FFIEC031_FFIEC041_FFIEC051_20230621_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 (1) eliminate and consolidate
items on the Call Reports resulting from the statutorily mandated full review of the Call Reports
as required under Section 604 of the Financial Services Regulatory Relief Act of 2006, (2) make
Call Report process changes, (3) clarify the instructions for the reporting of certain items on
Schedule RC-T, Fiduciary and Related Services, and (4) seek comment on a previously made
clarification related to the reporting of certain Federal Home Loan Mortgage Corporation and
similar securitizations on the Call Reports, with changes effective for the September 30, 2023,
report date.
The current estimated total annual burden for the Call Reports is 127,554 hours, and
would decrease to 123,387 hours. The proposed revisions would result in a decrease of 4,167
hours. The 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 (FRA) (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 through 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, that have total consolidated
assets of $100 billion or more, or that are otherwise an advanced approaches institution for
regulatory capital purposes 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 generally file the FFIEC 051.1
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.2 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.3 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

1

Except such banks that (1) are advanced approaches institutions or are subject to Category III capital standards for
regulatory capital purposes, (2) are large or highly complex institutions for deposit insurance assessment purposes,
or (3) have elected, or have been required by their primary federal regulator, to file the FFIEC 041.
2
Report of 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).
3
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.

2

companies lack the data necessary to assess the financial condition of individual banks to
determine whether there has 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.
Respondent Panel
For purposes of the Board, the respondent panel for the Call Reports 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 generally file the
FFIEC 041, and banks with domestic offices only and total assets less than $5 billion generally
file the FFIEC 051.
Frequency and Time Schedule
The Call Reports are collected quarterly as 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.
Initially Proposed Revisions
Statutorily Mandated Review of the Call Reports
Section 604 of the Financial Services Regulatory Relief Act of 2006 requires the agencies
to perform within one year of enactment and every five years thereafter, the review of
information collected in the Call Reports (statutorily mandated review) to “reduce or eliminate
any requirement to file information or schedules under paragraph (3) (other than information or
schedules that are otherwise required by law)” if the agencies determine that “the continued
collection of such information or schedules is no longer necessary or appropriate.”4 The agencies
conducted the 2022 statutorily mandated review between June 2021 and March 2022.5 Over this
4

12 U.S.C. § 1817(a)(11).
The 2017 statutorily mandated review was accelerated as part of the 2014 FFIEC initiative to identify potential
opportunities to reduce burden associated with the Call Report requirements for community banks. The initiative
resulted in the creation of a new streamlined FFIEC 051 Call Report for eligible small institutions that took effect as
of the March 31, 2017, report date. It also resulted in significant reductions to the number of data items reported,
changes in the frequency of items collected, and increases in reporting thresholds for certain data items on the
FFIEC 031 and FFIEC 041 Call Reports. In addition, the agencies issued a final rule in June 2019 implementing
5

