FFIEC031_FFIEC041_FFIEC051_20211105_omb

Supporting Statement for the
Consolidated Reports of Condition and Income
(FFIEC 031, FFIEC 041, and FFIEC 051; OMB No. 7100-0036)
Summary
The Board of Governors of the Federal Reserve System (Board) requests approval from
the Office of Management and Budget (OMB) to extend for three years, with revision, the
Federal Financial Institutions Examination Council (FFIEC) Consolidated Reports of Condition
and Income (Call Reports) (FFIEC 031, FFIEC 041, and FFIEC 051; OMB No. 7100-0036).
With respect to the Board, these reports are required of state member banks and are filed on a
quarterly basis. The revisions to the Call Reports that are the subject of this request have been
approved by the FFIEC. The Federal Deposit Insurance Corporation (FDIC) and the Office of
the Comptroller of the Currency (OCC) (together with the Board, the agencies) have also
submitted similar requests for OMB review to request this information from banks under their
supervision.
The Board uses the information collected on the Call Reports to fulfill its statutory
obligation to supervise state member banks. State member banks are required to file detailed
schedules of assets, liabilities, and capital accounts in the form of a condition report and
summary statement as well as detailed schedules of operating income and expense, sources and
disposition of income, and changes in equity capital.
The agencies, under the auspices of the FFIEC, propose to revise the Call Report
effective for the December 31, 2021, report date to implement a new item related to the final rule
on the standardized approach for counterparty credit risk (SA-CCR).
The current estimated total annual burden for the Call Reports is 132,845 hours, and
would remain unchanged with the proposed revisions. The draft forms and instructions are
available on the FFIEC’s public website at https://www.ffiec.gov/ffiec_report_forms.htm.
Background and Justification
State banks that are members of the Federal Reserve System are required by section 9(6)
of the Federal Reserve Act (12 U.S.C. § 324) to file reports of condition with the Board. The
Board, acting in concert with the other federal banking supervisory agencies thro ugh the FFIEC
since 1979, requires state member banks to submit on the quarterly Call Reports such financial
data as are needed by the Federal Reserve System to supervise and regulate banks through
monitoring of their financial condition, ensuring the continued safety of the public’s monies and
the overall soundness of the nation’s financial structure, and discharging of the Federal Reserve’s
monetary policy responsibilities. The data, which generally is made publicly available by the
agencies, is used not only by the federal government, but also by state and local governments,
the banking industry, securities analysts, and the academic community.

Description of Information Collection
The Call Reports, which consist of the Reports of Condition and Income, collect basic
financial data from commercial banks in the form of a balance sheet, income statement, and
supporting schedules. The Report of Condition contains supporting schedules that provide detail
on assets, liabilities, and capital accounts. The Report of Income contains supporting schedules
that provide detail on income and expenses.
The Call Reports consist of three reporting forms that apply to different categories of
state member banks. Currently, banks that have foreign offices or that have total consolidated
assets of $100 billion or more must file the FFIEC 031, banks with domestic offices only and
total consolidated assets of less than $100 billion but at least $5 billion file the FFIEC 041, and
banks with domestic offices only and total assets less than $5 billion file the FFIEC 051.
The information collected by the Call Reports is not available from other sources.
Although there are other reports that collect information similar to certain items on the Call
Reports, the information they collect would be of limited value as a replacement for Call Report
data. For example, the Board collects various data in connection with its measurement of
monetary aggregates, bank credit, and flow of funds. 1 These reports provide the Board with
detailed information relating to balance sheet accounts such as balances due from depository
institutions, loans, and deposit liabilities. These collections of information, however, are
collected on a weekly basis usually prepared as of dates other than the last business day of each
quarter. Moreover, information on bank credit is obtained on a sample basis rather than from all
banks. Additionally, institutions below a certain size are exempt entirely from some of these
reporting requirements.
The Board also collects financial data from holding companies on a regular basis. 2 Such
data is generally required to be reported for the holding company on a consolidated basis,
including its banking and nonbanking subsidiaries, and on a parent-company-only basis. Data
collected from bank holding companies on a consolidated basis reflect aggregate amounts for all
entities within the organization, including banking and nonbanking subsidiaries, so that the
actual dollar amounts applicable to any banking subsidiary would not be determinable from the
holding company reporting information. Therefore, reports collected from bank holding
companies lack the data necessary to assess the financial condition of individual banks to
determine whether there had been any deterioration in their condition.
Banks are required to transmit their Call Report data electronically. Each bank must
maintain in its files for three years a signed and attested record of its completed report each
quarter.

1

Report of Transaction Accounts, Other Deposits, and Vault Cash (FR 2900; OMB No. 7100-0087) and Weekly
Report of Selected Assets and Liabilities of Domestically Chartered Commercial Banks and U.S. Branches and
Agencies of Foreign Banks (FR 2644; OMB No. 7100-0075).
2
The Board collects standardized financial statements through one or more of the Financial Statements for Holding
Companies (FR Y-9; OMB No. 7100-0128) series.

