FINAL FFIEC 051 Redlined Instructions 604 v3 5.22.2023

FFIEC 051
Draft Instructions for Call Report Revisions
Effective as of the September 30, 2023, Report Date
The following draft instructions, which are subject to change,
present the pages from the FFIEC 051 Call Report
instructions as they are proposed to be revised, subject to final
approval by the Office of Management and Budget. These
proposed revisions are described in the federal banking agencies'
initial Paperwork Reduction Act (PRA) Federal Register notice
published in the Federal Register on February 21, 2023 (see
FIL-7-2023, dated February 22, 2023). As discussed in the
agencies' final PRA Federal Register notice published in the
Federal Register on June XX, 2023, the agencies are proceeding
with the revisions to the FFIEC 051 Call Report, with certain
modifications.
In addition, certain clarifications are being made to the instructions
on Schedule RC-T, Fiduciary and Related Services, that are
included in the following pages.
The initial and final PRA Federal Register notice and draft redlined
instructions for these proposed revisions to the FFIEC 051 Call
Report are available on the FFIEC webpage for the FFIEC 051 Call
Report.

Draft as of May 18, 2023

Schedule
RI – Income Statement

Description
Memorandum item 12. Noncash income from negative amortization on closedend loans secured by 1–4 family RIAD Amount residential properties (included in
Schedule RI, item 1.a.(1)(a))

RC-C—Loans and Lease
Financing Receivables, Part I
RC-F – Other Assets
RC-M – Memoranda

Memorandum item 15.a.(1) through 15.c.(2). Reverse mortgages in domestic
offices
6.d. FDIC loss-sharing indemnification assets
18. Money Market Mutual Fund Liquidity Facility (MMLF):
a. Outstanding balance of assets purchased under the MMLF
b. Quarterly average amount of assets purchased under the MMLF and excluded
from “Total assets for the leverage ratio” reported in Schedule RC-R, Part I, item
30
11. Loans and leases reported in items 1 through 8 above
that are wholly or partially guaranteed by the U.S.
Government, excluding loans and leases covered by
loss-sharing agreements with the FDIC
12. Portion of covered loans and leases included in item 9 above that is protected
by FDIC loss-sharing agreements.

RC-N – Past Due and
Nonaccrual
Loans, Leases, and Other
Assets
RC-N – Past Due and
Nonaccrual
Loans, Leases, and Other
Assets
SU – Supplemental
Information
RC-T – Fiduciary and Related
Services

Pages
3

4-5
6
7

9

9

Note: Schedule SU, items 9.b and 9.c are redesignated as Schedule RC-N, item
12, columns B and C.
9. FDIC Loss-Sharing Agreements

10-11

Clarifications

12-16

FFIEC 051

RI - INCOME STATEMENT

Memoranda
Item No.

Caption and Instructions

NOTE: Memorandum item 12 is to be completed by banks that are required to complete Schedule RC-C,
Part I, Memorandum items 8.b and 8.c, and is to be completed annually as of the December 31 report
date.
12

Noncash income from negative amortization on closed-end loans secured by
1-4 family residential properties. Report the amount of noncash income from negative
amortization on closed-end loans secured by 1-4 family residential properties (i.e., interest
income accrued and uncollected that has been added to principal) included in interest and
fee income on loans secured by real estate (Schedule RI, item 1.a.(1)).
Negative amortization refers to a method in which a loan is structured so that the borrower’s
minimum monthly (or other periodic) payment is contractually permitted to be less than the
full amount of interest owed to the lender, with the unpaid interest added to the loan’s
principal balance. The contractual terms of the loan provide that if the borrower allows the
principal balance to rise to a pre-specified amount or maximum cap, the loan payments are
then recast to a fully amortizing schedule. Negative amortization features may be applied to
either adjustable rate mortgages or fixed rate mortgages, the latter commonly referred to as
graduated payment mortgages (GPMs).

12 and 13

Not applicable.

NOTE: Memorandum item 14 is to be completed only by institutions that have not adopted FASB
Accounting Standards Update No. 2016-13 (ASU 2016-13), which governs the accounting for credit
losses. Institutions that have adopted ASU 2016-13 should leave Memorandum item 14 blank.
14

Other-than-temporary impairment losses on held-to-maturity and available-for-sale
debt securities recognized in earnings. Report the amount of other-than-temporary
impairment losses on held-to-maturity and available-for-sale debt securities that have been
recognized in earnings during the calendar year to date as discussed in the following
paragraphs. This amount is included in the realized gains (losses) on held-to-maturity and
available-for-sale securities reported in Schedule RI, items 6.a and 6.b, respectively.
When the fair value of an individual held-to-maturity or available-for-sale debt security is less
than its amortized cost basis, the security is impaired and the impairment is either temporary
or other-than-temporary. To determine whether the impairment is other-than-temporary, a
bank must apply the relevant guidance in ASC Topic 320, Investments-Debt Securities
(formerly FASB Statement No. 115, “Accounting for Certain Investments in Debt and Equity
Securities,” as amended by FASB Staff Position (FSP) FAS 115-1 and FAS 124-1, “The
Meaning of Other-Than-Temporary Impairment and Its Application to Certain Investments,”
and FSP FAS 115-2 and FAS 124-2, “Recognition and Presentation of Other-ThanTemporary Impairments”) and ASC Subtopic 325-40, Investments-Other – Beneficial
Interests in Securitized Financial Assets (formerly Emerging Issues Task Force (EITF) Issue
No. 99-20, “Recognition of Interest Income and Impairment on Purchased Beneficial Interests
and Beneficial Interests That Continue to Be Held by a Transferor in Securitized Financial
Assets,” as amended by FSP EITF 99-20-1, “Amendments to the Impairment Guidance of
EITF Issue No. 99-20”), as appropriate.
When an other-than-temporary impairment loss has occurred on an individual debt security,
the total amount of the loss is the entire difference between the amortized cost of the debt
security and its fair value on the measurement date of the other-than-temporary impairment.
For an other-than-temporary impairment loss on a debt security that the bank intends to sell