3

period, staff at the FFIEC member entities who are users of Call Report data, representing a wide
variety of functional areas, participated in a series of three surveys and conducted an analysis of
recent reporting by Call Report respondents. As an integral part of these surveys, users were
asked to explain the need for the continued collection of each Call Report data item, how the data
item is used, the frequency with which it is needed, and the threshold for the population of
institutions by asset size from which it is required. Based on these survey results, the agencies
are proposed certain revisions to the Call Reports.
FDIC Loss-sharing Agreements Items
FDIC loss-sharing agreements indemnified institutions for certain losses incurred on
specified assets acquired from failed insured depository institutions or otherwise purchased from
the FDIC that are covered by such agreements with the FDIC. Under a loss-sharing agreement,
the FDIC agreed to absorb a portion of the losses on a specified pool of a failed insured
depository institution’s assets to maximize asset recoveries and minimize the FDIC’s losses. The
number of institutions reporting on the related items has decreased as loans, other real estate, and
other assets covered by loss-sharing agreements with the FDIC have largely been paid-off or
sold. Additionally, all loss-sharing agreements have expired or have been terminated. Therefore,
the agencies no longer consider the current level of detail on these agreements to be appropriate
and proposed to eliminate the following associated items:
• For all versions of the Call Reports, Schedule RC-F, Other Assets, item 6.d, “FDIC losssharing indemnification assets,” which represent the carrying amount of the right to
receive payments from the FDIC for losses incurred under loss-sharing agreements.
• For FFIEC 031 and FFIEC 041, Schedule RC-M, Memoranda, item 13, “Assets covered
by loss-agreements with the FDIC,” including each subitem 13.a.(1)(a)(1) through 13.d.
These items include, for each appropriate class of asset, the balance sheet carrying
amount of all assets acquired from failed insured depository institutions or otherwise
purchased from the FDIC that are covered by loss-sharing agreements.
• For the FFIEC 031, Schedule RC-M, item 13.b.(6), “In foreign offices.” This item is not
reported in the FFIEC 041.
• For FFIEC 031 and FFIEC 041, Schedule RC-N, Past Due and Nonaccrual Loans,
Leases, and Other Assets, item 12, “Loans and leases reported in items 1 through 8 above
that are covered by loss-sharing agreements with the FDIC,” including each subitem
12.a.(1)(a) through 12.f. Items 12.a.(1)(a) through 12.e include the amount of all loans
and leases covered by FDIC loss-sharing agreements that are past due 30 days or more or
are in nonaccrual status as of the report date. Item 12.f includes the associated maximum
amount recoverable from the FDIC, beyond the amount reflected in the loss-sharing
indemnification assets.
• For the FFIEC 051, Schedule SU, Supplemental Information, item 9 “Does the institution
have assets covered by FDIC loss-sharing agreements?” including items 9.a through 9.e,
which collect, as appropriate, the amount of loans, leases and other real estate owned that
are covered by FDIC loss-sharing agreements, and details of amounts that are past due 30

Section 205 of the Economic Growth, Regulatory Relief, and Consumer Protection Act, expanding the eligibility for
institutions to complete the FFIEC 051 Call Report. See 84 FR 29039 (June 21, 2019).

4

days or more or are in nonaccrual status, and the maximum amount recoverable from the
FDIC.
Noncash Income from Negative Amortization Loans
Negative amortization loans contractually permit a borrower to make minimum periodic
payments that are less than the full amount of interest owed to the lender, with the unpaid interest
added to the loan’s principal balance. Based on the results of the 2022 statutorily mandated full
review, the agencies proposed to remove one item related to negative amortization loans. The
agencies proposed this removal based on the decline in volume of institutions reporting of
noncash income on negative amortization loans secured by 1-4 family residential properties to a
level no longer deemed necessary to collect. The agencies would be able to continue monitoring
the level of activity on negative amortization loans by reviewing the data reported on Schedule
RC-C, Memorandum items 8.a through 8.c. Therefore, for all versions of the Call Reports, the
agencies proposed to remove Schedule RI, Income Statement, Memorandum item 12, “Noncash
income from negative amortization on closed end loans secured by 1-4 family residential
properties.”
Reverse Mortgages Items
A reverse mortgage is an arrangement in which a homeowner borrows against the equity
in a principal residence and receives cash either in a lump sum or through periodic payments and
no payment is required from the borrower until the home is no longer used as the borrower’s
principal residence. Based on the results of the 2022 statutorily mandated full review, the
agencies no longer need the current level of detail on this activity and proposed, for all versions
of the Call Reports, to consolidate the subitems reported in Schedule RC-C, Loans and Lease
Financing Receivables, Part I, Loans and Leases, Memorandum item 15, “Reverse mortgages,”6
which is completed annually in the December report only.
Specifically, the proposal would consolidate Memorandum item 15.a.(1) and
Memorandum item 15.a.(2) into Memorandum item 15.a, “Reverse mortgages outstanding that
are held for investment (included in Schedule RC-C, item 1.c, above).” Similarly, Memorandum
item 15.b.(1) and Memorandum item 15.b.(2) would be consolidated into Memorandum item
15.b, “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.” Finally, Memorandum item 15.c.(1) and Memorandum item 15.c.(2)
would be consolidated into Memorandum item 15.c, “Principal amount of reverse mortgage
originations that have been sold during the year.”
Paycheck Protection Program and Federal Reserve Facilities Items
To enhance the functioning of money markets in response to the outbreak of the
coronavirus disease 2019 and to bolster the effectiveness of the Small Business Administration’s
Paycheck Protection Program (PPP),7 the Board, with the approval of the Secretary of the
6
7

For FFIEC 031 only, “Reverse mortgages in domestic offices.”
See https://www.sba.gov/funding-programs/loans/covid-19-relief-options/paycheck-protection-program.

