FFIEC031_FFIEC041_FFIEC051_20250729_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 depository
institutions 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.
On September 28, 2023, the agencies, under the auspices of the FFIEC, requested public
comment for 60 days on a proposal to revise the Call Reports.1 The proposed revisions included
changes to the Call Report forms and instructions that were in response to the Financial
Accounting Standards Board’s (FASB) Accounting Standards Update (ASU) 2022-02,
“Financial Instruments - Credit Losses (Topic 326): Troubled Debt Restructurings and Vintage
Disclosures” (ASU 2022-02). After considering the comments received on the proposal, the
FFIEC and the agencies on May 22, 2024, finalized certain proposed revisions resulting from
ASU 2022-02, but deferred action related to the length of time that loan modifications to
borrowers experiencing financial difficulty would be reported in the Call Report forms.2 The
agencies have now completed their review and are revising the instructions to align the
regulatory reporting of loan modifications to borrowers experiencing financial difficulty with
U.S. generally accepted accounting principles (GAAP). These revisions would be effective as of
the December 31, 2025, report date. However, the agencies do not object if an institution chooses
to implement this revised reporting in advance of the effective date for the September 30, 2025,
report date.
The current estimated total annual burden for the Call Reports is 128,272 hours, and
would increase to 128,499 hours. The proposed revisions would result in an increase of 227
hours. The forms and instructions are available on the FFIEC’s public website at
https://www.ffiec.gov/resources/reporting-forms.

1
2

88 FR 66933 (September 28, 2023).
89 FR 45046 (May 22, 2024).

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 is 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 051.3
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.4 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.

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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.
4
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).

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The Board also collects financial data from holding companies on a regular basis.5 Such
data is generally required to be reported for the holding company on a consolidated basis,
including its banking and nonbanking subsidiaries, and on a parent-company-only basis. Data
collected from bank holding companies on a consolidated basis reflect aggregate amounts for all
entities within the organization, including banking and nonbanking subsidiaries, so that the
actual dollar amounts applicable to any banking subsidiary would not be determinable from the
holding company reporting information. Therefore, reports collected from bank holding
companies lack the data necessary to assess the financial condition of individual banks to
determine whether there 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.
Proposed Revisions
In the September 2023 notice, the agencies proposed revisions to all three versions of the
Call Report (FFIEC 031, FFIEC 041, and FFIEC 051) related to FASB’s ASU 2022-02. As
proposed, institutions would have reported loan modifications to borrowers experiencing
financial difficulty for a minimum period of 12 months after modification and until an institution
performs a current, well documented credit evaluation to support that the borrower is no longer
experiencing financial difficulty, unless the loan is paid off, charged-off, sold, or otherwise
settled. This may have been for a period longer than financial statement disclosures required by
5

The Board collects standardized financial statements through one or more of the Financial Statements for Holding
Companies (FR Y-9; OMB No. 7100-0128) series.

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ASU 2022-02. ASU 2022-02 requires that for each period for which a statement of income is
presented, an entity shall disclose by class of financing receivable, qualitative and quantitative
information about receivable performance in the 12 months after a modification of a receivable
made to a debtor experiencing financial difficulty.6
The comment period for the September 2023 notice ended on November 27, 2023. The
agencies received six comment letters on the September 2023 notice, four of which included
objections to the proposed length of time for which these modifications would be reported on the
Call Report.7 These commenters indicated that the divergence from GAAP financial statement
disclosure requirements in accordance with ASU 2022-02 would create additional costs,
complexity, and operational challenges without any substantial corresponding benefit to either
the institutions or the agencies. The agencies deferred action on the length of time for which
these modifications would be reported pending additional review of the proposal and the
commenters’ concerns. Current Call Report forms collect data on loan modifications to
borrowers experiencing financial difficulty and the instructions define the types of loan
modifications to be reported but do not prescribe a specific duration for reporting such
modifications.
The agencies have completed their evaluation of the comments received. The agencies
determined that consistency with the GAAP financial statement disclosure requirements under
ASU 2022-02 would provide sufficient supervisory data on loan modifications due to the
debtor’s financial difficulty. Therefore, the agencies will revise the Call Report instructions to
indicate that institutions should only report those loans that have been modified in the previous
12 months consistent with FASB ASC paragraph 310-10-50-42.
The agencies will revise Schedule RC-C, Loans and Lease Financing Receivables, Part I,
Loans and Leases, Memoranda item 1, “Loan modifications to borrowers experiencing financial
difficulty that are in compliance with their modified terms (included in Schedule RC-C, Part I,
and not reported as past due or nonaccrual in Schedule RC-N, Memorandum item 1),” and
Schedule RC-N, Past Due and Nonaccrual Loans, Leases, and Other Assets, Memoranda item 1,
“Loan modifications to borrowers experiencing financial difficulty included in Schedule RC-N,
items 1 through 7, above (and not reported in Schedule RC-C, Part I, Memorandum item 1)” to
align reporting of loan modifications to borrowers experiencing financial difficulty, as described
in ASU 2022-02. Specifically, modified loans reported in these items should meet the definition
of loan modifications to borrowers experiencing financial difficulty, as described in ASU 202202, and include only such modifications which occurred in the previous 12 months.
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,
6