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Respondent Panel
The respondent panel for the Call Report consists of all state member banks. State
member banks that have foreign offices or that have total consolidated assets of $100 billion or
more must file the FFIEC 031, banks with domestic offices only and total consolidated assets of
less than $100 billion but at least $5 billion file the FFIEC 041, and banks with domestic offices
only and total assets less than $5 billion file the FFIEC 051.
Proposed Revisions
The agencies propose to add a new item to the Call Report forms related to early or
voluntary adoption of the standardized approach for counterparty credit risk methodology in the
agencies’ capital rules. 3
On January 24, 2020, the agencies issued a final rule 4 (SA-CCR final rule) that amended
the regulatory capital rule to implement a new approach for calculating the exposure amount for
derivative contracts for purposes of calculating the total risk-weighted assets (RWA), which is
called SA-CCR. The final rule also incorporates SA-CCR into the determination of the exposure
amount of derivatives for total leverage exposure under the supplementary leverage ratio, and the
cleared transaction framework under the capital rule.
Banking institutions that are not advanced approaches institutions5 may elect to use
SA-CCR to calculate standardized total RWA by notifying their appropriate federal supervisor. 6
Advanced approaches institutions are required to use SA-CCR to calculate standardized total RWA
starting on January 1, 2022. Advanced approaches institutions may adopt SA-CCR prior to
January 1, 2022, but must notify their appropriate federal supervisor of early adoption.7
The agencies propose to revise Schedule RC-R, Part I, Regulatory Capital Components
and Ratios, on all versions of the Call Report by adding a new line item 31.b, “Standardized
Approach for Counterparty Credit Risk opt-in election.” The agencies propose to add this new
item to identify which institutions have chosen to early adopt or voluntarily elect SA-CCR. This
information would allow for enhanced comparability of the reported derivative data and for
better supervision of the implementation of the framework at these institutions. Due to the
inherent complexity of adopting SA-CCR, identification of non-advanced approaches institutions
that choose to voluntarily adopt SA-CCR is particularly important for their supervision.
A non-advanced approaches institution that adopts SA-CCR would enter “1” for “Yes” in
line item 31.b. All other non-advanced approaches institutions would leave this item blank. If a
non-advanced approaches institution has elected to use SA-CCR, the institution may change its
election only with prior approval of its appropriate federal regulator. 8 An advanced approaches
3

12 CFR Part 3 (OCC); 12 CFR Part 217 (Board); 12 CFR Part 324 (FDIC).
85 FR 4362 (January 24, 2020).
5
See 12 CFR 217.2 (definition of Advanced approaches Board-regulated institution).
6
12 CFR 3.34(a)(1)(ii) (OCC); 12 CFR 217.34(a)(1)(ii) (Board); 12 CFR 324.34(a)(1)(ii) (FDIC).
7
12 CFR 3.300(g) (OCC); 12 CFR 217.300(h) (Board); 12 CFR 324.300(g) (FDIC).
8
12 CFR 3.34(a)(1)(ii) (OCC); 12 CFR 217.34(a)(1)(ii) (Board); 12 CFR 324.34(a)(1)(ii) (FDIC).
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institution that elects to early adopt SA-CCR prior to the January 1, 2022, mandatory compliance
date would enter “1” for “Yes” in line item 31.b. After January 1, 2022, an advanced approaches
institution would leave this item blank. This proposed reporting change would take effect starting
with the December 31, 2021, Call Report. This item would no longer be applicable to advanced
approaches institutions starting with the March 31, 2022, report date.
Time Schedule for Information Collection
The Call Reports are collected quarterly as of the end of the last calendar day of March,
June, September, and December, although certain information is collected on a semiannual or
annual basis, as described in the Call Report instructions. Less frequent collection of Call
Reports would reduce the Federal Reserve’s ability to identify on a timely basis those banks that
are experiencing adverse changes in their condition so that appropriate corrective measures can
be implemented to restore their safety and soundness. State member banks generally must submit
the Call Reports to the appropriate Federal Reserve Bank within 30 calendar days following the
as of date, except that banks with more than one foreign office must submit the call Reports
within 35 calendar days following the as of date.
Public Availability of Data
Aggregate data are published in the Federal Reserve Bulletin and the Annual Statistical
Digest. Additionally, data are used in the Uniform Bank Performance Report (UBPR) and the
Annual Report of the FFIEC. Individual respondent data, excluding confidential information, are
available to the public from the National Technical Information Service in Springfield, Virginia,
upon request approximately twelve weeks after the report date. Data are also available from the
FFIEC Central Data Repository Public Data Distribution (CDR PDD) website
(https://cdr.ffiec.gov/public/). Data for the current quarter are made available, shortly after a
bank’s submission, beginning the first calendar day after the report date. Updated or revised data
may replace data already posted at any time thereafter.
Legal Status
The Board is authorized to collect information on the Call Reports from state member
banks pursuant to section 9 of the Federal Reserve Act (12 U.S.C. § 324), which requires state
member banks to file reports of condition and of the payment of dividends with the Federal
Reserve. The obligation for state member banks to respond is mandatory.
Most of the information provided on the Call Reports is made public, although some
items are confidential. Confidential items include the FDIC deposit insurance assessment
information reported in response to item 2.g on schedule RI-E and the information regarding
other data for deposit insurance and FICO assessments reported in response to memorandum
items 6-9, 14-15, and 18 on schedule RC-O. Board staff have determined that it is possible to
reverse engineer an institution’s Capital, Asset Quality, Management, Earnings, Liquidity, and
Sensitivity (CAMELS) rating based on the data reported under the FDIC deposit insurance
assessment data items. If this information were publicly available, it would be possible to
determine a state member bank’s CAMELS rating. Therefore, this information may be kept