5

Treasury, established in 2020 the Money Market Mutual Fund Liquidity Facility (MMLF) and
Paycheck Protection Program Liquidity Facility (PPPLF).8 Under the MMLF, the Federal
Reserve Bank of Boston extended loans to eligible borrowers to purchase assets from money
market mutual funds, which were posted as collateral to the facility. Under the PPPLF, Federal
Reserve Banks extended loans to eligible borrowers that were secured by covered loans
originated under the PPP. In March 2020 and April 2020, the agencies published interim final
rules (subsequently finalized in October 2020), which permit banking organizations to exclude
from regulatory capital requirements exposures related to the MMLF and PPPLF.9 On June 26,
2020, the FDIC adopted a final rule modifying the deposit insurance assessment regulations to
mitigate the assessment effects of participation in the MMLF, PPP, and PPPLF, as reported on
the Call Reports.10 Starting with the June 30, 2020, report date, banking organizations report
amounts related to the MMLF, PPP, and PPPLF on Schedule RC-M, Memoranda. When adding
these items, the agencies noted that these items were expected to be time-limited and would be
reviewed in connection with the 2022 statutorily mandated review of the Call Reports.11
The MMLF ceased extending credit on March 31, 2021, and as of April 30, 2021, the
outstanding amount of loans under the facility was zero dollars.12 The agencies therefore
proposed remove Schedule RC-M, Memoranda, item 18.a, “Outstanding balance of assets
purchased under the MMLF” and 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” on all versions of the Call Reports.
The PPP ended on May 31, 2021,13 and the PPPLF ceased offering credit on July 30,
2021. However, during the 2022 statutorily mandated full review, the number and outstanding
balance of PPP loans, along with the related outstanding balance pledged to the PPPLF, as
reported by institutions on Schedule RC-M, items 17.a, 17.b and 17.c, were identified as
continuing to be critical in the review of asset quality and other components of the Uniform
Financial Institutions Rating System used by the agencies during safety and soundness
examinations. In addition, item 17.b, “Outstanding balance of PPP loans,” along with items
17.d.(1) and 17.d.(2) that collect information on the remaining maturity of the outstanding
balances of borrowings from the Federal Reserve Banks under the PPPLF were deemed required
for FDIC deposit insurance assessment purposes. Finally, item 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” continues to be needed for regulatory capital
purposes. The agencies will continue to monitor the PPP-related data items and plan to propose
to discontinue the collection of these items once the aggregate industry activity has diminished to
a point where individual institution information is of limited practical utility and is no longer
needed for the purposes described above.
8

These facilities were established pursuant to section 13(3) of the FRA (12 U.S.C. § 343(3)). See
https://www.federalreserve.gov/monetarypolicy/mmlf.htm and
https://www.federalreserve.gov/monetarypolicy/ppplf.htm. The PPPLF was previously known as the Paycheck
Protection Program Lending Facility.
9
85 FR 16232 (March 23, 2020), 85 FR 20387 (April 13, 2020) and 85 FR 68243 (October 28, 2020).
10
85 FR 38282 (June 26, 2020).
11
85 FR 44366 (July 22, 2020).
12
See https://www.federalreserve.gov/monetarypolicy/mmlf.htm.
13
See https://www.federalreserve.gov/newsevents/pressreleases/monetary20210308a.htm.

