FFIEC041_202106_f_draft

Consolidated Reports of Condition and Income

FFIEC041_202106_f_draft

OMB: 7100-0036

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FFIEC 041 Draft Reporting Form and Instructions for Call Report
Revisions with Effective Dates Beginning with the June 30, 2021, Report Date

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The following draft reporting form and draft instructions, both of which are subject to change,
present the pages from the FFIEC 041 Call Report as they are proposed to be revised, subject to
final approval by the U.S. Office of Management and Budget. These proposed revisions are
described in the federal banking agencies’ initial Paperwork Reduction Act (PRA) Federal
Register notices published in the Federal Register on December 18, 2020 (see FIL-117-2020,
dated December 30, 2020) and on February 5, 2021 (see FIL-11-2021, dated February 23, 2021).
As discussed in the agencies’ final PRA Federal Register notice published in the Federal Register
on May 24, 2021, the agencies are proceeding with the revisions to the FFIEC 041 Call Report,
with certain modifications.

The initial and final PRA Federal Register notices are available on the FFIEC’s webpage for the
FFIEC 041 Call Report.

Draft as of May 24, 2021

Table of Contents

Impacted Schedule/ Instruction Book Entry

Page

Effective as of the June 30, 2021, Report Date

4
7

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1. Schedule RC-O, Memorandum item 5
a. Report Form
b. Instructions

Effective as of the September 30, 2021, Report Date

2. Schedule RC-E, Memorandum items 1.h and 1.i
a. Report Form
b. Instructions
c. Glossary

18
20
21

Clarifications for the June 30, 2021 Call Report

23
25

1. Schedule RC-E, Memorandum item 1.f
a. Instructions
2. Brokered Deposits Glossary Entry

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The revisions on pages 4 to 16 are effective as of the June 30, 2021, report
date, subject to final approval by the OMB.

FFIEC 041
Page 52 of 87
RC-36

Schedule RC-O—Other Data for Deposit Insurance Assessments
All FDIC-insured depository institutions must complete items 1 and 2, 4 through 9,10, and 11, Memorandum item 1, and, if
applicable, item 9.a, Memorandum items 2, 3, and 5 6 through 18 each quarter. Unless otherwise indicated, complete items 1
through 11 and Memorandum items 1 through 3 on an “unconsolidated single FDIC certificate number basis” (see
instructions) and complete Memorandum items 5 6 through 18 on a fully consolidated basis.
Dollar Amounts in Thousands RCON
1. Total deposit liabilities before exclusions (gross) as defined in Section 3(l) of the Federal
Deposit Insurance Act and FDIC regulations .......................................................................... F236
2. Total allowable exclusions, including interest accrued and unpaid on allowable exclusions .............. F237
3. Not applicable
4. Average consolidated total assets for the calendar quarter........................................................ K652
Number
a. Averaging method used
(for daily averaging, enter 1, for weekly averaging, enter 2) ..................... K653

Amount

1.
2.
4.
4.a.
Amount

K654

5.
6.

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5. Average tangible equity for the calendar quarter1 ....................................................................
6. Holdings of long-term unsecured debt issued by other FDIC-insured depository institutions .............
7. Unsecured "Other borrowings" with a remaining maturity of (sum of items 7.a through 7.d must be
less than or equal to Schedule RC-M, items 5.b.(1)(a)–(d) minus item 10.b):
a. One year or less ...........................................................................................................
b. Over one year through three years ...................................................................................
c. Over three years through five years ..................................................................................
d. Over five years .............................................................................................................
8. Subordinated notes and debentures with a remaining maturity of
(sum of items 8.a. through 8.d. must equal Schedule RC, item 19):
a. One year or less ...........................................................................................................
b. Over one year through three years ...................................................................................
c. Over three years through five years ..................................................................................
d. Over five years .............................................................................................................
9. Brokered reciprocal deposits (included in Schedule RC-E, Memorandum item 1.b) ........................

K655

G465
G466

7.a.
7.b.
7.c.
7.d.

G467
G468

G469
G470

8.a.
8.b.
8.c.
8.d.
9.

G471
G472
G803

Item 9.a is to be completed on a fully consolidated basis by all institutions that own another insured
depository institution.

a. Fully consolidated brokered reciprocal deposits................................................................... L190
10. Banker's bank certification:
Yes
Does the reporting institution meet both the statutory definition of a banker's bank and the business
K656
conduct test set forth in FDIC regulations? ............................................................................
If the answer to item 10 is "YES," complete items 10.a and 10.b.

9.a.
No

10.
Amount

10.a.
10.b.

a. Banker's bank deduction ................................................................................................ K657
b. Banker's bank deduction limit .......................................................................................... K658
11. Custodial bank certification:
Yes

11.

Does the reporting institution meet the definition of a custodial bank set forth in FDIC regulations? .. K659
If the answer to item 11 is "YES," complete items 11.a and 11.b.2

Amount

a. Custodial bank deduction ............................................................................................... K660
b. Custodial bank deduction limit ......................................................................................... K661

11.a.
11.b.

1. See instructions for averaging methods. For deposit insurance assessment purposes, tangible equity is defined as Tier 1 capital as set forth in the
banking agencies' regulatory capital standards and reported in Schedule RC-R, Part I, item 26, except as described in the instructions.
2. If the amount reported in item 11.b is zero, item 11.a may be left blank.

06/2021

FFIEC 041
Page 53 of 87
RC-37

Schedule RC-O—Continued
Memoranda
Amount

M.1.a.(1)
M.1.a.(2)
M.1.b.(1)
M.1.b.(2)

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Dollar Amounts in Thousands RCON
1. Total deposit liabilities of the bank, including related interest accrued and unpaid, less
allowable exclusions, including related interest accrued and unpaid (sum of Memorandum
items 1.a.(1), 1.b.(1), 1.c.(1), and 1.d.(1) must equal Schedule RC-O, item 1 less item 2):
a. Deposit accounts (excluding retirement accounts) of $250,000 or less:1
(1) Amount of deposit accounts (excluding retirement accounts) of $250,000 or less............. F049
Number
(2) Number of deposit accounts (excluding retirement accounts)
F050
of $250,000 or less ...............................................................
b. Deposit accounts (excluding retirement accounts) of more than $250,000:1
(1) Amount of deposit accounts (excluding retirement accounts) of more than $250,000 ........ F051
Number
(2) Number of deposit accounts (excluding retirement accounts)
F052
of more than $250,000 ...........................................................
c. Retirement deposit accounts of $250,000 or less:1
(1) Amount of retirement deposit accounts of $250,000 or less ........................................ F045

M.1.c.(1)

Number

(2) Number of retirement deposit accounts of $250,000 or less........... F046

M.1.c.(2)

d. Retirement deposit accounts of more than $250,000:
(1) Amount of retirement deposit accounts of more than $250,000 ................................... F047
1

M.1.d.(1)

Number

(2) Number of retirement deposit accounts of more than $250,000 ..... F048

M.1.d.(2)

Memorandum item 2 is to be completed by banks with $1 billion or more in total assets.2

2. Estimated amount of uninsured deposits including related interest accrued and unpaid
(see instructions)3 ....................................................................................................... 5597
3. Has the reporting institution been consolidated with a parent bank or savings association
in that parent bank's or parent savings association's Call Report?
If so, report the legal title and FDIC Certificate Number of the parent bank or parent savings
RCON
association:
TEXT
A545

M.2.

FDIC Cert. No.

A545

M.3.

4. and 5. Not applicable

1. The dollar amounts used as the basis for reporting in Memorandum items 1.a through 1.d reflect the deposit insurance limits in effect on the
report date.
2. For the $1 billion asset-size test for report dates through December 31, 2021, an institution may use the lesser of the total assets
reported in its Report of Condition as of December 31, 2019, or June 30, 2020.
3. Uninsured deposits should be estimated based on the deposit insurance limits set forth in Memorandum items 1.a through 1.d.

06/2021

FFIEC 041
Page 54 of 87
RC-38

5. Applicable portion of the CECL transitional amount or modified CECL transitional amount that has been added to retained
earnings for regulatory capital purposes as of the current report date and is attributable to loans and leases held for investment.

Schedule RC-O—Continued
Amounts reported in Memorandum items 6 through 9, 14, and 15 will not be made available to the public on an
individual institution basis.

Memoranda—Continued
Dollar Amounts in Thousands RCON
Memorandum items 5 6 through 12 are to be completed by "large institutions" and "highly
complex institutions" as defined in FDIC regulations.
XXXX

M.5.

K665
K666

M.6.a.
M.6.b.
M.6.c.
M.6.d.

N025
N026

M.7.a.
M.7.b.

N027
N028

M.8.a.
M.8.b.

N029
N030

M.9.a.
M.9.b.

K676

M.10.a.

K677

M.10.b.

K669

M.11.

K678

M.12.

N177

M.13.a.
M.13.b.
M.13.c.