FFIEC 051

RI-31
(9-23)
(9-19)

RI - INCOME STATEMENT

FFIEC 051

RC-C - LOANS AND LEASES

Part I. (cont.)
Memoranda
Item No.

Caption and Instructions

14
(cont.)

pledge of collateral because they do not qualify as sales under ASC Topic 860, Transfers and
Servicing (formerly FASB Statement No. 140, “Accounting for Transfers and Servicing of
Financial Assets and Extinguishments of Liabilities,” as amended). Also include loans and
leases held for sale or investment by consolidated variable interest entities (VIEs) that can be
used only to settle obligations of the same consolidated VIEs. (Such loans and leases should
also be reported in Schedule SU, item 7.a). In general, the pledging of loans and leases is
the act of setting aside certain loans and leases to secure or collateralize bank transactions
with the bank continuing to own the loans and leases unless the bank defaults on the
transaction.
When a bank is subject to a blanket lien arrangement or has otherwise pledged an entire
portfolio of loans to secure its Federal Home Loan Bank advances, it should report the
amount of the entire portfolio of loans subject to the blanket lien in this item. Any loans within
the portfolio that have been explicitly excluded or specifically released from the lien and that
the bank has the right, without constraint, to repledge to another party should not be reported
as pledged in this item. However, if any such loans have been repledged to another party,
they should be reported in this item.

NOTE: Memorandum item 15 is to be completed for the December report only.
15

Reverse mortgages. A reverse mortgage is an arrangement in which a homeowner borrows
against the equity in his or her home and receives cash either in a lump sum or through
periodic payments. However, unlike a traditional mortgage loan, no payment is required until
the borrower no longer uses the home as his or her principal residence. Cash payments to
the borrower after closing, if any, and accrued interest are added to the principal balance.
These loans may have caps on their maximum principal balance or they may have clauses
that permit the cap on the maximum principal balance to be increased under certain
circumstances. The reverse mortgage market currently consists of two basic types of
products: proprietary products designed and originated by financial institutions and a
federally-insured product known as a Home Equity Conversion Mortgage (HECM).
Report in the appropriate subitem the specified information about the bank’s involvement with
reverse mortgages.

15.a

Reverse mortgages outstanding that are held for investment. Report in the appropriate
subitem the amount of HECM and proprietary reverse mortgages held for investment that are
included in Schedule RC-C, Part I, item 1.c, Loans “Secured by 1-4 family residential
properties.” A loan is held for investment if the bank has the intent and ability to hold the loan
for the foreseeable future or until maturity or payoff. Exclude reverse mortgages that are held
for sale.

15.a.(1)

Home Equity Conversion Mortgage (HECM) reverse mortgages. Report the amount of
HECM reverse mortgages held for investment that are included in Schedule RC-C, Part I,
item 1.c, Loans “Secured by 1-4 family residential properties.”

15.a.(2)

Proprietary reverse mortgages. Report the amount of proprietary reverse mortgages held
for investment that are included in Schedule RC-C, Part I, item 1.c, Loans “Secured by 1-4
family residential properties.”

FFIEC 051

RC-C-38
(3-21)
(9-23)

RC-C - LOANS AND LEASES

FFIEC 051

RC-C - LOANS AND LEASES

Part I. (cont.)
Memoranda
Item No.
15.b

Caption and Instructions
Estimated number of reverse mortgage loan referrals to other lenders during the year
from whom compensation has been received for services performed in connection
with the origination of the reverse mortgages. A bank that does not underwrite and fund
reverse mortgages may refer customers to other lenders that underwrite and fund such
mortgages. Under the Real Estate Settlement Procedures Act and its implementing
regulations, a mortgage lender may pay fees or compensation to another party, such as a
bank that has referred a customer to the mortgage lender, only for services actually
performed by that party.
If the bank receives compensation from reverse mortgage lenders for services the bank has
performed in connection with the origination of reverse mortgages granted to customers that
the bank has referred to the reverse mortgage lenders, report in the appropriate subitem a
reasonable estimate of the number of HECM and proprietary reverse mortgages for which the
bank received such compensation during the year. Do not report the estimated amount of
referral fee income in these subitems. this item.

15.b.(1)

Home Equity Conversion Mortgage (HECM) reverse mortgages. Report a reasonable
estimate of the number of HECM reverse mortgages for which the bank received
compensation for services performed during the year in connection with the origination of
HECM reverse mortgages granted to customers that the bank has referred to the reverse
mortgage lenders.

15.b.(2)

Proprietary reverse mortgages. Report a reasonable estimate of the number of proprietary
reverse mortgages for which the bank received compensation for services performed during
the year in connection with the origination of proprietary reverse mortgages granted to
customers that the bank has referred to the reverse mortgage lenders.