6

Call Report Process Changes
In addition to the proposed revisions to the Call Reports, the agencies propose two
process improvements to streamline preparation of the Call Reports.
Format of Call Report Instructions
Each quarter, the FFIEC and FDIC make available on their websites the Instructions for
the Preparation of the Call Report, together with detailed updates to the Call Report instructions
implemented for that quarter-end report date.14 The instructions and updates are formatted in a
double-sided, printable format, including fixed page numbering and pages intentionally left
blank, to facilitate the use of a hard copy stored in a binder (binder format). The agencies make
the instructions available online in a Portable Document Format (PDF) format, and many
institutions access and use the instructions in that format. However, continuing to maintain the
instructions in a binder format increases the number of blank space and blank pages in the PDF
files, which makes the document longer by increasing the number of pages in the document and
could make using the instructions less efficient for users accessing the instructions electronically.
Therefore, the agenciessought comment on the benefits and burdens, if any, of maintaining the
PDF format of the instructions and updates only instead of continuing to support the binder
format.
Optional Tax Worksheet
Each quarter the FFIEC and FDIC make available on their websites the optional tax
worksheet, which is designed to assist certain institutions in the calculation of applicable income
taxes for the year-to-date reporting period on the FFIEC 041 and FFIEC 051 Call Reports.
Institutions are not required to use the optional tax worksheet and may use any reasonable
approach for reporting applicable income taxes in their Call Report in accordance with
Accounting Standards Codification (ASC) Topic 740, Income Taxes. The optional worksheet
provides a simplified approach for calculating year-to-date applicable income taxes under ASC
Topic 740. It should not be used by institutions that prepare quarterly financial statements in
accordance with U.S. generally accepted accounting principles (GAAP) or where it will likely
result in significantly lower applicable income taxes than as calculated under U.S. GAAP. In
addition, the worksheet should not be used by institutions that are, for federal income tax
purposes, either “S corporations” or “qualified subchapter S subsidiaries” as of June 30, 2022,
and that are generally not subject to federal corporate income taxes. The agencies have
determined that a limited number of institutions are accessing the optional tax worksheet on the
applicable websites. Therefore, the agenciessought comment on the continued usefulness of the
optional tax worksheet to Call Report filers or other stakeholders and any concerns if the
agencies discontinue its publication.

14

There is a combined set of instructions for the FFIEC 031 and FFIEC 041 and a separate set of instructions for the
FFIEC 051.

7

Clarification of Federal Home Loan Mortgage Corporation and Other
Securitization Structures
The Federal Home Loan Mortgage Corporation (FHLMC or Freddie Mac) may acquire
and securitize guaranteed bonds that are issued by third party trusts and backed by multifamily
loans through a variety of structures, such as “K-Deals” and “Q-Deals”.15 The June 2022 Call
Report instruction book update and Supplemental Instructions included a technical clarification,
indicating that structured financial products that are guaranteed by U.S. government-sponsored
enterprises, such as K-Deals and Q-Deals issued by Freddie Mac, are to be reported in Schedule
RC-B, Securities, item 5.b, “Structured financial products.” The agencies made this technical
clarification to promote consistent reporting treatment after receiving several inquiries on where
to report these products. The agencies viewed item 5.b as the most appropriate location to report
these products consistent with the pre-existing instructions. However, the agencies subsequently
received additional inquiries about reporting Freddie Mac K-Deals and Q-Deals and other
structured products in Schedule RC-B, including whether to report the related certificates in
Schedule RC-B, item 4, “Mortgage-backed securities (MBS).” Therefore, the agenciessought
comment on the reporting of these types of structured financial products including those issued
or guaranteed by U.S. government or government-sponsored enterprises.
Timing
The proposed revisions to the Call Reports would first take effect as of the June 30, 2023,
report date. The agencies invited comment on any difficulties that institutions would expect to
encounter in implementing the systems changes necessary to accommodate the proposed
revisions to the Call Reports consistent with this effective 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 FRA, which requires state member banks to file reports of
condition and of the payment of dividends with the Federal Reserve (12 U.S.C. § 324), and
section 11(a)(2) of the FRA, which authorizes the Board to require depository institutions to
submit reports of their liabilities and assets as the Board may determine to be necessary or
15

See https://mf.freddiemac.com/investors/k-deals and https://mf.freddiemac.com/investors/q-deals.

