_suppinst_201406.pdf)
Indemnification Assets and ASU No. 2012-06 – Supplemental Instructions for June 30, 2014
(https://www.ffiec.gov/PDF/FFIEC_forms/FFIEC031_FFIEC041_suppinst_201406.pdf)
Small Business Lending Fund – Supplemental Instructions for March 31, 2013
(https://www.ffiec.gov/PDF/FFIEC_forms/FFIEC031_FFIEC041_suppinst_201303.pdf)
Reporting Purchased Subordinated Securities in Schedule RC-S – Supplemental Instructions for
September 30, 2011
(https://www.ffiec.gov/PDF/FFIEC_forms/FFIEC031_FFIEC041_suppinst_201109.pdf)
Treasury Department’s Capital Purchase Program – Supplemental Instructions for September 30, 2011
(https://www.ffiec.gov/PDF/FFIEC_forms/FFIEC031_FFIEC041_suppinst_201109.pdf)
Deposit insurance assessments – Supplemental Instructions for September 30, 2009
(https://www.ffiec.gov/PDF/FFIEC_forms/FFIEC031_041_suppinst_200909.pdf)
Accounting for share-based payments under FASB Statement No. 123 (Revised 2004), Share-Based
Payment – Supplemental Instructions for December 31, 2006
(https://www.ffiec.gov/PDF/FFIEC_forms/FFIEC031_041_suppinst_200612.pdf)
Commitments to originate and sell mortgage loans – Supplemental Instructions for March 31, 2006
(https://www.ffiec.gov/PDF/FFIEC_forms/FFIEC031_041_suppinst_200603.pdf) and June 30, 2005
(https://www.ffiec.gov/PDF/FFIEC_forms/FFIEC031_041_suppinst_200506.pdf)

Call Report Software Vendors
For information on available Call Report preparation software products, institutions should contact:
Axiom Software Laboratories, Inc.
67 Wall Street, 17th Floor
New York, New York 10005
Telephone: (212) 248-4188
http://www.axiomsl.com

DBI Financial Systems, Inc.
P.O. Box 14027
Bradenton, Florida 34280
Telephone: (800) 774-3279
http://www.e-dbi.com

Fed Reporter, Inc.
28118 Agoura Road, Suite 202
Agoura Hills, California 91301
Telephone: (888) 972-3772
http://www.fedreporter.net

FIS Compliance Solutions
16855 West Bernardo Drive,
Suite 270
San Diego, California 92127
Telephone: (800) 825-3772
http://www.callreporter.com

FiServ, Inc.
1345 Old Cheney Road
Lincoln, Nebraska 68512
Telephone: (402) 423-2682
http://www.premier.fiserv.com

KPMG LLP
303 Peachtree Street, Suite 2000
Atlanta, Georgia 30308
Telephone: (404) 221-2355
https://advisory.kpmg.us/riskconsulting/frm/capitalmanagement.html

SHAZAM Core Services
6700 Pioneer Parkway
Johnston, Iowa 50131
Telephone: (888) 262-3348
http://www.cardinal400.com

Vermeg
205 Lexington Avenue,
14th floor
New York, New York 10016
Telephone: (212) 682-4930
http://www.vermeg.com

Wolters Kluwer Financial Services
130 Turner Street, Building 3,
4th Floor
Waltham, Massachusetts 02453
Telephone (800) 261-3111
http://www.wolterskluwer.com

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