Supporting Statement A

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09-11-2026
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 revise 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) under the emergency clearance
provisions of OMB’s regulations. 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.
The agencies, under the auspices of the FFIEC, propose to revise to the Call Report by
implementing changes to the general cap and the definition of agent institution. These revisions
would be effective as of the September 30, 2026, report date.
The current estimated total annual burden for the Call Reports is 127,492 hours, and
would not change with the proposed revisions. The forms and instructions are available on the
FFIEC’s public website at https://www.ffiec.gov/resources/reporting-forms.
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 051.1
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
companies lack the data necessary to assess the financial condition of individual banks to
determine whether there has been any deterioration in their condition.

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.

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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
The agencies propose under the emergency clearance provisions of OMB’s regulations to
revise the Call Reports for the September 30, 2026, report date. The agencies have determined
that (1) the collection of information within the scope of this request is needed prior to the
expiration of time periods established under 5 CFR 1320.10, (2) this collection of information is
essential to the mission of the agencies, and (3) the agencies cannot reasonably comply with the
normal clearance procedures because an unanticipated event has occurred and the use of normal
clearance procedures is reasonably likely to prevent or disrupt the collection of information.
These revisions arise from congressional enactment of the 21st Century ROAD to
Housing Act (the Housing Act).4 Section 902 of the Housing Act amends section 29(i) of the
Federal Deposit Insurance Act (FDI Act), resulting in two changes to the limited exception for
reciprocal deposits. First, the Housing Act expands the scope of institutions that may qualify to
except an amount of reciprocal deposits from treatment as brokered deposits. Second, the
Housing Act changes the calculation for determining the amount of reciprocal deposits a
qualifying institution may treat as not brokered. These provisions became effective automatically
when the law was signed on July 11, 2026.
The agencies must receive data from the quarterly Call Reports as part of their shared
4

Pub. L. No. 119-101, 140 Stat. 846 (July 11, 2026).

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missions of ensuring the safety and soundness of financial institutions and the financial system
and the protection of consumer financial rights as well as agency-specific missions affecting
national and state-chartered institutions, including the administration of federal deposit
insurance. The next reports are due from the end of September 2026 through early October 2026
based on information available as of September 30, 2026. In order for the agencies to implement
Section 902 of the Housing Act, the agencies cannot comply with the normal clearance process
and still receive the September 30, 2026, financial data in a timely manner.
Reciprocal Deposits
Section 29 of the FDI Act restricts an insured depository institution from accepting
deposits by or through a deposit broker unless the institution is well capitalized. A “deposit
broker,” as defined by section 29 of the FDI Act, includes “any person engaged in the business
of placing deposits, or facilitating the placement of deposits, of third parties with insured
depository institutions or the business of placing deposits with insured depository institutions for
the purpose of selling interests in those deposits to third parties[.]” Under the FDIC’s regulations,
a “brokered deposit” is thus defined as “any deposit that is obtained, directly or indirectly, from
or through the mediation or assistance of a deposit broker.”
Reciprocal deposits are a subset of brokered deposits and must be reported as brokered
unless an exception applies. Section 29 of the FDI Act permits “agent institutions” to except an
amount of reciprocal deposits from being reported as brokered. The Housing Act amended the
first prong of the definition of agent institution, which previously required that an institution be
rated “outstanding or good,” to instead require that an institution be assigned a CAMELS
composite rating of “1,” “2,” or “3.” Accordingly, well-capitalized institutions rated ‘3’ now
qualify as agent institutions and may report in accordance with the general cap.
The Housing Act also amended the amount and calculation method of the general cap.
Specifically, the Housing Act provides that the general cap is the sum of:
(1) 50 percent of the portion of the total liabilities of the agent institution that is less than
or equal to $1,000,000,000,
(2) 40 percent of the portion, if any, of the total liabilities of the agent institution that is
greater than $1,000,000,000, but less than or equal to $10,000,000,000, and
(3) 30 percent of the portion, if any, of the total liabilities of the agent institution that is
greater than $10,000,000,000, but less than or equal to $96,333,333,333.
Accordingly, the maximum amount of reciprocal deposits now allowed under the
exception for any institution totals $30 billion, which would be the general cap for an institution
with $96.33 billion or more in total liabilities (assuming the institution is not limited to the
special cap). An institution with less than approximately $96.33 billion in total liabilities must
calculate its general cap using the new tiered methodology.
As Section 902 of the 21st Century ROAD to Housing Act expands the circumstances in