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confidential under exemption 8 of the Freedom of Information Act (FOIA) (5 U.S.C. §
552(b)(8)), which specifically exempts from disclosure information “contained in or related to
examination, operating, or condition reports prepared by, on behalf of, or for the use of an
agency responsible for the regulation or supervision of financial institutions.” This information is
also likely to constitute nonpublic commercial or financial information, which is both
customarily and actually treated as private by the respondent. Therefore, this information can
also be kept confidential under exemption 4 of FOIA, which exempts “trade secrets and
commercial or financial information obtained from a person and privileged or confidential”
(5 U.S.C. § 552(b)(4)).
Additionally, the information reported regarding Section 4013 loans outstanding in
response to Memorandum items 17.a and 17.b of Schedule RC-C, Part 1 and the information
reported regarding representation and warranty reserves for 1-4 family residential mortgage
loans sold in response to items 7.a and 7.b of Schedule RC-P is likely to constitute nonpublic
commercial or financial information, which is both customarily and actually treated as private by
the respondent and is, therefore, kept confidential under exemption 4 of FOIA.
Consultation Outside the Agency
The Board coordinated and consulted with the FDIC and OCC in developing these
revisions as part of the FFIEC approval process.
Public Comments
On July 22, 2021, the agencies, under the auspices of the FFIEC, published an initial
notice in the Federal Register (86 FR 38810) requesting public comment for 60 days on the
extension, with revision, of the Call Reports. The comment period for this notice expire d on
September 20, 2021. The agencies received one comment that was generally supportive of the
proposed new Call Report line item related to the SA-CCR final rule. The agencies did not
receive any other comments on the proposed change and intend to add the new item for SA-CCR
as proposed. On November 4, 2021, the agencies, under the auspices of the FFIEC, published a
final notice in the Federal Register (86 FR 60965) requesting public comment for 30 days on the
extension, with revision, of the Call Reports. The comment period for this notice expires on
December 6, 2021.
Estimate of Respondent Burden
As shown in the table below, the estimated total annual burden for the Call Reports is
132,845 hours, and would remain unchanged with the proposed revisions. The estimated average
hours per response for the quarterly filings of the Call Report is a weighted average of the three
versions of the Call Report (FFIEC 031, FFIEC 041, and FFIEC 051). Both the weighted average
Call Report burden estimate and the three separate versions of the Call Report vary by agency
because of differences in the composition of the institutions under each agency ’s supervision
(e.g., size distribution of institutions, types of activities in which they are engaged, and existence
of foreign offices). The agencies estimate that the recordkeeping burden is usual and customary,

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and would not incur any burden. These reporting requirements represent 1.7 percent of the
Board’s total paperwork burden.
FFIEC 031, FFIEC 041, and
FFIEC 051
Current

Estimated
number of
respondents9

Annual
frequency

728

4

Estimated
Estimated
average hours annual burden
per response
hours
45.62

132,845

The estimated total annual cost to the public for the Call Reports is $7,857,782.10
Sensitive Questions
This collection of information contains no questions of a sensitive nature, as defined by
OMB guidelines.
Estimate of Cost to the Federal Reserve System
The estimated cost to the Federal Reserve System for collecting and processing the
FFIEC 031, FFIEC 041, and FFIEC 051 is $1,871,500 per year.

9

Of these respondents, 466 are considered small entities as defined by the Small Business Administration (i.e.,
entities with less than $600 million in total assets), https://www.sba.gov/document/support--table-size-standards.
10
Total cost to the public was estimated using the following formula: percent of staff time, multiplied by annual
burden hours, multiplied by hourly rates (30% Office & Administrative Support at $20, 45% Financ ial Managers at
$73, 15% Lawyers at $72, and 10% Chief Executives at $95). Hourly rates for each occupational group are the
(rounded) mean hourly wages from the Bureau of Labor and Statistics (BLS), Occupational Employment and Wages
May 2020, published March 31, 2021, https://www.bls.gov/news.release/ocwage.t01.htm. Occupations are defined
using the BLS Standard Occupational Classification System, https://www.bls.gov/soc/.

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