K663
K664

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6. Criticized and classified items:
a. Special mention ......................................................................................................
b. Substandard ..........................................................................................................
c. Doubtful ................................................................................................................
d. Loss .....................................................................................................................
7. “Nontraditional 1– 4 family residential mortgage loans” as defined for assessment purposes
only in FDIC regulations:
a. Nontraditional 1– 4 family residential mortgage loans......................................................
b. Securitizations of nontraditional 1– 4 family residential mortgage loans ..............................
8. “Higher-risk consumer loans” as defined for assessment purposes only in FDIC regulations:
a. Higher-risk consumer loans.......................................................................................
b. Securitizations of higher-risk consumer loans ...............................................................
9. “Higher-risk commercial and industrial loans and securities” as defined for assessment
purposes only in FDIC regulations:
a. Higher-risk commercial and industrial loans and securities ..............................................
b. Securitizations of higher-risk commercial and industrial loans and securities .......................
10. Commitments to fund construction, land development, and other land loans secured by real
estate:
a. Total unfunded commitments ....................................................................................
b. Portion of unfunded commitments guaranteed or insured by the U.S. government (including
the FDIC) ..............................................................................................................
11. Amount of other real estate owned recoverable from the U.S. government under
guarantee or insurance provisions (excluding FDIC loss-sharing agreements) ........................
12. Nonbrokered time deposits of more than $250,000 in domestic offices
(included in Schedule RC-E, Part I, Memorandum item 2.d) ................................................

Amount

Memorandum item 13.a is to be completed by "large institutions" and "highly complex institutions"
as defined in FDIC regulations. Memorandum items 13.b through 13.h are to be completed by
"large institutions" only.

13. Portion of funded loans and securities guaranteed or insured by the U.S. government
(including FDIC loss-sharing agreements):
a. Construction, land development, and other land loans secured by real estate ......................
b. Loans secured by multifamily residential and nonfarm nonresidential properties...................
c. Closed-end loans secured by first liens on 1– 4 family residential properties ........................
d. Closed-end loans secured by junior liens on 1– 4 family residential properties and
revolving, open-end loans secured by 1– 4 family residential properties and extended
under lines of credit .................................................................................................
e. Commercial and industrial loans ................................................................................
f. Credit card loans to individuals for household, family, and other personal expenditures ...............
g. All other loans to individuals for household, family, and other personal expenditures .............
h. Non-agency residential mortgage-backed securities .......................................................

N178
N179

M.13.d.
M.13.e.
M.13.f.
M.13.g.
M.13.h.

N180
N181
N182
N183
M963

Memorandum items 14 and 15 are to be completed by "highly complex institutions" as defined in
FDIC regulations.
14. Amount of the institution's largest counterparty exposure....................................................
15. Total amount of the institution's 20 largest counterparty exposures .......................................

M.14.
M.15.

K673
K674

06/2021

FFIEC 031 and 041

RC-O - ASSESSMENTS

SCHEDULE RC-O – OTHER DATA FOR DEPOSIT INSURANCE
ASSESSMENTS
General Instructions
Each FDIC-insured depository institution must complete items 1 and 2, 4 through 9, 10, and 11;
Memorandum item 1; and, if applicable, items 3 and 9.a and Memorandum items 2 and 3 (and
Memorandum item 4 on the FFIEC 031 report) each quarter. Each “large institution” and each “highly
complex institution,” which generally are FDIC-insured depository institutions with $10 billion or more in
total assets, must complete Memorandum items 65 through 12, 13.a, 16, and 18 and, if applicable,
Memorandum item 17 each quarter. In addition, each “large institution” must complete Memorandum
items 13.b through 13.h and each “highly complex institution” must complete Memorandum items 14 and
15 each quarter. The terms “large institution” and “highly complex institution” are more fully described in
the General Instructions preceding Memorandum item 65.

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Each separately chartered depository institution that is insured by the FDIC has a unique FDIC certificate
number. When one FDIC-insured institution owns another FDIC-insured institution as a subsidiary, the
parent institution should complete items 1 through 11 (except item 9.a) and Memorandum items 1 through
3 (and Memorandum item 4 on the FFIEC 031 report) of Schedule RC-O by accounting for the insured
institution subsidiary under the equity method of accounting instead of consolidating it, i.e., on an
“unconsolidated single FDIC certificate number basis.” Thus, each FDIC-insured institution should report
only its own amounts in items 1 through 11 (except item 9.a) and Memorandum items 1 through 3 (and
Memorandum item 4 on the FFIEC 031 report) of Schedule RC-O under its own FDIC certificate number
without eliminating the parent and subsidiary institutions’ intercompany balances. (However, an FDICinsured institution that owns another FDIC-insured institution should complete item 9.a by consolidating
its subsidiary institution.) In contrast, when an FDIC-insured institution has entities other than FDICinsured institutions that must be consolidated for purposes of Schedule RC, Balance Sheet, the parent
institution should complete items 1 through 11 and Memorandum items 1 through 3 (and Memorandum
item 4 on the FFIEC 031 report) of Schedule RC-O on a consolidated basis with respect to these other
entities.

“Large institutions” and “highly complex institutions,” including those that own another FDIC-insured
institution as a subsidiary, should complete Memorandum items 65 through 18, as appropriate, on a fully
consolidated basis.
Item Instructions
Item No.

Total deposit liabilities before exclusions (gross) as defined in Section 3(l) of the
Federal Deposit Insurance Act and FDIC regulations. Report on an unconsolidated single
FDIC certificate number basis the gross total deposit liabilities as of the calendar quarter-end
report date that meet the statutory definition of deposits in Section 3(l) of the Federal Deposit
Insurance Act before deducting allowable exclusions from total deposits. An institution’s
gross total deposit liabilities are the combination of:

Caption and Instructions

•
•
•
•
•
•

FFIEC 031 and 041

All deposits in “domestic offices” reported in Schedule RC, item 13.a;
All deposits in “foreign offices” reported in Schedule RC, item 13.b, on the FFIEC 031
report;
Interest accrued and unpaid on deposits in “domestic offices” reported in Schedule RC-G,
item 1.a;
Interest accrued and unpaid on deposits in “foreign offices” included in Schedule RC-G,
item 1.b;
Uninvested trust funds held in the institution’s own trust department;
Deposits of consolidated subsidiaries (except any consolidated subsidiary that is an
FDIC-insured institution) and the interest accrued and unpaid on such deposits;

RC-O-1
(96-1921)

RC-O - ASSESSMENTS

FFIEC 031 and 041

RC-O - ASSESSMENTS

Memoranda
Caption and Instruction

2
(cont.)

(7) For all other deposit accounts, the bank should make a reasonable estimate of the
portion of these deposits that is uninsured using the data available from its information
systems. In developing this estimate, if the bank has automated information systems in
place that enable it to identify jointly owned accounts and estimate the deposit insurance
coverage of these deposits, the higher level of insurance afforded these joint accounts
should be taken into consideration. Similarly, if the bank has automated information
systems in place that enable it to classify accounts by deposit owner and/or ownership
capacity, the bank should incorporate this information into its estimate of the amount of
uninsured deposits by aggregating accounts held by the same deposit owner in the same
ownership capacity before applying the $250,000 insurance limit. Ownership capacities
include, but are not limited to, single ownership, joint ownership, business (excluding sole
proprietorships), revocable trusts, irrevocable trusts, and retirement accounts.

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Item No.

In the absence of automated information systems, a bank may use nonautomated information
such as paper files or less formal knowledge of its depositors if such information provides
reasonable estimates of appropriate portions of its uninsured deposits. A bank's use of such
nonautomated sources of information is considered appropriate unless errors associated with
the use of such sources would contribute significantly to an overall error in the FDIC's
estimate of the amount of insured and uninsured deposits in the banking system.
3

Has the reporting institution been consolidated with a parent bank or savings
association in that parent bank's or parent savings association's Call Report? If the
reporting institution is owned by another bank or savings association and that parent bank or
parent savings association is consolidating the reporting institution as part of the parent
institution's Call Report for this report date, report the legal title and FDIC Certificate Number
of the parent institution in this item.

NOTE: Memorandum item 4 is applicable only to banks filing the FFIEC 031 report form.

Dually payable deposits in the reporting institution’s foreign branches. Report the
amount of deposits included in Schedule RC, item 13.b, Deposits “In foreign offices, Edge
and Agreement subsidiaries, and IBFs,” that are carried on the books and records of an
office of the reporting institution located outside of any state and payable at both that office
and a branch of the reporting institution in any state. For purposes of this item, the term
“state” is defined in Section 3(a)(3) of the Federal Deposit Insurance Act and means “any
State of the United States, the District of Columbia, any territory of the United States, Puerto
Rico, Guam, American Samoa, the Trust Territory of the Pacific Islands, the Virgin Islands,
and the Northern Mariana Islands.”

Exclude deposits held in Overseas Military Banking Facilities operated under Department of
Defense regulations, 32 CFR Parts 230 and 231. Such facilities are not considered offices
located outside any state of the United States. Deposits at Overseas Military Banking
Facilities are to be reported in Schedule RC-E, Part I, as deposits in domestic offices.