See FASB ASC paragraph 310-10-50-42.
Comments other than those related to the proposed length of time for which modifications would be reported have
been addressed by FFIEC and the agencies in a prior notice (89 FR 45046, May 22, 2024).
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upon request approximately twelve weeks after the report date. Data are also available from the
FFIEC Central Data Repository Public Data Distribution (CDR PDD) website
(https://cdr.ffiec.gov/public/). Data for the current quarter are made available, shortly after a
bank’s submission, beginning the first calendar day after the report date. Updated or revised data
may replace data already posted at any time thereafter.
Legal Status
The Board is authorized to collect information on the Call Reports from state member
banks pursuant to section 9 of the Federal Reserve Act (12 U.S.C. § 324), which requires state
member banks to file reports of condition and of the payment of dividends with the Federal
Reserve, and section 11(a)(2) of the Federal Reserve Act (12 U.S.C. § 248(a)(2)), which
authorizes the Board to require depository institutions to submit reports of their assets and
liabilities as the Board may determine to be necessary or desirable to enable the Board to
discharge its responsibility to monitor and control monetary and credit aggregates. The
obligation for state member banks to respond is mandatory.
Most of the information provided on the Call Reports is made public. However, the
following items are confidential: any amount reported on Schedule RI-E, item 2.g, “FDIC
deposit insurance assessments,” for report dates beginning June 30, 2009; Schedule RC-O,
Memorandum items 6 through 9, 14, and 15, for certain assessment-related data for report dates
beginning June 30, 2011; Schedule RC-O, Memorandum item 18, for two-year probability of
default data for 1-4 family residential mortgage loans and consumer loans and leases for report
dates beginning June 30, 2013; Schedule RC-P, items 7.a and 7.b, for representation and
warranty reserves for 1-4 family residential mortgages sold made to specified parties for report
dates beginning June 30, 2012; and Schedule RC-C, Part I, Memorandum items 17.a and 17.b,
for eligible loan modifications under Section 4013 of the 2020 Coronavirus Aid, Relief, and
Economic Security Act for report dates beginning June 30, 2020. 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 item and the prepaid deposit insurance assessments data item. If this
information were publicly available, it would be possible to determine the state member bank’s
CAMELS rating. Therefore, this information can 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.”
Additionally, to the extent any information contained in the call report is confidential
commercial or financial information, which is both customarily and actually treated as private by
the respondent, the respondent may request confidential treatment pursuant to exemption 4 of the
FOIA (5 U.S.C. § 552(b)(4)).