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which an institution may qualify for the reciprocal deposit exception, the related Call Report
revisions will require institutions to report total reciprocal deposits in Schedule RC-E,
Memorandum item 1.g, and the portion of those deposits that is not excepted from treatment as
brokered deposits in Schedule RC-O, item 9, and, if applicable, item 9.a. Because the amounts
reported in Schedule RC-O, items 9 and 9.a, may change based on an institution’s eligibility for
the exception, application of the applicable cap, or supervisory status, disclosure of those
amounts—particularly when compared with the institution’s total reciprocal deposits—could
reveal nonpublic supervisory information. Accordingly, the agencies propose to establish a new
confidentiality exception for the amounts reported in Schedule RC-O, items 9 and 9.a.
Schedule RC-O, item 9, reports the amount of an institution’s reciprocal deposits that are
not excepted from treatment as brokered deposits under the FDIC’s reciprocal deposit regulation.
Item 9.a reports the corresponding amount on a fully consolidated basis for an institution that
owns another insured depository institution.
The agencies propose to keep these amounts confidential because, when considered
together with the amount reported in Schedule RC-E, Memorandum item 1.g, “Total reciprocal
deposits,” they may reveal nonpublic supervisory information about an institution.
An agent institution that qualifies for the reciprocal deposit exception generally may
exclude qualifying reciprocal deposits from treatment as brokered deposits, subject to the
applicable general or special cap. If an institution no longer qualifies as an agent institution, or if
an institution subject to the special cap receives reciprocal deposits in excess of the special cap,
the institution must report all of its reciprocal deposits as brokered reciprocal deposits in
Schedule RC-O, item 9, rather than reporting only the amount above the applicable cap. As a
result, the amount reported in Schedule RC-O, item 9, could increase substantially from one
quarter to the next while the institution’s total reciprocal deposits reported in Schedule RC-E,
Memorandum item 1.g, remain relatively unchanged.
The relationship between these two items could allow the public to infer that an
institution no longer qualifies for the reciprocal deposit exception, has become subject to the
special-cap provisions, or has exceeded the applicable cap. In addition, because an institution
that is well capitalized generally must have a CAMELS composite rating of “1,” “2,” or “3” to
qualify as an agent institution, a significant change in the amount reported in Schedule RC-O,
item 9, when viewed together with Schedule RC-E, Memorandum item 1.g, could permit an
observer to infer the institution’s confidential supervisory rating.
The same concerns apply to the amount reported in Schedule RC-O, item 9.a, although
that item presents brokered reciprocal deposits on a fully consolidated basis. Public disclosure of
item 9.a could similarly reveal nonpublic information concerning an institution’s or consolidated
organization’s eligibility for the reciprocal deposit exception and supervisory status.
Accordingly, the agencies propose to treat amounts reported in Schedule RC-O, items 9 and 9.a,
as confidential on an individual institution basis.

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Proposed Revisions to the Call Report and Call Report Forms
The revisions update the instructions for existing Call Report items and related glossary
definitions. No separate form or filing requirement will be created. The proposed changes are as
follows:
•

Brokered reciprocal deposits. The agencies revised the instructions for Schedule RC-E,
Memorandum item 1.b, “Total brokered deposits,” and Schedule RC-O, item 9,
“Brokered reciprocal deposits,” to conform to the statutory and regulatory definition of
brokered reciprocal deposits. Brokered reciprocal deposits are reciprocal deposits that are
not excepted from an institution’s brokered deposits pursuant to the FDIC’s reciprocal
deposit regulation.

•

Definitions used in reporting reciprocal deposits. The revised instructions define and
cross-reference the terms “agent institution,” “covered deposit,” “deposit placement
network,” “network member bank,” and “reciprocal deposits.” For Call Report purposes,
reciprocal deposits are deposits received by an agent institution through a deposit
placement network with the same maturity, if any, and in the same aggregate amount as
covered deposits placed by the agent institution in other network member banks. A
covered deposit is a deposit submitted for placement through a deposit placement
network that does not consist of funds obtained for the agent institution, directly or
indirectly, by or through a deposit broker before submission for placement through the
network.