8

desirable to enable the Board to discharge its responsibility to monitor and control monetary and
credit aggregates (12 U.S.C. § 248(a)(2)). 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 has 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
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, be 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 and Current Proposal
On February 21, 2023, the agencies, under the auspices of the FFIEC, published an initial
notice in the Federal Register (88 FR 10644) requesting public comment for 60 days on the
extension, with revision, of the Call Reports. The comment period for this notice expired on
April 24, 2023. The agencies received three comments on the February notice.
Statutorily Mandated Review
As a result of the statutorily mandated review required by Section 604 of the of the
Financial Services Regulatory Relief Act of 2006, the agencies identified multiple items for

9

removal or consolidation. These items related to FDIC loss-sharing agreements, negative
amortization loans, reverse mortgages, and the MMLF.
One commenter generally supported the removal of items no longer necessary in
connection with the statutorily mandated review. This commenter also requested removal of
Schedule RC-C, Memorandum items 17.a and 17.b, which collect information regarding the
number and amount of loans modified pursuant to Section 4013 of the CARES Act.16 The
commenter noted that similar items previously were removed from bank holding company
reports. These items relate to loan modifications or restructurings, which the agencies are
planning to address in a more comprehensive proposal. Therefore, the agencies will retain these
items for now but will consider the commenter’s input when developing that proposal, which
will follow the standard notice and comment process pursuant to the Paperwork Reduction Act
(PRA).
After further deliberation and recent loss-share transactions established by the FDIC, the
agencies decided to retain and redesignate certain items related to FDIC loss-sharing agreements
that had been proposed for removal. These items are necessary solely for FDIC deposit insurance
assessment purposes. On the FFIEC 031 and FFIEC 041 Call Report forms, the retained items
are:
• Schedule RC-M, item 13.b.(7), “Portion of covered other real estate owned included in
items 13.b.(1) through (6) above that is protected by FDIC loss-sharing agreements.”
This item would be redesignated as item 13 and reflect the total of other real estate owned
that is protected by FDIC loss-sharing arrangements. The agencies still would discontinue
all other subitems of item 13, including subitems 13.b.(1) through 13.b.(6), 13.c and 13.d,
as this information is not necessary for deposit insurance assessment or other purposes.
• Schedule RC-N, item 12.f, “Portion of covered loans and leases included in items 12.a
through 12.e above that is protected by FDIC loss-sharing agreements” (Columns A, B,
and C). This item would be redesignated as item 12 and reflect the total of loans and
leases protected by FDIC loss-sharing arrangements. The agencies still would discontinue
subitems 12.a through 12.e, as this information is not necessary for deposit insurance
assessment or other purposes.
On the FFIEC 051, the agencies will also retain the following subitems of Schedule SU,
item 9.c, “Portion of past due and nonaccrual covered loans and leases that is protected by FDIC
loss-sharing agreements:”
• Schedule SU, item 9.c.(2), “Past due 90 days or more and still accruing.”
• Schedule SU, item 9.c.(3), “Nonaccrual.”
These items would be moved to Schedule RC-N, Past Due and Nonaccrual Loans,
Leases, and Other Assets, and redesignated as item 12, “Portion of loans and leases covered by
FDIC loss-sharing agreements,” with reporting in column B, “Past due 90 days or more and still
accruing” and column C, “Nonaccrual,” which would be consistent with the FFIEC 031 and
FFIEC 041 forms. The agencies still would discontinue the other subitems under Schedule SU,
item 9, FDIC Loss-Sharing Agreements, as this information is not necessary for deposit
16

Public Law 116–136, 4013 (2020).