Not applicable.

FFIEC 031 and 041

RC-O-17
(96-1621)

RC-O - ASSESSMENTS

FFIEC 031 and 041

RC-O - ASSESSMENTS

General Instructions for Schedule RC-O, Memorandum items 65 through 18
Memorandum items 65 through 18 are applicable only to large institutions and/or highly complex
institutions as defined below. Amounts reported in Memorandum items 6 through 9, 14, 15, and 18 will
not be made available to the public on an individual institution basis. Large institutions and highly
complex institutions should complete Memorandum items 65 through 18, as appropriate, on a fully
consolidated basis. Thus, when a large institution or highly complex institution owns another FDICinsured institution as a subsidiary, it should complete Memorandum items 65 through 18, as appropriate,
on a fully consolidated basis.

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According to Section 327.8(f) of the FDIC’s regulations, a large institution is an FDIC-insured bank or
savings association that reported total assets of $10 billion or more as of December 31, 2006, that does
not meet the definition of a highly complex institution. After December 31, 2006, if a bank or savings
association classified as a small institution in accordance with Section 327.8(e) of the FDIC’s regulations
reports total assets of $10 billion or more for four consecutive quarters, the bank or savings association
will be classified as a large institution beginning the following quarter. In the Consolidated Reports of
Condition and Income, an FDIC-insured depository institution’s total assets are reported in Schedule RC,
item 12.
An institution that has a community bank leverage ratio (CBLR) framework election in effect as of the
quarter-end report date, as reported in Schedule RC-R, Part I, item 31.a (and further described in the
General Instructions for Schedule RC-R, Part I), shall be classified as a small institution for deposit
insurance assessments, even if that institution otherwise would be classified as a large institution.1
According to Section 327.8(g) of the FDIC’s regulations, a highly complex institution is an FDIC-insured
bank or savings association (excluding a credit card bank2) that:
(1) Has had $50 billion or more in total assets for at least four consecutive quarters that either is
controlled by a U.S. parent holding company that has had $500 billion or more in total assets for four
consecutive quarters, or is controlled by one or more intermediate U.S. parent holding companies that
are controlled by a U.S. holding company that has had $500 billion or more in total assets for four
consecutive quarters; or

(2) Is a processing bank or trust company that has had $10 billion or more in total assets for at least four
consecutive quarters. According to Section 327.8(s) of the FDIC’s regulations, a processing bank or
trust company is “an institution whose last three years’ non-lending interest income, fiduciary
revenues, and investment banking fees, combined, exceed 50 percent of total revenues (and its last
three years fiduciary revenues are non-zero), and whose total fiduciary assets total $500 billion or
more.”

1 An

institution that has a CBLR framework election in effect as of the quarter-end report date that meets the
definition of an established depository institution under 12 CFR 327.8(k), generally one that has been federally
insured for at least five years, will be assessed as an established small institution. An institution that has a CBLR
framework election in effect as of the quarter-end report date that has been federally insured for less than five years
will be assessed as a new small institution under 12 CFR 327.8(w). An institution that has a CBLR framework
election in effect as of the quarter-end report date with assets between $5 and $10 billion cannot request to be
treated as a large institution for deposit insurance assessments under 12 CFR 327.16(f).
defined in Section 327.8(t) of the FDIC’s regulations, a credit card bank is “a bank for which credit card
receivables plus securitized receivables exceed 50 percent of assets plus securitized receivables.”
2 As

FFIEC 031 and 041

RC-O-19
(36-2021)

RC-O - ASSESSMENTS

FFIEC 031 and 041

RC-O - ASSESSMENTS

Memoranda
General Instructions for Schedule RC-O, Memorandum items 65 through 18 (cont.)
If, after December 31, 2010, a bank or savings association classified as a highly complex institution falls
below $50 billion in total assets for four consecutive quarters, or its parent company or companies fall
below $500 billion in total assets for four consecutive quarters, or a processing bank or trust company
falls below $10 billion in total assets for four consecutive quarters, the FDIC will reclassify the bank or
savings association as a large institution or a small institution, as appropriate,1 beginning the quarter after
the fourth consecutive quarter.

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Amounts Guaranteed or Insured by the U.S. Government, its Agencies, or its Government-Sponsored
Agencies – The instructions for Schedule RC-O, Memorandum items 6, 11, and 16 refer to amounts
recoverable from, or guaranteed or insured by, the U.S. government, its agencies, or its governmentsponsored agencies under guarantee or insurance provisions. Examples include guarantees or
insurance (or reinsurance) provided by the Department of Veterans Affairs, the Federal Housing
Administration, the Small Business Administration (SBA), the Department of Agriculture Rural
Development Loan Program, and the Department of Education for individual loans as well as coverage
provided by the FDIC under loss-sharing agreements. For loan securitizations and securities, examples
include those guaranteed by the Government National Mortgage Association, the Federal National
Mortgage Association (Fannie Mae), and the Federal Home Loan Mortgage Corporation (Freddie Mac) as
well as SBA Guaranteed Loan Pool Certificates and securities covered by FDIC loss-sharing agreements.
However, if an institution holds securities backed by mortgages it has transferred to Fannie Mae or
Freddie Mac with recourse or other transferor-provided credit enhancements, these securities should not
be considered guaranteed to the extent of the institution’s maximum contractual credit exposure arising
from the credit enhancements.

Amounts Guaranteed or Insured by the U.S. Government – The instructions for Schedule RC-O,
Memorandum items 7 through 10, 13, and 18 refer to the maximum amounts recoverable from the U.S.
Government. Amounts recoverable from the U.S. government do not include amounts recoverable from
government-sponsored agencies (also known as government-sponsored enterprises) including the
Federal National Mortgage Association (Fannie Mae), the Federal Home Loan Mortgage Corporation
(Freddie Mac), the Federal Home Loan Banks, and the Farm Credit System.

1 An

institution that has a community bank leverage ratio (CBLR) framework election in effect as of the quarter-end
report date, as reported in Schedule RC-R, Part I, item 31.a (and further described in the General Instructions for
Schedule RC-R, Part I), shall be classified as a small institution, even if that institution otherwise would be classified
as a large institution.

FFIEC 031 and 041

RC-O-20
(36-2021)

RC-O - ASSESSMENTS

FFIEC 031 and 041

RC-O - ASSESSMENTS

Memoranda
General Instructions for Schedule RC-O, Memorandum items 65 through 18 (cont.)
NOTE: Because certain information on coverage under FDIC loss-sharing agreements is reported
elsewhere in the Consolidated Reports of Condition and Income, the treatment of FDIC loss-sharing
agreements varies in Schedule RC-O, Memorandum items 6 through 9, 10.b, 11, 13, 16, and 18.
Higher-risk Securitizations – For purposes of Schedule RC-O, Memorandum items 7.b, 8.b, and 9.b,
higher-risk securitizations are securitizations where more than 50 percent of the assets backing the
securitization meet the criteria for “nontraditional 1-4 family residential mortgage loans,” “higher-risk
consumer loans,” or “higher-risk commercial and industrial loans and securities” as those terms are
defined in the instructions for Schedule RC-O, Memorandum items 7.a, 8.a, and 9.a, and in Appendix C
to Subpart A to Part 327 of the FDIC’s regulations.
Caption and Instructions

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Item No.

NOTE: Memorandum items 65 through 12 are to be completed on a fully consolidated basis by “large
institutions” and “highly complex institutions.”
NOTE: Schedule RC-O, Memorandum item 5, is to be completed only by large and highly complex
institutions that have adopted ASU 2016-13, which addresses the accounting for credit losses, and
report having a current expected credit losses (CECL) transition election in effect as of the current report
date in Schedule RC-R, Part I, item 2.a.
5

Applicable portion of the CECL transitional amount or modified CECL transitional
amount that has been added to retained earnings for regulatory capital purposes as of
the current report date and is attributable to loans and leases held for investment.

For an institution that has a 3-year CECL transition election in effect as of the current report
date (i.e., an institution that entered a “1” in Schedule RC-R, Part I, item 2.a), report the
applicable portion of the CECL transitional amount that has been added to retained earnings
for regulatory capital purposes as of the current report date (as reported in Schedule RC-R,
Part I, item 2) and is attributable to loans and leases held for investment (hereafter, loans and
leases).
• As defined in section 301 of the regulatory capital rule,1 the term “CECL transitional
amount” means the difference, net of any deferred tax assets (DTAs), in the amount of an
institution’s retained earnings as of the beginning of the fiscal year in which the institution
adopts the current expected credit lossesCECL methodology (CECL) from the amount of
the institution’s retained earnings as of the closing of the fiscal year-end immediately prior
to the institution’s adoption of CECL. Thus, the CECL transitional amount reflects the
effect on retained earnings, net of any DTAs, of establishing allowances for credit losses
in accordance with CECL on loans and leases, held-to-maturity debt securities, other
financial assets measured at amortized cost, and off-balance sheet credit exposures as
of the beginning of the fiscal year of adoption (e.g., January 1, 2020).
• The CECL transitional amount attributable to loans and leases is the CECL transitional
amount that remains after excluding the adoption date effect on retained earnings, net of
any DTAs, of establishing allowances for credit losses in accordance with CECL on heldto-maturity debt securities, other financial assets measured at amortized cost, and offbalance sheet credit exposures.
For a 3-year CECL electing institution, the applicable portion of the CECL transitional amount
attributable to loans and leases is 75 percent of the institution’s CECL transitional amount

1 See

12 CFR 3.301 (OCC); 12 CFR 217.301 (Board); and 12 CFR 324.301 (FDIC).

FFIEC 031 and 041

RC-O-20a
(36-2021)

RC-O - ASSESSMENTS

FFIEC 031 and 041

RC-O - ASSESSMENTS

Memoranda
Item No.