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Consultation Outside the Agency
The Board coordinated and consulted with the FDIC and OCC in developing these
revisions as part of the FFIEC approval process.
Public Comments
On September 28, 2023, the agencies, under the auspices of the FFIEC, published an
initial notice in the Federal Register (88 FR 66933) requesting public comment for 60 days on
the extension, with revision, of the Call Reports. The comment period for this notice expired on
November 27, 2023. The agencies received six comment letters on the September 2023 notice,
four of which included objections to the proposed length of time for which these modifications
would be reported on the Call Report. These commenters indicated that the divergence from
GAAP financial statement disclosure requirements in accordance with ASU 2022-02 would
create additional costs, complexity, and operational challenges without any substantial
corresponding benefit to either the institutions or the agencies. The agencies deferred action on
the length of time for which these modifications would be reported pending additional review of
the proposal and the commenters’ concerns. Current Call Report forms collect data on loan
modifications to borrowers experiencing financial difficulty and the instructions define the types
of loan modifications to be reported but do not prescribe a specific duration for reporting such
modifications.
The agencies have completed their evaluation of the comments received. The agencies
determined that consistency with the GAAP financial statement disclosure requirements under
ASU 2022-02 would provide sufficient supervisory data on loan modifications due to the
debtor’s financial difficulty. Therefore, the agencies will revise the Call Report instructions to
indicate that institutions should only report those loans that have been modified in the previous
12 months consistent with FASB ASC paragraph 310-10-50-42.
The agencies will revise Schedule RC-C, Loans and Lease Financing Receivables, Part I,
Loans and Leases, Memoranda item 1, “Loan modifications to borrowers experiencing financial
difficulty that are in compliance with their modified terms (included in Schedule RC-C, Part I,
and not reported as past due or nonaccrual in Schedule RC-N, Memorandum item 1),” and
Schedule RC-N, Past Due and Nonaccrual Loans, Leases, and Other Assets, Memoranda item 1,
“Loan modifications to borrowers experiencing financial difficulty included in Schedule RC-N,
items 1 through 7, above (and not reported in Schedule RC-C, Part I, Memorandum item 1)” to
align reporting of loan modifications to borrowers experiencing financial difficulty, as described
in ASU 2022-02. Specifically, modified loans reported in these items should meet the definition
of loan modifications to borrowers experiencing financial difficulty, as described in ASU 202202, and include only such modifications which occurred in the previous 12 months. The
proposed revisions to the Call Report instructions are proposed to become effective with the
December 31, 2025, report date. On July 11, 2025, the agencies, under the auspices of the
FFIEC, published a final notice in the Federal Register (90 FR 31111) requesting public
comment for 30 days on the extension, with revision, of the Call Reports. The comment period
for this notice expires on August 11, 2025.

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Estimate of Respondent Burden
As shown in the table below, the estimated total annual burden for the Call Reports is
128,272 hours, and would increase to 128,499 hours with the proposed revisions. The increase in
burden reflect a shift in respondents moving between the FFIEC 031, FFIEC 041, and
FFIEC 051. 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 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 1.7 percent of the Board’s total paperwork burden.
FFIEC 031, FFIEC 041, and
FFIEC 051
Current
Proposed

Estimated
number of
respondents8

Estimated
annual
frequency

Estimated
average hours
per response

Estimated
annual burden
hours

709
709

4
4

45.23
45.31

128,272
128,499
227

Change

The estimated total annual cost to the public for the Call Reports is $9,254,825, and
would increase to $9,271,203 with the proposed revisions.9
Sensitive Questions
This information collection 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.

8

Of these respondents, 460 are considered small entities as defined by the Small Business Administration (i.e.,
entities with less than $850 million in total assets). Size standards effective March 17, 2023. See
https://www.sba.gov/document/support-table-size-standards.
9
Total cost to the responding public is estimated using the following formula: total burden hours, multiplied by the
cost of staffing, where the cost of staffing is calculated as a percent of time for each occupational group multiplied
by the group’s hourly rate and then summed (30% Office & Administrative Support at $24, 45% Financial
Managers at $87, 15% Lawyers at $88, and 10% Chief Executives at $126). Hourly rates for each occupational
group are the (rounded) mean hourly wages from the Bureau of Labor Statistics (BLS), Occupational Employment
and Wages, May 2024, published April 2, 2025, https://www.bls.gov/news.release/ocwage.t01.htm. Occupations are
defined using the BLS Standard Occupational Classification System, https://www.bls.gov/soc/.

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