15.c

Principal amount of reverse mortgage originations that have been sold during the year.
Report in the appropriate subitem the principal amount of HECM and proprietary reverse
mortgages sold during the year that were originated by the bank. Report the principal
balance outstanding of the reverse mortgages as of their sale dates, which excludes any
unused commitments to the borrowers on the reverse mortgages sold.

15.c.(1)

Home Equity Conversion Mortgage (HECM) reverse mortgages. Report the principal
amount of HECM reverse mortgages sold during the year that were originated by the bank.

15.c.(2)

Proprietary reverse mortgages. Report the principal amount of proprietary reverse
mortgages sold during the year that were originated by the bank.

NOTE: Memorandum item 16 is to be completed semiannually in the June and December reports only.
16

FFIEC 051

Revolving, open-end loans secured by 1-4 family residential properties and extended
under lines of credit (in domestic offices) that have converted to non-revolving closedend status (included in item 1.c.(1) above). Report the amount outstanding of loans
included in Schedule RC-C, Part I, item 1.c.(1), that have converted to non-revolving, closedend status, but originated as draws under revolving, open-end lines of credit secured by
1-to-4 family residential properties, including those for which the draw periods have ended.

RC-C-39
(3-21)
(9-23)

RC-C - LOANS AND LEASES

FFIEC 051

RC-F - OTHER ASSETS

Item No.

Caption and Instructions

6
(cont.)

(8)

Credit or debit card sales slips in process of collection until the reporting bank has been
notified that it has been given credit (report thereafter in Schedule RC, item 1.a,
"Noninterest-bearing balances and currency and coin").

(9)

Purchased computer software, net of accumulated amortization, and unamortized costs
of computer software to be sold, leased, or otherwise marketed capitalized in
accordance with the provisions of ASC Subtopic 985-20, Software – Costs of Software
to Be Sold, Leased or Marketed (formerly FASB Statement No. 86, “Accounting for the
Cost of Computer Software to be Sold, Leased, or Otherwise Marketed”). (Report the
amount of computer software in Schedule RC-F, item 6.e, if this amount is greater than
$100,000 and exceeds 25 percent of the amount reported in Schedule RC-F, item 6.)

(10) Bullion (e.g., gold or silver) not held for trading purposes.
(11) Original art objects, including paintings, antique objects, and similar valuable decorative
articles (report at cost unless there has been a decline in value, judged to be other than
temporary, in which case the object should be written down to its fair value).
(12) Securities or other assets held in charitable trusts (e.g., Clifford Trusts).
(13) Debt issuance costs related to line-of-credit arrangements, net of accumulated
amortization. Debt issuance costs related to a recognized debt liability that is not a
line-of-credit arrangement should be presented as a direct deduction from the face
amount of the related debt, not as an asset. For debt reported at fair value under a
fair value option, debt issuance costs should be expensed as incurred.
(14) Furniture and equipment rented to others under operating leases, net of accumulated
depreciation.
(15) Ground rents.
(16) Customers' liability for deferred payment letters of credit.
(17) Reinsurance recoverables from reinsurers external to the consolidated bank.
(18) "Separate account assets" of the reporting bank's insurance subsidiaries.
(19) The positive fair value of unused loan commitments (not accounted for as derivatives)
that the bank has elected to report at fair value under a fair value option.
(20) FDIC loss-sharing indemnification assets. These indemnification assets represent the
carrying amount of the right to receive payments from the FDIC for losses incurred on
specified assets acquired from failed insured depository institutions or otherwise
purchased from the FDIC that are covered by loss-sharing agreements with the FDIC.
(Report the amount of such assets in Schedule RC-F, item 6.d, if this amount is greater
than $100,000 and exceeds 25 percent of the amount reported in Schedule RC-F,
item 6.) (Exclude the assets covered by the FDIC loss-sharing agreements from this
component of “All other assets.” Instead, report each covered asset in the balance
sheet category appropriate to the asset on Schedule RC, e.g., report covered held-forinvestment loans in Schedule RC, item 4.b, “Loans and leases held for investment.”)

FFIEC 051

RC-F-6
(3-19)
(9-23)

RC-F - OTHER ASSETS

FFIEC 051

Item No.
17.d

RC-M - MEMORANDA

Caption and Instructions
Outstanding balance of borrowings from Federal Reserve Banks under the PPPLF with
a remaining maturity of. Report in the appropriate subitem the specified information about
the outstanding amount of borrowings from Federal Reserve Banks under the PPPLF
reported in Schedule RC, item 16. The maturity date of an extension of credit under the
PPPLF equals the maturity date of the PPP loan pledged to secure the extension of credit,
which is either two or five years from origination of the PPP loan. However, the maturity date
of the extension of credit will be accelerated and the institution is required to repay the
extension of credit under the PPPLF prior to its maturity date when the institution has been
reimbursed by the SBA for a PPP loan forgiveness (to the extent of the forgiveness), has
received payment from the SBA representing exercise of the PPP loan guarantee, or has
received payment from the PPP borrower of the underlying PPP loan (to the extent of the
payment received).
The remaining maturity is the amount of time remaining from the report date until the final
contractual maturity of the borrowing without regard to the borrowing’s repayment schedule, if
any.

17.d.(1)
.