Caption and Instructions

5
(cont.)

attributable to loans and leases during the first year of the transition period (as defined for the
3-year CECL transition provision in section 301 of the regulatory capital rule); 50 percent of
its CECL transitional amount attributable to loans and leases during the second year of the
transition period; and 25 percent of its CECL transitional amount attributable to loans and
leases during the third year of the transition period.

AF
T

For an institution that has a 5-year 2020 CECL transition election in effect as of the current
report date (i.e., an institution that entered a “2” in Schedule RC-R, Part I, item 2.a), report
the applicable portion of the modified CECL transitional amount that has been added to
retained earnings for regulatory capital purposes reported as of the current report date (as
reported in Schedule RC-R, Part I, item 2) and is attributable to loans and leases.
• As defined in section 2 of the regulatory capital rule,1 the term “adjusted allowances for
credit losses” (AACL) means, with respect to an institution that has adopted CECL,
valuation allowances that have been established through a charge against earnings or
retained earnings for expected credit losses on financial assets measured at amortized
cost and a lessor's net investment in leases that have been established to reduce the
amortized cost basis of the assets to amounts expected to be collected as determined in
accordance with U.S. generally accepted accounting principles (GAAP). The AACL
includes allowances for expected credit losses on off-balance sheet credit exposures not
accounted for as insurance as determined in accordance with GAAP. The AACL
excludes “allocated transfer risk reserves” and allowances created that reflect credit
losses on purchased credit deteriorated assets and available-for-sale debt securities.
• Consistent with the definition of the term “modified CECL transitional amount” in section
301 of the regulatory capital rule, the modified CECL transitional amount attributable to
loans and leases is the CECL transitional amount attributable to loans and leases, as
described above, plus:
o During the first two years of the transition period, the difference between the AACL
on loans and leases as reported in the Call Report as of the current report date and
the AACL on loans and leases as of the beginning of the fiscal year in which the
institution adopts CECL, multiplied by 0.25; and
o During the last three years of the transition period, the difference between the AACL
on loans and leases as reported in the Call Report at the end of the second year of
the transition period and the AACL on loans and leases as of the beginning of the
fiscal year in which the institution adopts CECL multiplied by 0.25.

For a 5-year CECL electing institution, the applicable portion of the modified CECL
transitional amount attributable to loans and leases is 100 percent of the institution’s modified
CECL transitional amount attributable to loans and leases during the first and second years
of the transition period (as defined for the 5-year 2020 CECL transition provision in section
301 of the regulatory capital rule); 75 percent of its modified CECL transitional amount
attributable to loans and leases during the third year of the transition period; 50 percent of its
modified CECL transitional amount attributable to loans and leases during the fourth year of
the transition period; and 25 percent of its modified CECL transitional amount attributable to
loans and leases during the fifth year of the transition period.
For further information on the CECL transition provisions, see the “3-Year and 5-Year 2020
CECL Transition Provisions” section of the General Instructions for Schedule RC-R, Part I,
and section 301 of the regulatory capital rule.

1 See

12 CFR 3.2 (OCC); 12 CFR 217.2 (Board); and 12 CFR 324.2 (FDIC).

FFIEC 031 and 041

RC-O-20b
(36-2021)

RC-O - ASSESSMENTS

FFIEC 031 and 041

RC-O - ASSESSMENTS

Memoranda
Caption and Instructions

5
(cont).

To illustrate how an institution should calculate the applicable portion of the CECL transitional amount
or modified CECL transitional amount that has been added to retained earnings for regulatory capital
purposes as of the current report date and is attributable to loans and leases held for investment,
consider the examples after the instructions to Schedule RC-O, Memorandum item 18.j.

AF
T

Item No.

FFIEC 031 and 041

RC-O-21
(36-2021)

RC-O - ASSESSMENTS

FFIEC 031 and 041

RC-O - ASSESSMENTS

CECL Double-Count Examples for Schedule RC-O, Memorandum Item 5
Examples for the 3-year and the 5-year 2020 CECL Transition Provisions:
Assumptions for both examples:

•

•
•

•

An institution with a calendar year fiscal year has a CECL effective date of January 1, 2020, and a 21
percent income tax rate.
As of the closing of the fiscal year immediately prior to adopting CECL (i.e., December 31, 2019), the
institution’s Call Report reflected the following amounts:
o Retained earnings: $20 million;
o ALLL: $1,020,000; and
o Allowance for credit losses on off-balance-sheet credit exposures: $80,000.
As of the beginning of the fiscal year in which the institution adopted CECL (i.e., January 1, 2020), the
institution has $1.4 million in allowances for credit losses (ACL), all of which qualify as the adjusted
allowances for credit losses (AACL), as defined in the regulatory capital rules.
The institution’s $1.4 million in ACL and AACL as of the beginning of the fiscal year in which it
adopted CECL is comprised of the following:
o $1.25 million in the ACL on loans and leases;
o $100,000 in the ACL for off-balance-sheet credit exposures; and
o $50,000 in the ACL for held-to-maturity debt securities.
The institution has no ACL for other financial assets measured at amortized cost as of the beginning
of the fiscal year in which it adopted CECL.
The institution recognizes the effect of the adoption of CECL as of January 1, 2020, by recording an
increase in its ACL of $300,000 (credit), with an offsetting increase in temporary difference deferred
tax assets (DTAs) of $63,000 (debit) and a reduction in beginning retained earnings of $237,000
(debit). This $237,000 reduction in beginning retained earnings is the CECL transitional amount, as
defined in the regulatory capital rules.
The dollar amounts in the examples have not been rounded for purposes of reporting in
Schedule RC-O, Memorandum item 5.

AF
T

•

The institution has elected to apply the 3-year CECL transition provision for regulatory capital
purposes. The institution begins to report the applicable portion of its CECL transitional amount that
has been added to retained earnings for regulatory capital purposes and is attributable to loans and
leases in Schedule RC-O, Memorandum item 5, in year 2 of the 3-year transition period.
The 3-year CECL electing institution’s CECL transitional amount attributable to loans and leases is
calculated by excluding from the CECL transitional amount of $237,000, the amount that remains
after excluding the adoption date effect on retained earnings, net of any DTAs, of establishing ACLs
in accordance with CECL on credit exposures other than loans and leases.

•

Example for the 3-year CECL Transition Provision:

CECL transitional amount
Less change in retained earnings due to:
ACL for off-balance-sheet credit exposures upon adopting CECL compared to
immediately prior to adopting CECL ($80,000 - $100,000)
Initial establishment of ACL for held-to-maturity debt securities upon adopting CECL
Offsetting increase in retained earnings for deferred tax effect of ACL increases
($20,000 + $50,000)*(0.21)
Total amount excluded from CECL transitional amount
CECL transitional amount attributable to loans and leases and reported on Schedule
RC-O, Memorandum item 5

FFIEC 031 and 041

RC-O-36
(6-21)

$237,000
-$20,000
-$50,000
+$14,700
-$55,300
$181,700

RC-O - ASSESSMENTS

CECL Double-Count Examples for Schedule RC-O, Memorandum Item 5 (cont.)
•

•

For each of the quarterly reporting periods in year 2 of the transition period (i.e., 2021), the amount by
which the 3-year CECL electing institution increases retained earnings for regulatory capital purposes
that is attributable to loans and leases is $90,850 ($181,700 x 50 percent), which is the amount the
institution would report in Schedule RC-O, Memorandum item 5, in year 2 of the transition period.
For each of the quarterly reporting periods in year 3 of the transition period (i.e., 2022), the amount by
which the 3-year CECL electing institution increases retained earnings for regulatory capital purposes
that is attributable to loans and leases is $45,425 ($181,700 x 25 percent), which is the amount the
institution would report in Schedule RC-O, Memorandum item 5, in year 3, the final year of the
transition period.