10

insurance assessment or other purposes.
The agencies are proceeding with the removal or consolidation of the other items
described in the February notice. While the agencies had proposed removing these items as of
June 30, 2023, due to the time needed to update systems for the Call Reports, the agencies
instead propose to remove or consolidate the items related to negative amortization loans, reverse
mortgages, MMLF and FDIC loss-sharing agreements, as described above, effective as of the
September 30, 2023, report date.
Furthermore, to maintain consistency of reporting between the Call Report and the
FFIEC 002, the Board proposed in the February notice to remove from Schedule O, Other Data
for Deposit Insurance Assessments, Memorandum item 7, “Quarterly average amount of
holdings of assets purchased from money market funds under the Money Market Mutual Fund
Liquidity Facility” and intend to remove this item, also effective for the September 30, 2023,
report date.
Call Report Process Changes
In the February notice, the agencies had proposed changes to improve efficiency and
usability of the Call Report. Specifically, the agencies proposed providing the Call Report
instructions and the instructional updates using the PDF instead of the binder format and would
discontinue preparing the optional tax worksheet. No comments were received on these process
changes, and the agencies will discontinue the optional tax worksheet starting with the June 30,
2023, report date. The agencies are continuing to review alternatives to providing the Call Report
instructions and the instructional updates in a format other than the existing binder format.
Clarification of Reporting Certain Securitizations
In the February notice, the agencies had proposed a change to clarify reporting of certain
Federal Home Loan Mortgage Corporation and similar securitization structures that have
government guarantees in the Call Report. The agencies had proposed clarifying that these
securitizations should be reported in Schedule RC-B, Securities, item 5.b., “Structured financial
products.”
Two comments were received on this clarification. One comment opposed reporting of
these securities in Schedule RC-B, Securities, item 5.b, noting that this item includes a broad
range of structured financial products, and there would be a lack of clarity on the amount of
securities reported in this item that is guaranteed by a government or agency. The other comment
supported reporting these securities in item 5.b. However, the commenter also noted the lack of
transparency in this item regarding the proportion of securities with government guarantees. The
commenter requested that a subcategory be added to item 5.b to report the amount that was
guaranteed by the U.S. government or an agency. The agencies are continuing to review the
original clarification and the new item proposed by the commenter.

11

Other Comments Received
The agencies also received requests from two commenters on the Call Report that were
not specifically related to any of the proposed changes.
One commenter requested the agencies to provide clarification on how long an institution
would continue to report a loan subsequent to its modification that met the criteria in Accounting
Standards Update 2022-02, “Financial Instruments - Credit Losses (Topic 326): Troubled Debt
Restructurings and Vintage Disclosures’’ (ASU 2022-02) in the Call Report. The agencies plan
to propose revisions to the Call Report in response to ASU 2022-02 and will consider these
comments at that time. This proposal would follow the standard notice and comment process
pursuant to the PRA.
The other commenter requested that the agencies expand the level of detail on interest
and fee income collected in the Call Report on Schedule RI, Income Statement, to align with
each loan category reported on Schedule RC-C, Part I, Loans and Leases. The agencies are
declining to make any changes to the level of detail on loan income at this time. The current
level of detail strikes the appropriate balance between the information necessary for monitoring
the condition and performance of individual institutions and the industry with the effort required
by those organizations to separately collect and report interest and fee income information by
loan category.
Proposed Instructional Clarifications to Schedule RC-T
In response to questions received on the reporting of managed and non-managed assets
and number of managed and non-managed accounts on Schedule RC-T, Fiduciary and Related
Services, and to promote consistent reporting across all institutions, the agencies are proposing to
clarify the instructions for these items as of the September 30, 2023, report date. Specifically:
• Reporting of life insurance trusts. The agencies have observed inconsistent reporting of
life insurance trusts and are clarifying that life insurance trusts, other than term life
insurance policies that have nominal value, should be reported in Schedule RC-T, item 4,
“Personal trust and agency accounts.” Relatedly, the agencies are proposing to clarify in
the “Fiduciary and Related Assets” section of the Schedule RC-T instructions that the
cash surrender value of a life insurance policy generally may be used when calculating
the value of the account.
• Classification of investment advisory employee benefit accounts. The agencies have
observed inconsistent reporting of employee benefit accounts for which the institution
provides investment services or investment advice for a fee and whether those accounts
are classified as managed or non-managed in item 5, “Employee benefit and retirementrelated trust and agency accounts.” The agencies are proposing to clarify in Schedule
RC-T, items 5.a through 5.c, that accounts for which the institution serves as either
trustee or agent and provides investment management services, or provides investment
advice for a fee, should be reported in one of the subcategories of item 5. The agencies
are further proposing to clarify that accounts for which the institution serves as a directed
trustee or provides investment advice for a fee should be reported under non-managed
accounts. In addition, the agencies are proposing to clarify that employee benefit