One year or less. Report the outstanding amount as of the report date of borrowings by the
reporting institution from a Federal Reserve Bank under the PPPLF with a remaining maturity
of one year or less.
The borrowings that should be included in this item will also have been included in
(1) Schedule RC-M, item 5.b.(1)(a), “Other borrowings with a remaining maturity or next
repricing date of One year or less,” (2) Schedule RC-M, item 5.b.(2), “Other borrowings with a
remaining maturity of one year or less,” and (3) Schedule RC-M, item 10.b, “Amount of ‘Other
borrowings’ that are secured.”

17.d.(2)

More than one year. Report the outstanding amount as of the report date of borrowings by
the reporting institution from a Federal Reserve Bank under the PPPLF with a remaining
maturity of more than one year.
The borrowings that should be included in this item will also have been included in (1)
Schedule RC-M, item 5.b.(1)(b), Other borrowings with a remaining maturity or next repricing
date of “Over one year through three years,” or Schedule RC-M, item 5.b.(1)(c), “Over three
years through five years,” as appropriate, and (2) Schedule RC-M, item 10.b, “Amount of
‘Other borrowings’ that are secured.”

17.e

Quarterly average amount of PPP loans pledged to the PPPLF and excluded from
“Total assets for the leverage ratio” reported in Schedule RC-R, Part I, item 30. Report
the quarterly average amount of PPP loans pledged to the PPPLF that are included as a
deduction in Schedule RC-R, Part I, item 29, “LESS: Other deductions from (additions to)
assets for leverage ratio purposes,” and thus excluded from “Total assets for the leverage
ratio” reported in Schedule RC-R, Part I, item 30.
This quarterly average should be consistent with and calculated using the same averaging
method used for calculating the quarterly average for “Total assets” reported in Schedule
RC-K, item 9.

18

FFIEC 051

Money Market Mutual Fund Liquidity Facility (MMLF). To prevent the disruption in the
money markets from destabilizing the financial system, the Board of Governors of the Federal
Reserve System authorized the Federal Reserve Bank of Boston on March 19, 2020, to
establish the MMLF pursuant to Section 13(3) of the Federal Reserve Act (12 U.S.C. 343(3)).
Under the MMLF, the Federal Reserve Bank of Boston extends non-recourse loans to eligible
borrowers to purchase eligible assets from money market mutual funds, which is posted as
collateral to the Federal Reserve Bank of Boston.
RC-M-20
(9-21)
(9-23)

RC-M - MEMORANDA

FFIEC 051

Item No.

RC-M - MEMORANDA

Caption and Instructions

18.a

Outstanding balance of assets purchased under the MMLF. Report on a fully
consolidated basis the aggregate amount at which the reporting institution’s holdings of
assets purchased under the MMLF are included in Schedule RC, item 1.b, “Interest-bearing
balances” due from depository institutions; item 2.a, “Held-to-maturity securities;” item 2.b,
“Available-for-sale securities;” item 5, “Trading assets;” and item 11, “Other assets;” as
appropriate, as of the report date.

18.b

Quarterly average amount of assets purchased under the MMLF and excluded from
“Total assets for the leverage ratio” reported in Schedule RC-R, Part I, item 30. Report
the quarterly average amount of assets purchased under the MMLF that are included as a
deduction in Schedule RC-R, Part I, item 29, “LESS: Other deductions from (additions to)
assets for leverage ratio purposes,” and thus excluded from “Total assets for the leverage
ratio” reported in Schedule RC-R, Part I, item 30.
This quarterly average should be consistent with and calculated using the same averaging
method used for calculating the quarterly average for “Total assets” reported in Schedule
RC-K, item 9.

FFIEC 051

RC-M-21
(9-21)
(9-23)

RC-M - MEMORANDA

FFIEC 051

Item No.
11

RC-N - PAST DUE

Caption and Instructions
Loans and leases reported in items 1 through 8 above that are wholly or partially
guaranteed by the U.S. Government, excluding loans and leases covered by losssharing agreements with the FDIC. Report in the appropriate column the aggregate
amount of all loans and leases reported in Schedule RC-N, items 1 through 8, above for
which repayment of principal is wholly or partially guaranteed or insured by the U.S.
Government, including its agencies and its government-sponsored agencies, but excluding
loans and leases covered by loss-sharing agreements with the FDIC, which are reported in
Schedule SU, item 9. Examples include loans guaranteed by the Small Business
Administration and the Federal Housing Administration. Amounts need not be reported in
this item and in items 11.a and 11.b below if they are considered immaterial.
Exclude from this item loans and leases guaranteed or insured by state or local governments,
state or local government agencies, foreign (non-U.S.) governments, and private agencies or
organizations. Also exclude loans and leases collateralized by securities issued by the
U.S. Government, including its agencies and its government-sponsored agencies.

11.a

Guaranteed portion of loans and leases included in item 11 above, excluding rebooked
“GNMA loans.” Report in the appropriate column the maximum amount recoverable from
the U.S. Government, including its agencies and its government-sponsored agencies, under
the guarantee or insurance provisions applicable to the loans and leases included in
Schedule RC-N, item 11, above.
Seller-servicers of GNMA loans should exclude all delinquent rebooked GNMA loans that
have been repurchased or are eligible for repurchase from this item (report such rebooked
GNMA loans in item 11.b below). Servicers of GNMA loans should exclude individual
delinquent loans (for which they were not the transferor) that they have purchased out of
GNMA securitizations from this item (report such purchased GNMA loans in item 11.b below).