Example for the 5-year 2020 CECL Transition Provision:

•

AF
T

•

The institution has elected to apply the 5-year 2020 CECL transition provision for regulatory capital
purposes. The institution begins to report the applicable portion of its modified CECL transitional
amount that has been added to retained earnings for regulatory capital purposes and is attributable to
loans and leases in Schedule RC-O, Memorandum item 5, in the sixth quarter of the 5-year transition
period.
The 5-year 2020 electing institution’s AACL for loans and leases as of the beginning of the fiscal year
in which it adopted CECL (i.e., January 1, 2020) is $1.25 million and its CECL transitional amount
attributable to loans and leases is $181,700, which are the same as above under the application of
the 3-year CECL transition provision.
As of the end of the sixth quarter of the 5-year transition period (i.e., June 30, 2021), the 5-year 2020
CECL electing institution’s ACL for loans and leases is $1.55 million, all of which qualifies as the
AACL for loans and leases.
o The institution’s modified CECL transitional amount attributable to loans and leases as of
June 30, 2021, is $256,700, which is its CECL transitional amount attributable to loans and
leases of $181,700 plus 25 percent of the $300,000 difference between the institution’s
$1.55 million AACL for loans and leases as of June 30, 2021, and its $1.25 million AACL for loans
and leases as of January 1, 2020.
o During the first two years of the 5-year 2020 CECL electing institution’s transition period, the
applicable portion of the institution’s modified CECL transitional amount that has been added to
retained earnings for regulatory capital purposes and is attributable to loans and leases is
100 percent of its modified CECL transitional amount attributable to loans and leases.
Accordingly, the institution would report $256,700 in Schedule RC-O, Memorandum item 5, as of
the June 30, 2021, report date.
As of the end of the seventh quarter of the 5-year transition period (i.e., September 30, 2021), the
5-year 2020 CECL electing institution’s ACL for loans and leases is $1.59 million, all of which
qualifies as the AACL for loans and leases.
o The institution’s modified CECL transitional amount attributable to loans and leases as of
September 30, 2021, is $266,700, which is its CECL transitional amount attributable to loans
and leases of $181,700 plus 25 percent of the $340,000 difference between the institution’s
$1.59 million AACL for loans and leases as of September 30, 2021, and its $1.25 million AACL
for loans and leases as of January 1, 2020.
o During the first two years of the 5-year 2020 CECL electing institution’s transition period, the
applicable portion of the institution’s modified CECL transitional amount that has been added to
retained earnings for regulatory capital purposes and is attributable to loans and leases is
100 percent of its modified CECL transitional amount attributable to loans and leases.
Accordingly, the institution would report $266,700 in Schedule RC-O, Memorandum item 5, as of
the September 30, 2021, report date.
As of the end of the second year of the 5-year transition period (i.e., December 31, 2021), the 5-year
2020 CECL electing institution’s ACL for loans and leases is $1.5 million, all of which qualifies as the
AACL for loans and leases.

•

FFIEC 031 and 041

RC-O-37
(6-21)

RC-O - ASSESSMENTS

CECL Double-Count Examples for Schedule RC-O, Memorandum Item 5 (cont.)
The institution’s modified CECL transitional amount attributable to loans and leases as of
December 31, 2021, is $244,200, which is its CECL transitional amount attributable to loans
and leases of $181,700 plus 25 percent of the $250,000 difference between the institution’s
$1.5 million AACL for loans and leases as of December 31, 2021, and its $1.25 million AACL for
loans and leases as of January 1, 2020.
o During the first two years of the 5-year 2020 CECL electing institution’s transition period, the
applicable portion of the institution’s modified CECL transitional amount that has been added to
retained earnings for regulatory capital purposes and is attributable to loans and leases is
100 percent of its modified CECL transitional amount attributable to loans and leases.
Accordingly, the institution would report $244,200 in Schedule RC-O, Memorandum item 5, as of
the December 31, 2021, report date.
During the last three years of the 5-year 2020 CECL electing institution’s transition period, its
modified CECL transitional amount attributable to loans and leases is fixed at $244,200, which is its
CECL transitional amount attributable to loans and leases of $181,700 plus 25 percent of the
$250,000 difference between the institution’s $1.5 million AACL for loans and leases as of the end of
the second year of the transition period (i.e., December 31, 2021) and its $1.25 million AACL for
loans and leases as of January 1, 2020.
o During the third year of the transition period, i.e., 2022, the applicable portion of the institution’s
modified CECL transitional amount attributable to loans and leases is 75 percent of its modified
CECL transitional amount attributable to loans and leases of $244,200. Accordingly, the
institution would report $183,150 ($244,200 x 75 percent) in Schedule RC-O, Memorandum
item 5, for the four quarterly report dates in 2022.
o During the fourth year of the transition period, i.e., 2023, the applicable portion of the institution’s
modified CECL transitional amount attributable to loans and leases is 50 percent of its modified
CECL transitional amount attributable to loans and leases of $244,200. Accordingly, the
institution would report $122,100 ($244,200 x 50 percent) in Schedule RC-O, Memorandum
item 5, for the four quarterly report dates in 2023.
o During the fifth year of the transition period, i.e., 2024, the applicable portion of the institution’s
modified CECL transitional amount attributable to loans and leases is 25 percent of its modified
CECL transitional amount attributable to loans and leases of $244,200. Accordingly, the
institution would report $61,050 ($244,200 x 25 percent) in Schedule RC-O, Memorandum item 5,
for the four quarterly report dates in 2024.
o

AF
T

•

FFIEC 031 and 041

RC-O-38
(6-21)

RC-O - ASSESSMENTS

AF
T

The revisions on pages 18 to 21 are effective as of the September 30, 2021,
report date, subject to final approval by the OMB.

FFIEC 041
Page 33 of 87
RC-17

Schedule RC-E—Deposit Liabilities
Nontransaction
Accounts

Transaction Accounts
(Column A)
Total Transaction
Accounts (Including
Total Demand
Deposits)

Dollar Amounts in Thousands

Memoranda

Amount

RCON

Amount

(Column C)
Total
Nontransaction
Accounts
(Including MMDAs)
RCON

Amount

B549

B550

2202

2520

2203

2530

1.
2.
3.

B551
2213

B552
2236

4.
5.

2216

2377

2385

AF
T

Deposits of:
1. Individuals, partnerships, and corporations ......
2. U.S. Government ......................................
3. States and political subdivisions in the U.S. ....
4. Commercial banks and other depository
institutions in the U.S. .................................
5. Banks in foreign countries ...........................
6. Foreign governments and official institutions
(including foreign central banks) ....................
7. Total (sum of items 1 through 6) (sum of
columns A and C must equal Schedule RC,
item 13.a) .................................................

RCON

(Column B)
Memo: Total
Demand Deposits1
(Included in
Column A)

2215

2210

Dollar Amounts in Thousands
1. Selected components of total deposits (i.e., sum of item 7, columns A and C):
a. Total Individual Retirement Accounts (IRAs) and Keogh Plan accounts ..............................
b. Total brokered deposits ...........................................................................................
c. Brokered deposits of $250,000 or less (fully insured brokered deposits)2 ............................
d. Maturity data for brokered deposits:
(1) Brokered deposits of $250,000 or less with a remaining maturity of one year or less
(included in Memorandum item 1.c above) ...............................................................
(2) Not applicable
(3) Brokered deposits of more than $250,000 with a remaining maturity of one year or
less (included in Memorandum item 1.b above) ........................................................
e. Preferred deposits (uninsured deposits of states and political subdivisions in the U.S.
reported in item 3 above which are secured or collateralized as required under state law)
(to be completed for the December report only) .............................................................
f. Estimated amount of deposits obtained through the use of deposit listing services
that are not brokered deposits ...................................................................................
g. Total reciprocal deposits ..........................................................................................

RCON

Amount

6835
2365
HK05

M.1.a.
M.1.b.
M.1.c.

HK06

M.1.d.(1)

K220

M.1.d.(3)

5590

M.1.e.

K223
JH83

M.1. f.
M.1.g.

Insert A

1. Includes interest-bearing and noninterest-bearing demand deposits.
2. The dollar amount used as the basis for reporting in Memorandum item 1.c reflects the deposit insurance limits in effect on the
report date.

09/2021

INSERT A

Dollar Amounts in Thousands RCON
XXXX
XXXX
XXXX
XXXX
XXXX

M.1.h.(1)
M.1.h.(2)
M.1.h.(3)
M.1.h.(4)
M.1.i.

AF
T

h. Sweep deposits:
(1) Fully insured, affiliate sweep deposits………………………………………………………..
(2) Not fully insured, affiliate sweep deposits….………………………………………………
(3) Fully insured, non-affiliate sweep deposits…………………………………………………
(4) Not fully insured, non-affiliate sweep deposits…………………………………………..
i. Total sweep deposits that are not brokered deposits………………………………………

Amount

09/2021

.
FFIEC 031 and 041

RC-E - DEPOSITS

Memoranda
Item No.

Caption and Instructions

NOTE: On the FFIEC 031 report form, Memorandum items 1.h.(1)(a), 1.h.(2)(a), 1.h.(3)(a), and
1.h.(4)(a) are to be completed by institutions with $100 billion or more in total assets. Memorandum
items 1.h.(1)(a), 1.h.(2)(a), 1.h.(3)(a), and 1.h.(4)(a) are not applicable to banks filing the FFIEC 041
report form.
1.h

Sweep deposits. Report in the appropriate subitem the indicated sweep deposit data (as
defined in the Glossary entry for “sweep deposits”).
Fully insured, affiliate sweep deposits. Report the amount of affiliate sweep deposits that
are fully insured.