•

Agent institution eligibility. The revised instructions reflect the amended eligibility
standard for an agent institution. In accordance with section 902, an insured depository
institution may qualify under the applicable provision when it most recently was
examined under section 10(d) of the FDI Act and was assigned a composite CAMELS
rating of 1, 2, or 3 and was well capitalized. The instructions also address institutions that
have obtained an applicable waiver and institutions subject to the special-cap provisions.

•

Revised general cap. The revised instructions replace the prior general-cap calculation
with the tiered calculation established by section 902. An agent institution may except
reciprocal deposits from treatment as brokered deposits up to the sum of:
o 50 percent of the portion of the institution’s total liabilities that is less than or
equal to $1 billion;
o 40 percent of the portion of total liabilities that is greater than $1 billion but less
than or equal to $10 billion; and
o 30 percent of the portion of total liabilities that is greater than $10 billion but less
than or equal to $96,333,333,333.
Reciprocal deposits in excess of the applicable general cap must be reported as brokered
deposits.

•

Special Cap. The revisions update the special cap instructions to apply to institutions that
are not well capitalized or have been assigned a composite CAMELS rating of “4” or “5.”
The revisions further clarify that such an institution may still qualify as an agent

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institution if the total amount of reciprocal deposits it holds as of the end quarte end is at
or below the special cap.
•

Confidentiality of brokered reciprocal deposit amounts. The revisions include a note
stating that the amounts reported in Schedule RC-O items 9 and 9.a will not be made
available to the public on an individual basis.

•

Calculating the special cap examples. The revisions update the examples to illustrate
the special-cap calculation in the context of the amended reciprocal deposit framework.
The revised examples reflect the raised dollar thresholds for the general cap, which may
limit the amount of reciprocal deposits that can be treated as non-brokered by an
institution subject to the special cap.

Public Availability of Data
Aggregate data are published in the Federal Reserve Bulletin and the Annual Statistical
Digest. Additionally, data are used in the Uniform Bank Performance Report (UBPR) and the
Annual Report of the FFIEC. Individual respondent data, excluding confidential information, are
available to the public from the National Technical Information Service in Springfield, Virginia,
upon request approximately twelve weeks after the report date. Data are also available from the
FFIEC Central Data Repository Public Data Distribution (CDR PDD) website
(https://cdr.ffiec.gov/public/). Data for the current quarter are made available, shortly after a
bank’s submission, beginning the first calendar day after the report date. Updated or revised data
may replace data already posted at any time thereafter.
Legal Status
The Board is authorized to collect information on the Call Reports from state member
banks pursuant to section 9 of the Federal Reserve Act (12 U.S.C. § 324), which requires state
member banks to file reports of condition and of the payment of dividends with the Federal
Reserve, 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. Section 7 of
the Federal Deposit Insurance Act (12 U.S.C. § 1817) additionally requires insured depository
institutions to annually make four reports of condition to the appropriate Federal banking agency.
The appropriate Federal banking agency is the Board in the case of state member banks. 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

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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
FOIA (5 U.S.C. § 552(b)(4)).
Consultation Outside the Agency
The Board coordinated and consulted with the FDIC and OCC in proposing these
revisions. The agencies will follow this request for emergency processing with a request under
normal clearance procedures, during which comments will be solicited for the typical 60-day and
30-day periods. All comments received on paperwork burden, whether during the 60-day or 30day comment periods, will be considered in finalizing the collection.
Estimate of Respondent Burden
As shown in the table below, the estimated total annual burden for the Call Reports is
127,492 hours, and would not change 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
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
approximately 1.7 percent of the Board’s total paperwork burden.

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FFIEC 031, FFIEC 041, and
FFIEC 051
Current

Estimated
number of
respondents5

Estimated
annual
frequency

Estimated
average hours
per response

Estimated
annual burden
hours

705

4

45.21

127,492

The estimated total annual cost to the public for the Call Reports is $9,479,035.6
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 $2,505,000 per year.

5

Of these respondents, 434 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.
6
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 $25, 45% Financial
Managers at $90, 15% Lawyers at $89, and 10% Chief Executives at $130). Hourly rates for each occupational
group are the (rounded) mean hourly wages from the Bureau of Labor Statistics (BLS), Occupational Employment
and Wages, May 2025, published May 15, 2026, 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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