11.b

Rebooked "GNMA loans" that have been repurchased or are eligible for repurchase
included in item 11 above. Report in the appropriate column the amount included in
Schedule RC-N, item 11, of:
(1) Delinquent rebooked GNMA loans that have been repurchased or are eligible for
repurchase by seller-servicers of GNMA loans; and
(2) Delinquent loans that have been purchased out of GNMA securitizations by servicers of
GNMA loans that were not the transferors of the loans.

12

Portion of covered loans and leases included in item 9 above that is protected by FDIC losssharing agreements. Report in column B ("Past due 90 days or more and still accruing") and column C
("Nonaccrual"), as appropriate, the maximum amount recoverable from the FDIC under loss-sharing
agreements covering the past due and nonaccrual loans and leases reported in Schedule RC-N, item 9,
above beyond the amount that has already been reflected in the measurement of the reporting bank’s
indemnification asset, which represents the right to receive payments from the FDIC under
the loss-sharing agreement. Amounts need not be reported in this item if they are considered immaterial.
In general, the maximum amount recoverable from the FDIC on covered past due and nonaccrual loans
and leases is the recorded amount of these loans and leases, as reported in Schedule RC-N, item 9,
multiplied by the currently applicable loss coverage rate (e.g., 80 percent or 95 percent). This product will
normally be the maximum amount recoverable because reimbursements from the FDIC for covered
losses related to the amount by which the “book value” of a covered asset on the failed institution’s books
(which is the amount upon which payments under an FDIC loss-sharing agreement are based) exceeds
the amount at which the reporting bank reports the covered asset on Schedule RC, Balance Sheet,
should already have been taken into account in measuring the carrying amount of the reporting bank’s
loss-sharing indemnification asset, which is reported in Schedule RC-F, item 6, “All other assets.”

FFIEC 051

RC-N-8
(9-23)
(3-17)

RC-N - PAST DUE

FFIEC 051

Item No.

SU – SUPPLEMENTAL

Caption and Instructions

FDIC Loss-Sharing Agreements
9

Does the institution have assets covered by FDIC loss-sharing agreements?
If your institution has any assets covered by FDIC loss-sharing agreements, place an “X” in
the box marked “Yes” and complete items 9.a through 9.e, below.
If your institution does not have any assets covered by FDIC loss-sharing agreements, place
an “X” in the box marked “No” and skip item items 9.a through 9.e.
Note: Under a loss-sharing agreement, the FDIC agrees to absorb a portion of the losses on
a specified pool of a failed insured depository institution’s assets in order to maximize asset
recoveries and minimize the FDIC’s losses. In general, for transactions that occurred before
April 2010, the FDIC reimburses 80 percent of losses incurred by an acquiring institution on
covered assets over a specified period of time up to a stated threshold amount, with the
acquirer absorbing 20 percent of the losses on these assets. Any losses above the stated
threshold amount are reimbursed by the FDIC at 95 percent of the losses recognized by the
acquirer. For transactions that occurred after March 2010, the FDIC generally reimburses 80
percent of the losses incurred by the acquirer on covered assets, with the acquiring institution
absorbing 20 percent.

9.a

Loans and leases covered by FDIC loss-sharing agreements. Report the balance sheet
amount of loans and leases held for sale and loans and leases held for investment included
in Schedule RC-C, Part I, items 1 through 10, acquired from failed insured depository
institutions or otherwise purchased from the FDIC that are covered by loss-sharing
agreements with the FDIC.
Do not report the “book value” of the covered loans and leases on the failed institution’s
books, which may be the amount upon which payments from the FDIC to the reporting
institution are to be based in accordance with the loss-sharing agreement.

9.b

Past due and nonaccrual loans and leases covered by FDIC loss-sharing agreements.
Report in the appropriate subitem the aggregate amount of all loans and leases covered by
loss-sharing agreements with the FDIC and reported in Schedule SU, item 9.a, that have
been included in Schedule RC-N, items 1 through 8, because they are past due 30 days or
more or are in nonaccrual status as of the report date.

9.b.(1)

Past due 30 through 89 days and still accruing. Report the amount of covered loans
and leases reported in Schedule SU, item 9.a, that are included in Schedule RC-N,
items 1 through 8, column A, because they are past due 30 days through 89 days and still
accruing as of the report date.

9.b.(2)

Past due 90 days or more and still accruing. Report the amount of covered loans
and leases reported in Schedule SU, item 9.a, that are included in Schedule RC-N,
items 1 through 8, column B, because they are past due 90 days or more and still accruing as
of the report date.

9.b.(3)

Nonaccrual. Report the amount of covered loans and leases reported in Schedule SU,
item 9.a, that are included in Schedule RC-N, items 1 through 8, column C, because they are
in nonaccrual status.

9.c

Portion of past due and nonaccrual covered loans and leases that is protected by FDIC
loss-sharing agreements. Report in the appropriate subitem the maximum amount
recoverable from the FDIC under loss-sharing agreements covering the past due and

FFIEC 051

SU-15
(6-18)
(9-23)

SU – SUPPLEMENTAL

FFIEC 051

SU – SUPPLEMENTAL

Item No.