1.h.(1)(a)

Fully insured, affiliate, retail sweep deposits. Report the amount of affiliate, retail sweep
deposits that are fully insured included in Memorandum item 1.h.(1) above.

1.h.(2)

Not fully insured, affiliate sweep deposits. Report the amount of affiliate sweep deposits
for which less than the entire amount of the deposits is covered by deposit insurance.

1.h.(2)(a)

Not fully insured, affiliate, retail sweep deposits. Report the amount of affiliate, retail
sweep deposits for which less than the entire amount of the deposits is covered by deposit
insurance included in Memorandum item 1.h.(2) above.

1.h.(3)

Fully insured, non-affiliate sweep deposits. Report the amount of non-affiliate sweep
deposits that are fully insured.

1.h.(3)(a)

Fully insured, non-affiliate, retail sweep deposits. Report the amount of non-affiliate,
retail sweep deposits that are fully insured included in Memorandum item 1.h.(3) above.

1.h.(4)

Not fully insured, non-affiliate sweep deposits. Report the amount of non-affiliate sweep
deposits for which less than the entire amount of the deposits is covered by deposit
insurance.

AF
T

1.h.(1)

1.h.(4)(a)

Not fully insured, non-affiliate, retail sweep deposits. Report the amount of non-affiliate,
retail sweep deposits for which less than the entire amount of the deposits is covered by
deposit insurance included in Memorandum item 1.h.(4).

1.i

Total sweep deposits that are not brokered deposits. Report the total amount of sweep
deposits that are excluded from being reported as brokered deposits.

FFIEC 031 and 041

RC-E-10d
(3-19 9-21)

RC-E - DEPOSITS

FFIEC 031 and 041

GLOSSARY

Sweep Deposits: “Sweep deposit” means a deposit held at the reporting institution by a customer
or counterparty through a contractual feature that automatically transfers to the reporting
institution from another regulated financial company at the close of each business day amounts
under the agreement governing the account from which the amount is being transferred. (Note:
This definition of a “sweep deposit” is distinctly separate from the existing “retail sweep
arrangements” and “retail sweep programs” definitions in the “Reporting of Retail Sweep
Arrangements Affecting Transaction and Nontransaction Accounts” section of the Glossary
entry for “Deposits.”)

AF
T

“Affiliate sweep deposit” means a sweep deposit that is deposited in accordance with a contract
between a customer or counterparty and the reporting institution, a controlled subsidiary of the
reporting institution, or a company that is a controlled subsidiary of the same top-tier company
of which the reporting institution is a controlled subsidiary.
“Non-affiliate sweep deposit” means a sweep deposit that is deposited in accordance with a
contract between a customer or counterparty and an entity that is not affiliated with the reporting
institution.
“Affiliate retail sweep deposit” means a sweep deposit that is deposited in accordance with a
contract between a “retail customer or counterparty” and the reporting institution, a controlled
subsidiary of the reporting institution, or a company that is a controlled subsidiary of the same
top-tier company of which the reporting institution is a controlled subsidiary.
“Non-affiliate retail sweep deposit” means a sweep deposit that is deposited in accordance with
a contract between a “retail customer or counterparty” and an entity that is not affiliated with the
reporting institution.
“Retail customer or counterparty” means a customer or counterparty that is:

(1) An individual;
(2) A business customer, but solely if and to the extent that:
(i) The reporting institution manages its transactions with the business customer, including
deposits, unsecured funding, and credit facility and liquidity facility transactions, in the
same way it manages its transactions with individuals;
(ii) Transactions with the business customer have liquidity risk characteristics that are
similar to comparable transactions with individuals; and
(iii) The total aggregate funding raised from the business customer is less than $1.5 million;
or
(3) A living or testamentary trust that:
(i) Is solely for the benefit of natural persons;
(ii) Does not have a corporate trustee; and
(iii) Terminates within 21 years and 10 months after the death of grantors or beneficiaries of
the trust living on the effective date of the trust or within 25 years, if applicable under
state law.

FFIEC 031 and 041

A-118
(9-20 21)

GLOSSARY

AF
T

The clarifications on pages 23 to 30 will be included in the June 30, 2021 Instruction Book updates.

FFIEC 031 and 041

RC-E - DEPOSITS

Memoranda
Caption and Instructions

1.e
(cont.)

not be covered by federal deposit insurance. Under state law in such states, the value of the
securities a bank must pledge to the state is calculated annually, but represents only a
percentage of the uninsured portion of its public deposits. Institutions participating in the
state program may potentially be required to share in any loss to public depositors incurred in
the failure of another participating institution. As long as the value of the securities pledged
to the state exceeds the calculated requirement, all of the bank's uninsured public deposits
are protected from loss under the operation of the state program if the bank fails and,
therefore, all of the uninsured public deposits are considered "preferred deposits." For
example, a bank participating in a state public deposits program has $1,600,000 in public
deposits under the program from four political subdivisions and $700,000 of this amount is
uninsured, given the currently applicable $250,000 deposit insurance limit. The bank's most
recent calculation indicates that it must pledge securities with a value of at least $77,000 to
the state in order to participate in the state program. The bank has pledged securities with an
actual value of $80,000. The bank should report the $700,000 in uninsured public deposits
as "preferred deposits."

1.f

Estimated amount of deposits obtained through the use of deposit listing services that
are not brokered deposits. Report in this Memorandum item the estimated amount of all
nonbrokered deposits obtained through the use of deposit listing services included in total
deposits (in domestic offices) (Schedule RC-E, sum of item 7, columns A and C), regardless
of size or type of deposit instrument.

AF
T

Item No.

The objective of this Memorandum item is not to capture all deposits obtained through the
Internet, such as deposits that a bank receives because a person or entity has seen the rates
the bank has posted on its own Web site or on a rate-advertising Web site that has picked up
and posted the bank’s rates on its site without the bank’s authorization. Rather, the objective
of this Memorandum item is to collect the estimated amount of deposits obtained as a result
of action taken by the bank to have its deposit rates listed by a listing service, and the listing
service is compensated for this listing either by the bank whose rates are being listed or by
the persons or entities who view the listed rates. A bank should establish a reasonable and
supportable estimation process for identifying listing service deposits that meet these
reporting parameters and apply this process consistently over time. However, for those
nonbrokered deposits acquired through the use of a deposit listing service that offers deposit
tracking, the actual amount of listing service deposits, rather than an estimate, should be
reported.
When a nonbrokered time deposit obtained through the use of a deposit listing service is
renewed or rolled over at maturity, the time deposit should continue to be reported in this item
as a listing service deposit if the reporting institution continues to have its time deposit rates
listed by a listing service and the listing service is compensated for this listing as described
above. In contrast, if the reporting institution no longer has its time deposit rates listed by a
listing service when a nonbrokered listing service time deposit matures and is renewed or
rolled over by the depositor, the time deposit would no longer need to be reported as a listing
service deposit after the renewal or rollover. The reporting institution should continue to
report nonbrokered listing service deposits other than time deposits in this item as long as
the reporting institution continues to have its deposit rates for the same type of deposit
(e.g., NOW account, money market deposit account) listed by a listing service and the listing
service is compensated for this listing as described above.
If the reporting institution has merged with or acquired another institution that had obtained
nonbrokered deposits through the use of deposit listing services, these deposits would

FFIEC 031 and 041

RC-E-10b
(3-19)

RC-E - DEPOSITS

FFIEC 031 and 041

RC-E - DEPOSITS

Memoranda
Item No.

Caption and Instructions

1.f
(cont.)

continue to be regarded as listing service deposits after the merger or acquisition. In this
situation, the reporting institution should determine whether it must continue to report these
deposits as listing service deposits after the merger or acquisition in accordance with the
guidance in the preceding paragraph.

Exclude from this item all brokered deposits reported in Schedule RC-E, Memorandum
item 1.b.

AF
T

A deposit listing service is a company that compiles information about the interest rates
offered on deposits, such as certificates of deposit, by insured depository institutions. A
particular company could be a deposit listing service (compiling information about certificates
of deposits) as well as a deposit broker (facilitating the placement of certificates of deposits).
A deposit listing service is not a deposit broker if it does not meet all of the following four
criteria are metthe “deposit broker” definition and notably the criteria under 12 CFR
337.6(a)(5)(iii) for when a person is considered “engaged in the business of facilitating the
placement of deposits”:
(1) The listing service does not have legal authority, contractual or otherwise, to close the
account or move the third party’s funds to another insured depository institution; is not
involved in placing deposits. Any funds to be invested in deposit accounts are remitted
directly by the depositor to the insured depository institution and not, directly or indirectly,
by or through the listing service.

