FFIEC 031, FFIEC 041, and FFIEC 051 18 Question Format OMB Supporting Statement

Supporting Statement for the
Consolidated Reports of Condition and Income
(FFIEC 031, FFIEC 041, and FFIEC 051; OMB No. 7100-0036)
1.

Explain the circumstances that make the collection of information necessary.

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.

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2

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

2.

Indicate how, by whom, and for what purpose the information is to be used. Except
for a new collection, indicate the actual use the agency has made of the information
received from the current 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. 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 insured
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.4 Such
data is generally required to be reported for the holding company on a consolidated basis,
including its banking and nonbanking subsidiaries, and on a parent-company-only basis. Data
collected from bank holding companies on a consolidated basis reflect aggregate amounts for all
entities within the organization, including banking and nonbanking subsidiaries, so that the actual
dollar amounts applicable to any banking subsidiary would not be determinable from the holding
company reporting information. Therefore, reports collected from bank holding companies lack
the data necessary to assess the financial condition of individual banks to determine whether there
had been any deterioration in their condition.
Banks are required to transmit their Call Report data electronically. Each bank must
maintain in its files for three years a signed and attested record of its completed report each
3

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
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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quarter.
3.

Describe whether, and to what extent, the collection of information involves the use
of automated, electronic, mechanical, or other technological collection techniques or
other forms of information technology.

Banks are required to transmit their Call Report data electronically. The agencies have
created the Central Data Repository (CDR) as the only method available to banks and savings
associations for submitting their Call Report data. Under the CDR system, institutions file their
Call Report data via the Internet using software that contains the FFIEC’s edits for validating
Call Report data before submission.
4.

Describe efforts to identify duplication. Show specifically why any similar
information already available cannot be used or modified for use for the purposes
described in Item 2 above.

There is no other report or series of reports that collects from all insured banks and
savings associations the regulatory capital and other information gathered through the Call
Reports as a whole. There are other information collection systems that tend to duplicate certain
parts of the Call Report, but the information they provide would be of limited value as a
replacement for the Call Report.
5.

If the collection of information impacts small businesses or other small entities,
describe any methods used to minimize burden.

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. Data collected
in the Call Report information collection is tiered to the size and activity levels of reporting
institutions.
The Call Report requires the least amount of data from small institutions with domestic
offices only and less than $5 billion in total assets that file the streamlined FFIEC 051 report
form. Certain institutions with less than $300 million in total assets have fewer items applicable
to them than do institutions with $300 million to $1 billion in assets. In addition, the
supplemental information schedule in the FFIEC 051, which replaced five entire schedules and
parts of certain other schedules that had been in the FFIEC 041, includes nine indicator questions
with “yes”/”no” responses that ask about an institution’s involvement in certain complex or
specialized activities. Only if the response to a particular indicator question is a “yes” is an
institution required to complete an average of three indicator items that provide data on the
extent of the institution’s involvement in that activity.
Exemptions from reporting certain Call Report data within the FFIEC 041 report form
also apply to institutions with less than $500 million, $1 billion, and $10 billion in total assets. In
both the FFIEC 051 and the FFIEC 041, other exemptions are based on activity levels rather than
total assets and these activity-based thresholds tend to benefit small institutions. In addition, for

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small institutions with domestic offices only and less than $1 billion in total assets that file the
FFIEC 051, a significant number of data items in the FFIEC 051 report are collected
semiannually or annually rather than quarterly as they had been when these institutions filed the
FFIEC 041 report.
6.

Describe the consequence to Federal program or policy activities if the collection is
not conducted or is conducted less frequently, as well as any technical or legal
obstacles to reducing burden.

The agencies must have condition and income data at least quarterly to properly monitor
individual bank and industry trends and to comply with a statutory requirement to obtain four
reports of condition per year. Less frequent collection of this information would impair the
agencies’ ability to monitor financial institutions and could delay regulatory response.
7.

Explain any special circumstances that would cause an information collection to be
conducted in a manner inconsistent with 5 CFR 1320.5(d)(2).

This information collection is conducted in a manner consistent with the guidelines in 5
CFR 1320.5(d)(2).
8.

Describe comments in response to the Federal Register notice and efforts to consult
outside the agency.

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,

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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.
9.

Explain any decision to provide any payment or gift to respondents, other than
remuneration of contractors or grantees.
There are no payments or gifts provided to respondents.

10.

Describe any assurance of confidentiality provided to respondents and the basis for
the assurance in statute, regulation, or agency policy. If the collection requires a
systems of records notice (SORN) or privacy impact assessment (PIA), those should
be cited and described here.

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.”

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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)).
11.

Provide additional justification for any questions of a sensitive nature.
There are no questions of a sensitive nature.

12.

Provide estimates of the annual hourly burden of the collection of information.

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
respondents

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.
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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13.

Provide an estimate for the total annual cost burden to respondents or record
keepers resulting from the collection of information.
There are no annualized costs to the respondents.

14.

Provide estimates of annualized costs to the Federal government.

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.
15.

Explain the reasons for any program changes or adjustments reported on the
burden worksheet.

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
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.5
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.6 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
5

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).
6

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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.
16.

Provide information regarding plans for publication 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.
17.

If seeking approval to not display the expiration date for OMB approval of the
information collection, explain the reasons that display would be inappropriate.
No such approval is sought.

18.

Explain each exception to the topics of the certification statement identified in
“Certification for Paperwork Reduction Act Submissions.”
There are no exceptions.

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