Caption and Instructions

9.c
(cont.)

nonaccrual loans and leases reported in Schedule SU, items 9.b.(1) through 9.b.(3), above,
beyond the amount that has already been reflected in the measurement of the reporting
institution’s indemnification asset, which represents the right to receive payments from the
FDIC under the loss-sharing agreement.
In general, the maximum amount recoverable from the FDIC on covered past due and
nonaccrual loans and leases is the amount of these loans and leases, as reported in
Schedule SU, items 9.b.(1) through 9.b.(3), multiplied by the currently applicable loss
coverage rate (e.g., 80 percent or 95 percent). This product will normally be the maximum
amount recoverable because reimbursements from the FDIC for covered losses related to
the amount by which the “book value” of a covered asset on the failed institution’s books
(which is the amount upon which payments under an FDIC loss-sharing agreement are
based) exceeds the amount at which the reporting institution reports the covered asset on
Schedule RC, Balance Sheet, should already have been taken into account in measuring the
carrying amount of the reporting institution’s loss-sharing indemnification asset, which is
reported in Schedule RC-F, item 6, “All other assets.”

9.c.(1)

Past due 30 through 89 days and still accruing. Report the maximum amount recoverable
from the FDIC under loss-sharing agreements covering the loans and leases reported in
Schedule SU, item 9.b.(1), because they are past due 30 days through 89 days and still
accruing as of the report date.

9.c.(2)

Past due 90 days or more and still accruing. Report the maximum amount recoverable
from the FDIC under loss-sharing agreements covering the loans and leases reported in
Schedule SU, item 9.b.(2), because they are past due 90 days or more and still accruing as
of the report date.

9.c.(3)

Nonaccrual. Report the maximum amount recoverable from the FDIC under loss-sharing
agreements covering loans and leases reported in Schedule SU, item 9.b.(3), because they
are in nonaccrual status.

9.d

Other real estate owned covered by FDIC loss-sharing agreements. Report the carrying
amount of other real estate owned (included in Schedule RC, item 7) acquired from failed
insured depository institutions or otherwise purchased from the FDIC that are covered by
loss-sharing agreements with the FDIC.

9.e

Portion of covered other real estate owned that is protected by FDIC loss-sharing
agreements. Report the maximum amount recoverable from the FDIC under loss-sharing
agreements covering the other real estate owned reported in Schedule SU, item 9.d, beyond
the amount that has already been reflected in the measurement of the reporting institution’s
indemnification asset, which represents the right to receive payments from the FDIC under
the loss-sharing agreement.
In general, the maximum amount recoverable from the FDIC on covered other real estate
owned is the carrying amount of the other real estate, as reported in Schedule SU, item 9.d,
multiplied by the currently applicable loss coverage rate (e.g., 80 percent or 95 percent). This
product will normally be the maximum amount recoverable because reimbursements from the
FDIC for covered losses related to the amount by which the “book value” of a covered asset
on the failed institution’s books (which is the amount upon which payments under an FDIC
loss-sharing agreement are based) exceeds the amount at which the reporting institution
reports the covered asset on Schedule RC, Balance Sheet, should already have been taken
into account in measuring the carrying amount of the reporting institution’s loss-sharing
indemnification asset, which is reported in Schedule RC-F, item 6, “All other assets.”

FFIEC 051

SU-16
(6-18)
(9-23)

SU – SUPPLEMENTAL

FFIEC 051

RC-T – FIDUCIARY AND RELATED SERVICES

Item No.

Caption and Instructions

3
(cont.)

income greater than 10 percent of revenue (net interest income plus noninterest income) for
the preceding calendar year must complete:
• Items 4 through 22 quarterly;
• Items 23 through 26 annually with the December report;
• Memorandum item 3 quarterly; and
• Memorandum items 1, 2, and 4 annually with the December report.
Institutions with total fiduciary assets (item 10, sum of columns A and B) greater than
$250 million but less than or equal to $1 billion (as of the preceding December 31) that do not
meet the fiduciary income test for quarterly reporting must complete:
• Items 4 through 22 semiannually with the June and December reports;
• Items 23 through 26 annually with the December report;
• Memorandum item 3 semiannually with the June and December reports; and
• Memorandum items 1, 2, and 4 annually with the December report.
Institutions with total fiduciary assets (item 10, sum of columns A and B) of less than or equal
to $250 million (as of the preceding December 31) that do not meet the fiduciary income test
for quarterly reporting must complete:
• Items 4 through 13 annually with the December report; and
• Memorandum items 1 through 3 annually with the December report.
In addition, institutions with total fiduciary assets greater than $100 million but less than or
equal to $250 million (as of the preceding December 31) that do not meet the fiduciary
income test for quarterly reporting must also complete Memorandum item 4 annually with the
December report.

Fiduciary and Related Assets
Institutions should generally report fiduciary and related assets using their market value as of the report
date. While market value quotations are readily available for marketable securities, many financial and
physical assets held in fiduciary accounts are not widely traded or easily valued. If the methodology for
determining market values is not set or governed by applicable law (including the terms of the prevailing
fiduciary agreement), the institution may use any reasonable method to establish values for fiduciary and
related assets for purposes of reporting on this schedule. Reasonable methods include appraised values,
book values, if appropriate, cash surrender values of certain life insurance policies, or reliable estimates.
Valuation methods should be consistent from reporting period to reporting period. This "reasonable
method" approach to reporting market values applies both to financial assets that are not marketable and
to physical assets. Common physical assets held in fiduciary accounts include real estate, equipment,
collectibles, and household goods.
Only those Individual Retirement Accounts, Keogh Plan accounts, Health Savings Accounts, and similar
accounts offered through a fiduciary business unit of the reporting institution should be reported in Schedule
RC-T. When such accounts are not offered through an institution’s fiduciary business unit, they should not
be reported in Schedule RC-T. Accounts that consist solely of deposits in the bank itself should not be
reported in Schedule RC-T.
If two institutions are named co-fiduciary in the governing instrument, both institutions should report the
account. In addition, where one institution contracts with another for fiduciary or related services
(i.e.e.g, Bank A provides custody services to the trust accounts of Bank B, or Bank A provides investment
management services to the trust accounts of Bank B), both institutions should report the accounts in their
respective capacities. from reporting in Schedule RC-T
Exclude unfunded insurance trusts, testamentary executor appointments, and any other arrangements
representing potential future fiduciary accounts. Asset values reported on this schedule should generally
exclude liabilities. For example, an employee benefit account with associated loans against account
assets should be reported gross of the outstanding loan balances.
FFIEC 051

, such as testamentary executor appointments.