(2) The listing service is not involved in negotiating or setting rates, fees, terms, or conditions
for the deposit account; orperson or entity providing the listing service is compensated
solely by means of subscription fees (i.e., the fees paid by subscribers as payment for
their opportunity to see the rates gathered by the listing service) and/or listing fees (i.e.,
the fees paid by depository institutions as payment for their opportunity to list or “post”
their rates). The listing service does not require a depository institution to pay for other
services offered by the listing service or its affiliates as a condition precedent to being
listed.

(3) The fees paid by depository institutions are flat fees: they are not calculated on the basis
of the number or dollar amount of deposits accepted by the depository institution as a
result of the listing or “posting” of the depository institution’s rateslisting service is not
engaged in matchmaking activities as defined in 12 CFR 337.6(a)(5)(iii)(C)(1).
(4) In exchange for these fees, the listing service performs no services except (A) the
gathering and transmission of information concerning the availability of deposits; and/or
(B) the transmission of messages between depositors and depository institutions
(including purchase orders and trade confirmations). In publishing or displaying
information about depository institutions, the listing service must not attempt to steer
funds toward particular institutions (except that the listing service may rank institutions
according to interest rates and also may exclude institutions that do not pay the listing
fee). Similarly, in any communications with depositors or potential depositors, the listing
service must not attempt to steer funds toward particular institutions.

1
FFIEC 031 and 041

RC-E-10c
(3-196-21)

RC-E - DEPOSITS

FFIEC 031 and 041

GLOSSARY

Banks, U.S. and Foreign (cont.):
For purposes of the Consolidated Reports of Condition and Income, the term "U.S. branches and
agencies of foreign banks" covers:
(1) the U.S. branches and agencies of foreign banks;
(2) the U.S. branches and agencies of foreign official banking institutions, including central banks,
nationalized banks, and other banking institutions owned by foreign governments; and
(3) investment companies that are chartered under Article XII of the New York State banking law and
that are majority-owned by one or more foreign banks.
Banks in foreign countries –The institutional composition of "banks in foreign countries" includes:

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(1) the foreign-domiciled head offices and branches of:
(a) foreign commercial banks (including foreign-domiciled banking subsidiaries of U.S. banks and
Edge and Agreement corporations);
(b) foreign savings banks or discount houses;
(c) nationalized banks not functioning either as central banks, as foreign development banks, or
as banks of issue;
(d) other similar foreign institutions that accept short-term deposits; and
(2) the foreign-domiciled branches of U.S. banks.
See also "International Banking Facility (IBF)."

Banks in Foreign Countries: See "Banks, U.S. and Foreign."
Bill-of-Lading Draft: See "Commodity or Bill-of-Lading Draft."

Borrowings and Deposits in Foreign Offices: Borrowings in foreign offices include assets
rediscounted with central banks, certain participations sold in loans and securities, government
fundings of loans, borrowings from the Export-Import Bank, and rediscounted trade acceptances.
Federal funds sold and repurchase agreements in foreign offices should be reported in accordance
with the Glossary entries for "Federal Funds Transactions" and "Repurchase/Resale Agreements."
Liability accounts such as accruals and allocated capital shall not be reported as borrowings. Deposits
consist of such other short-term and long-term liabilities issued or undertaken as a means of obtaining
funds to be used in the banking business and include those liabilities generally characterized as
placements and takings, call money, and deposit substitutes.

Brokered Deposits: As defined in Section 337.6(a) of the FDIC’s regulations, the term “brokered
deposit” means “any deposit that is obtained, directly or indirectly, by or through any deposit broker.”
Brokered deposits include both those in which the entire beneficial interest in a given bank deposit
account or instrument is held by a single depositor and those in which the deposit broker sells
participations in a given bank deposit account or instrument to one or more investors.
The meaning of the term “brokered deposit” depends on the meaning of the term “deposit broker.”
The term “deposit broker” is defined broadly in Section 29(g) of the Federal Deposit Insurance Act
and Section 337.6(a)(5) of the FDIC’s regulations. Under Section 337.6(a)(5), the term “deposit broker”
and means:
(1) any person engaged in the business of placing deposits, or facilitating the placement of deposits,
of third parties with insured depository institutions, or the business of placing deposits with insured
depository institutions for the purpose of selling interests in those deposits to third parties, and
(2) an agent or trustee who establishes a deposit account to facilitate a business arrangement with an
insured depository institution to use the proceeds of the account to fund a prearranged loan
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GLOSSARY

FFIEC 031 and 041

- GLOSSARY

Brokered Deposits (cont.):
Any person engaged in the business of placing deposits of third parties with insured depository
institutions;
•

Any person engaged in the business of facilitating the placement of deposits of third parties with
insured depository institutions;

•

Any person engaged in the business of placing deposits with insured depository institutions for
the purpose of selling those deposits or interests in those deposits to third parties; and

•

An agent or trustee who establishes a deposit account to facilitate a business arrangement with
an insured depository institution to use the proceeds of the account to fund a prearranged loan.

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The FDIC’s regulations under Section 337.6(a)(5) further provide that a person is:

(1) “Engaged in the business of placing deposits” of third parties if that person receives third party
funds and deposits those funds at more than one insured depository institution; and
(2) “Engaged in the business of facilitating the placement of deposits” of third parties by, while
engaged in business, with respect to deposits placed at more than one insured depository
institution, engaging in one or more of the following activities:
• The person has legal authority, contractual or otherwise, to close the account or move
the third party’s funds to another insured depository institution;
• The person is involved in negotiating or setting rates, fees, terms, or conditions for the
deposit account; or
• The person engages in matchmaking activities, which occurs if the person proposes
deposit allocations at, or between, more than one bank based upon both the particular
deposit objectives of a specific depositor or depositor’s agent, and the particular deposit
objectives of specific banks, except in the case of deposits placed by a depositor’s agent
with a bank affiliated with the depositor’s agent. A proposed deposit allocation is based
on the particular objectives of:
i. A depositor or depositor’s agent when the person has access to specific financial
information of the depositor or depositor’s agent and the proposed deposit
allocation is based upon such information; and
ii. A bank when the person has access to the target deposit-balance objectives of
specific banks and the proposed deposit allocation is based upon such
information.

Brokered CDs that are placed by or through the assistance of third parties with insured depository
institutions are brokered deposits.

Section 337.6(a)(5)(v)(I)(4) defines brokered CD as a deposit placement arrangement in which a master
certificate of deposit is issued by an insured depository institution in the name of the third party that has
organized the funding of the certificate of deposit, or in the name of a custodian or a sub-custodian of
the third party, and the certificate is funded by individual investors through the third party, with each
individual investor receiving an ownership interest in the certificate of deposit, or a similar deposit
placement arrangement that the FDIC determines is arranged for a similar purpose.
Section 337.6(a)(5) of the FDIC’s regulations further also provides that the definition ofterm “deposit
broker” is subject to a list of exceptions. According to the list of exceptions, the following parties are
not treated as a deposit brokerdoes not include:

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FFIEC 031 and 041

GLOSSARY

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Brokered Deposits (cont.):
(1) an insured depository institution, with respect to funds placed with that depository institution;
(2) an employee of an insured depository institution, with respect to funds placed with the employing
depository institution;
(3) a trust department of an insured depository institution, if the trust or other fiduciary relationship in
question has not been established for the primary purpose of placing funds with insured
depository institutions;
(4) the trustee of a pension or other employee benefit plan, with respect to funds of the plan;
(5) a person acting as a plan administrator or an investment adviser in connection with a pension plan
or other employee benefit plan provided that that person is performing managerial functions with
respect to the plan;
(6) the trustee of a testamentary account;
(7) the trustee of an irrevocable trust (other than a trustee who establishes a deposit account to
facilitate a business arrangement with an insured depository institution to use the proceeds of the
account to fund a prearranged loan), as long as the trust in question has not been established for
the primary purpose of placing funds with insured depository institutions;
(8) a trustee or custodian of a pension or profit-sharing plan qualified under Section 401(d) or 403(a)
of the Internal Revenue Code of 1986;
(9) an agent or nominee whose primary purpose is not the placement of funds with depository
institutions;1 or
(10) an insured depository institution acting as an intermediary or agent of a U.S. government
department or agency for a government sponsored minority or women-owned depository
institution deposit program.
Section 337.6(a)(5) describes what it means to be “an agent or nominee whose primary purpose is not
the placement of funds with depository institutions.” More specifically, the primary purpose exception
applies when the primary purpose of the agent’s or nominee’s business relationship with its customers
is not the placement of funds with depository institutions.