12

•

•

accounts for which the institution provides investment management or investment
advisory services should not be reported in Schedule RC-T, item 7, “Investment
management and investment advisory agency accounts.”
Primary relationship test. The agencies have observed inconsistent reporting of trust
accounts for which the institution has both a fiduciary and custodial relationship. The
current instructions for Schedule RC-T, item 11, “Custody and safekeeping accounts”
indicate that the institution should report the account under the primary relationship. The
agencies are proposing to clarify in the instructions for this item that when an institution
has both a fiduciary and custodial relationship, the fiduciary relationship is the primary
relationship. In this case, the account should be reported as a fiduciary account in
Schedule RC-T, items 4 through 9, and it should not be reported as a custodial account in
item 11.
Back-office services. The agencies have received questions about whether accounts for
which the institution provides back-office or operational services for a third party, but
does not hold the account, should be reported along with custody and safekeeping
accounts. The agencies are proposing to revise the “Fiduciary and Related Assets”
section of the Schedule RC-T instructions to clarify that accounts for which the
institution only provides back-office or operational services and the accounts or assets are
not held by the institution should not be reported in Schedule RC-T.

The agencies are proposing to incorporate these clarifications starting with the September
30, 2023, report date. The agencies would expect institutions that are not currently reporting
consistent with these clarifications to incorporate the clarifications on a best-efforts basis over
the four subsequent quarterly reports.
Timing
The revisions to the Call Report resulting from the statutorily mandated full review
related to certain loss-sharing agreements with the FDIC, negative amortization loans, reverse
mortgages, and MMLF items, and the proposed clarifications to the instructions for Schedule
RC-T, will be effective as of the September 30, 2023, report date, subject to OMB approval. The
agencies plan to discontinue the optional tax worksheet as part of the implementation of the Call
Report process changes starting with the June 30, 2023, report date.
On June 13, 2023, the agencies, under the auspices of the FFIEC, published a final notice
in the Federal Register (88 FR 38592) requesting public comment for 30 days on the extension,
with revision, of the Call Reports. The comment period for this notice expires on July 13, 2023.
Estimate of Respondent Burden
As shown in the table below, the estimated total annual burden for the Call Reports is
127,554 hours, and would decrease to 123,387 hours with the proposed revisions. The estimated
average hours per response for the quarterly filings of the Call Reports is a weighted average of
the three versions of the Call Reports (FFIEC 031, FFIEC 041, and FFIEC 051). Both the
weighted average Call Report burden estimate and the three separate versions of the Call Reports
vary by agency because of differences in the composition of the institutions under each agency’s

13

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, and would not incur any burden. These reporting requirements represent 1.8
percent of the Board’s total paperwork burden.
FFIEC 031, FFIEC 041, and
FFIEC 051
Current
Proposed

Estimated
number of
respondents17

Estimated
annual
frequency

Estimated
average hours
per response

Estimated
annual burden
hours

699
699

4
4

45.62
44.13

127,554
123,387
(4,167)

Change

The estimated total annual cost to the public for the Call Reports is $8,450,453, and
would decrease to $8,174,389 with the proposed revisions.18
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 $2,163,300 per year.

17

Of these respondents, 200 are considered small entities as defined by the Small Business Administration (i.e.,
entities with less than $850 million in total assets), https://www.sba.gov/document/support-table-size-standards.
18
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 $22, 45% Financial Managers at
$80, 15% Lawyers at $79, and 10% Chief Executives at $118). Hourly rates for each occupational group are the
(rounded) mean hourly wages from the Bureau of Labor Statistics (BLS), Occupational Employment and Wages,
May 2022, published April 25, 2023, https://www.bls.gov/news.release/ocwage.t01.htm. Occupations are defined
using the BLS Standard Occupational Classification System, https://www.bls.gov/soc/.

14