RC-T-2
RC-T – FIDUCIARY AND RELATED SERVICES
(9-21)
Also exclude from Schedule RC-T, assets for which
the institution is only providing operational, or backoffice
services, and the accounts or assets are not held by the institution.

RC-T – FIDUCIARY AND RELATED SERVICES

FFIEC 051

Fiduciary and Related Assets (cont.)
Non-Managed Assets – Column B
Report the total market value of assets held in non-managed fiduciary accounts. An account should be
categorized as non-managed if the institution does not have investment discretion. Those accounts for
which the institution provides a menu of investment options but the ultimate selection authority remains
with the account holder or an external manager should be categorized as non-managed. For example,
an institution that offers a choice of sweep vehicles is not necessarily exercising investment discretion.
The process of narrowing investment options from a range of alternatives does not create a managed
fiduciary account for the purposes of this schedule. For example, a 401(k) employee benefit plan where
the participants select investments from a list of investment options should be reported as non-managed
for the purposes of this schedule.
Number of Managed Accounts – Column C
Report the total number of managed fiduciary accounts.
Number of Non-Managed Accounts – Column D
Report the total number of non-managed fiduciary accounts.
Item No.

Caption and Instructions

4

Personal trust and agency accounts. Report the market value and number of accounts for
all testamentary trusts, revocable and irrevocable living trusts (including life insurance trusts,
except for term life insurance policies that have nominal value), other personal trusts, and
non-managed personal agency accounts. Include accounts in which the institution serves as
executor, administrator, guardian, or conservator. Exclude personal investment management
and investment advisory agency accounts, which should be reported in Schedule RC-T,
item 7. Also exclude Keogh Plan accounts, Individual Retirement Accounts (IRAs), Health
Savings Accounts, and other pension or profit-sharing plans for self-employed individuals,
which should be reported in Schedule RC-T, item 5. Personal accounts that are solely
custody or safekeeping should be reported in item 11 of this schedule.

5

Employee benefit and retirement-related trust and agency accounts:

5.a

Employee benefit – defined contribution. Report the market value and number of
accounts for all employee benefit defined contribution accounts in which the institution serves
as either trustee or agent. Include 401(k) plans, 403(b) plans, profit-sharing plans, money
purchase plans, target benefit plans, stock bonus plans, employee stock ownership plans,
and thrift savings plans. Include those accounts in which the institution serves as either
trustee or agent and provides investment management services or provides investment
advice for a fee. Employee benefit accounts for which the institution serves as a directed
trustee or provides investment advice for a fee should be reported as non-managed. The
number of accounts reported should reflect the total number of plans administered rather
than the number of plan participants. Employee benefit accounts that are solely custody and
safekeeping accounts should be reported in Schedule RC-T, item 11.

5.b

Employee benefit – defined benefit. Report the market value and number of accounts for
all employee benefit defined benefit plans in which the institution serves as either trustee or
agent. Include those accounts in which the institution provides investment management
services or provides investment advice for a fee. Employee benefit accounts for which the
institution serves as a directed trustee or provides investment advice for a fee should be
reported as non-managed. The number of accounts reported should reflect the total number
of plans administered rather than the number of plan participants. Employee benefit
accounts that are solely custody and safekeeping accounts should be reported in
Schedule RC-T, item 11.

FFIEC 051

RC-T-X
(9-21)
(9-23)

RC-T – FIDUCIARY AND RELATED SERVICES

RC-T – FIDUCIARY AND RELATED SERVICES

FFIEC 051

5.c

FFIEC 051

Other employee benefit and retirement-related accounts. Report the market value and
number of accounts for all other employee benefit and retirement-related fiduciary accounts
in which the institution serves as either trustee or agent. Include those accounts in which the
institution provides investment management services or provides investment advice for a
fee. Include Keogh Plan accounts, Individual Retirement Accounts, Health Savings
Accounts, Medical Savings Accounts, and other

RC-T-X
(9-21)
(9-23)

RC-T – FIDUCIARY AND RELATED SERVICES

RC-T – FIDUCIARY AND RELATED SERVICES

FFIEC 051

Item No.

Caption and Instructions

5.c
(cont.)

pension or profit-sharing plans for self-employed individuals. Also report the market value of
assets and the number of accounts for employee welfare benefit trusts and agencies.
Employee welfare benefit plans include plans, funds, or programs that provide medical,
surgical, or hospital care benefits; benefits in the event of sickness, accident, disability, death,
or unemployment; vacation benefits; apprenticeship or other training programs; day care
centers; scholarship funds; or prepaid legal services. Employee benefit accounts for which
the institution serves as a directed trustee or provides investment advice for a fee should be
reported as non-managed. Exclude accounts, originated by fiduciary or non-fiduciary
personnel, that are only permitted to be invested in own-bank deposits. The number of
accounts reported should reflect the total number of plans or accounts administered rather
than the number of plan participants. Other retirement accounts that are solely custody and
safekeeping accounts should be reported in Schedule RC-T, item 11. Individual Retirement
Accounts, Health Savings Accounts, and other similar accounts should also be reported in
Schedule RC-T, item 13.