The following business relationships are designated as meeting the primary purpose exception, subject
to applicable notice and reporting requirements set forth in Section 303.243(b)(3), with respect to a
particular business line:
Less than 25 percent of the total assets that the agent or nominee has under administration for its
customers is placed at depository institutions;

•

100 percent of depositors’ funds that the agent or nominee places, or assists in placing, at
depository institutions are placed into transactional accounts that do not pay any fees, interest, or
other remuneration to the depositor;

•

A property management firm places, or assists in placing, customer funds into deposit accounts
for the primary purpose of providing property management services;

•

The agent or nominee places, or assists in placing, customer funds into deposit accounts for the
primary purpose of providing cross-border clearing services to its customers;

•

The agent or nominee places, or assists in placing, customer funds into deposit accounts for the
primary purpose of providing mortgage servicing;

•

A title company places, or assists in placing, customer funds into deposit accounts for the primary
purpose of facilitating real estate transactions;

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GLOSSARY

FFIEC 031 and 041

GLOSSARY

Brokered Deposits (cont.):
• A qualified intermediary places, or assists in placing, customer funds into deposit accounts for the
primary purpose of facilitating exchanges of properties under section 1031 of the Internal
Revenue Code;
A broker dealer or futures commission merchant places, or assists in placing, customer funds into
deposit accounts in compliance with 17 CFR 240.15c3-3(e) or 17 CFR 1.20(a);

•

The agent or nominee places, or assists in placing, customer funds into deposit accounts for the
primary purpose of posting collateral for customers to secure credit-card loans;

•

The agent or nominee places, or assists in placing, customer funds into deposit accounts for the
primary purpose of paying for or reimbursing qualified medical expenses under section 223 of the
Internal Revenue Code;

•

The agent or nominee places, or assists in placing, customer funds into deposit accounts for the
primary purpose of investing in qualified tuition programs under section 529 of the Internal
Revenue Code;

•

The agent or nominee places, or assists in placing, customer funds into deposit accounts to
enable participation in the following tax-advantaged programs: individual retirement accounts
under section 408(a) of the Internal Revenue Code, Simple individual retirement accounts under
section 408(p) of the Internal Revenue Code, or Roth individual retirement accounts under
section 408A of the Internal Revenue Code;

•

A Federal, State, or local agency places, or assists in placing, customer funds into deposit
accounts to deliver funds to the beneficiaries of government programs; and

•

The agent or nominee places, or assists in placing, customer funds into deposit accounts
pursuant to such other relationships as the FDIC specifically identifies as a designated business
relationship that meets the primary purpose exception.

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•

An agent or nominee that does not rely on a designated business exception described in this section
must receive an approval under the application process in 12 CFR 303.243(b) in order to qualify for the
primary purpose exception to the deposit broker definition.

Insured depository institutions that receive deposits through an entity that has a pending application for
a primary purpose exception with the FDIC should report such deposits as brokered deposits if and
until the FDIC approves such application.
Notwithstanding these ten exceptions, the term “deposit broker” (as amended on September 23, 1994,
by the Riegle Community Development and Regulatory Improvement Act of 1994) includes any insured
depository institution that is not well capitalized (as defined in Section 38 of the Federal Deposit
Insurance Act, Prompt Corrective Action), and any employee of any such institution, which engages,
directly or indirectly, in the solicitation of deposits by offering rates of interest (with respect to such
deposits) which are significantly higher than the prevailing rates of interest on deposits offered by other
insured depository institutions in such depository institution's normal market area.2 Only those deposits
accepted, renewed, or rolled over on or after June 16, 1992, in connection with this form of deposit
solicitation are to be reported as brokered deposits.

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GLOSSARY

FFIEC 031 and 041

- GLOSSARY

Brokered Deposits (cont.):
For further information on the solicitation and acceptance of brokered deposits by less than well
capitalized insured depository institutions, see Section 337.6(b) and 337.7(g) 6(b) of the FDIC's
regulations
1

For purposes of applying this ninth exception from the definition of deposit broker, "primary purpose" does not mean
"primary activity," but should be construed as "primary intent." Whether the “primary purpose” exception applies
should be determined based on the meaning of this exception as stated in the FDIC’s regulations and as interpreted
in the FDIC’s guidance.

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In addition, deposit instruments of the reporting bank that are sold to brokers, dealers, or underwriters
(including both bank affiliates of the reporting bank and nonbank subsidiaries of the reporting bank's
parent holding company) who then reoffer and/or resell these deposit instruments to one or more
investors, regardless of the minimum denomination which the investor must purchase, are considered
brokered deposits.
In some cases, brokered deposits are issued in the name of the depositor whose funds have been
placed in a bank by a deposit broker. In other cases, a bank’s deposit account records may indicate
that the funds have been deposited in the name of a third party custodian for the benefit of others
(e.g., “XYZ Corporation as custodian for the benefit of others,” or “Custodial account of XYZ
Corporation”). Unless the custodian meets one of the specific exceptions from the “deposit broker”
definition in Section 29 of the Federal Deposit Insurance Act and Section 337.6(a) of the FDIC’s
regulations, these custodial accounts should be reported as brokered deposits in Schedule RC-E,
Deposit Liabilities.

A deposit listing service whose only function is to provide information on the availability and terms of
accounts is not facilitating the placement of deposits and therefore is not a deposit broker per se .
However, if a deposit broker uses a deposit listing service to identify an institution offering a high rate on
deposits and then places its customers’ funds at that institution, the deposits would be brokered deposits
and the institution should report them as such in Schedule RC-E. The designation of these deposits as
brokered deposits is based not on the broker’s use of the listing service but on the placement of the
deposits in the institution by the deposit broker.

Section 202 of the Economic Growth, Regulatory Relief, and Consumer Protection Act, enacted on
May 24, 2018, amends Section 29 of the Federal Deposit Insurance Act to except a capped amount of
reciprocal deposits from treatment as, and from being reported as, brokered deposits for qualifying
institutions. The FDIC has amended its regulations to conform to the treatment of reciprocal deposits
set forth in Section 202. As defined in Section 337.6(e)(2)(v) of the FDIC’s regulations, “reciprocal
deposits” means “deposits received by an agent institution through a deposit placement network with
the same maturity (if any) and in the same aggregate amount as covered deposits placed by the agent
institution in other network member banks.” As defined in Section 327.8(q) of the FDIC’s regulations,
“brokered reciprocal deposits” are “reciprocal deposits as defined in Section 337.6(e)(2)(v) of the
FDIC’s regulations that are not excepted from an institution’s brokered deposits pursuant to
Section 337.6(e)” of the FDIC’s regulations. Brokered reciprocal deposits should be reported as
(1) brokered deposits and included in Schedule RC-E, Memorandum item 1.b, and, if applicable,
Memorandum items 1.c and 1.d, and (2) brokered reciprocal deposits and included in Schedule RC-O,
item 9 and, if applicable, item 9.a. An institution should report its total reciprocal deposits,
including any reciprocal deposits that are reported as brokered deposits, in Schedule RC-E,
Memorandum item 1.g. For further information on reciprocal deposits and brokered reciprocal
deposits, see the instructions for Schedule RC-E, Memorandum items 1.b and 1.g, and the examples
after the instructions for Schedule RC-E, Memorandum item 7.

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GLOSSARY

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GLOSSARY

Brokered Deposits (cont.):
Reliance on Previous Staff Advisory Opinions and Interpretations

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As stated in the FDIC’s rule on Brokered Deposits and Interest Rate Restrictions, the effective date of
the rule was April 1, 2021. Full compliance of the rule was extended to January 1, 2022. The extended
compliance date allows entities to continue to rely upon existing staff advisory opinions or other
interpretations that predated the final rule in determining whether deposits placed by or through an
agent or nominee are brokered deposits. After January 1, 2022, entities may no longer rely on upon
staff advisory opinions or other interpretations that predated the final rule, and to the extent that such
entities instead opt to rely on a designated exception for which a notice is required, a notice must be
filed. After January 1, 2022, the advisory opinions and other publicly available interpretations will be
moved to inactive status.

Fully insured brokered deposits are brokered deposits (including brokered deposits that represent
retirement deposit accounts as defined in Schedule RC-O, Memorandum item 1) with balances of
$250,000 or less or with balances of more than $250,000 that have been participated out by the
deposit broker in shares of $250,000 or less. As more fully described in the instructions for
Schedule RC-E, (Part I on the FFIEC 031), Memorandum item 1.c, fully insured brokered deposits also
include (a) certain brokered certificates of deposit issued in $1,000 amounts under a master certificate
of deposit issued by a bank to a deposit broker in an amount that exceeds $250,000 and (b) certain
brokered transaction accounts and money market deposit accounts denominated in amounts of $0.01
and established and maintained by the deposit broker (or its agent) as agent, custodian, or other
fiduciary for the broker’s customers.

For additional information on brokered deposits, refer to the FDIC’s “Identifying, Accepting and Reporting
Brokered Deposits: Frequently Asked Questions” at
https://www.fdic.gov/news/news/financial/2016/fil16042b.pdf.

2 Any

deposit accepted, renewed, or rolled over by a well capitalized institution before September 23, 1994, in
connection with this form of deposit solicitation should continue to be reported as a brokered deposit as long as the
deposit remains outstanding under the terms in effect before September 23, 1994. Notwithstanding the amendment
to the "deposit broker" definition, all institutions that obtain deposits, directly or indirectly, by or through any other
deposit broker must report such funds as brokered deposits in the Consolidated Report of Condition.

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