6

Corporate trust and agency accounts. Report the market value of assets held by the
institution for all corporate trust and agency accounts. Report assets that are the
responsibility of the institution to manage or administer in accordance with the corporate trust
agreement. Include assets relating to unpresented bonds or coupons relating to issues that
have been called or matured. Do NOT report the entire market value of the associated
securities or the outstanding principal of associated debt issues. Include accounts for which
the institution is trustee for corporate securities, tax-exempt and other municipal securities,
and other debt securities including unit investment trusts. Also include accounts for which the
institution is dividend or interest paying agent, and any other type of corporate trustee or
agent appointment. Accounts that are solely custodial or safekeeping should be reported in
Schedule RC-T, item 11.

7

Investment management and investment advisory agency accounts. Report the market
value and number of accounts for all individual and institutional investment management and
investment advisory agency accounts that are administered within the fiduciary area of the
institution. Investment management accounts are those agency accounts for which the
institution has investment discretion; however, title to the assets remains with the client.
Include accounts for which the institution serves as a sub-adviser. Investment advisory
accounts are those agency accounts for which the institution provides investment advice for a
fee, but for which some other person is responsible for investment decisions. Investment
management agency accounts should be reported as managed. Investment advisory agency
accounts should be reported as non-managed. Exclude investment management and
investment advisory agency accounts maintained for employee benefit and retirement-related
accounts, which should be reported in Schedule RC-T, item 5. Investment management and
investment advisory agency accounts maintained for foundations and endowments should be
reported in Schedule RC-T, item 8. As noted in the Fiduciary and Related Assets section
above, exclude investment management and investment advisory agency accounts that are
administered by subsidiary registered investment advisers. Include those mutual funds that
are advised by the fiduciary area that is a separately identifiable department or division (as
defined in Section 217 of the Gramm-Leach-Bliley Act). Classes of the same mutual fund
should be combined and reported as a single account.

8

Foundation and endowment trust and agency accounts. Report the market value and
number of accounts for all foundations and endowments (whether established by individuals,
families, corporations, or other entities) that file any version of Form 990 with the Internal
Revenue Service and for which the institution serves as either trustee or agent. Also include

FFIEC 051

RC-T-X
(9-21)
(9-23)

RC-T – FIDUCIARY AND RELATED SERVICES

RC-T – FIDUCIARY AND RELATED SERVICES

FFIEC 051

Item No.

those foundations and endowments that do not file Form 990, 990EZ, or 990PF solely
because the organization’s gross receipts or total assets fall below reporting thresholds, but
would otherwise be required to file. Foundations and endowments established by churches,
which are exempt from filing Form 990, should also be included in this item. Employee
benefit accounts maintained for a foundation’s or endowment’s employees should be
Caption and Instructions

8
(cont.)

reported in Schedule RC-T, item 5. Accounts that are solely custodial or safekeeping should
be reported in Schedule RC-T, item 11.

9

Other fiduciary accounts. Report the market value and number of accounts for all other
trusts and agencies not reported in Schedule RC-T, items 4 through 8. Custody and
safekeeping accounts should be reported in Schedule RC-T, item 11.

10

Total fiduciary accounts. Report the sum of items 4 through 9.

11

Custody and safekeeping accounts. Report the market value and number of accounts for
all personal and institutional custody and safekeeping accounts held by the institution.
Safekeeping and custody accounts are a type of agency account in which the reporting
institution performs one or more specified agency functions but the institution is not a trustee
and also is not responsible for managing the asset selection for account assets. These
agency services may include holding assets, processing income and redemptions, and other
recordkeeping and customer reporting services. For employee benefit custody or
safekeeping accounts, the number of accounts reported should reflect the total number of
plans administered rather than the number of plan participants. Include accounts in which
the institution serves in a sub-custodian capacity. For example, where one institution
contracts with another for custody services, both institutions should report the accounts in
their respective capacity. Individual Retirement Accounts, Health Savings Accounts, and
other similar accounts should also be reported in Schedule RC-T, item 13.
Accounts in which the institution serves as either trustee or in an agency capacity agent in
addition to being custodian should be reported in the category of the primary relationship. An
account with both a fiduciary and custodial relationship should be reported under the
fiduciary capacity as the primary relationship. For example, personal trust accounts in which
the institution also serves as custodian should be reported as personal trust accounts and
not as custodian accounts. An institution should report an account only once in Schedule
RC-T, items 4 through 9 and 11.
Report custodian accounts that are incidental to fiduciary services. Include those custody
and safekeeping accounts that are administered by the trust department, and those that are
administered in other areas of the institution through an identifiable business unit that focuses
on offering fiduciary related custodial services to institutional clients. Exclude those custodial
and escrow activities related to commercial bank services such as hold-in-custody
repurchase assets, securities safekeeping services for correspondent banks, escrow assets
held for the benefit of third parties, safety deposit box assets, and any other similar
commercial arrangement.

12

FFIEC 051

Not applicable.

RC-T-X
(9-23)
(9-21)

RC-T – FIDUCIARY AND RELATED SERVICES