January 11, 2017
The Federal Financial Institutions Examination Council (FFIEC) recently finalized proposed reporting requirements of a streamlined call report available to small institutions beginning in the quarter ending March 31, 2017. Introduced as part of the burden-reduction efforts of the federal banking agencies, the FFIEC 051 form will be available to institutions with domestic offices only with total assets of less than $1 billion.
Reductions in Reporting
FFIEC 051 form reduces the number of existing pages in the call report from 85 to 61, while removing approximately 40 percent of the nearly 2,400 data items. Despite the reduction in pages and data items, the agencies recognize that not all community institutions eligible to file the FFIEC 051 will see an immediate or significant reduction in reporting burden. However, some of the more significant changes include reducing the reporting frequency of Schedule RC-C, Part II, Loans to Small Businesses and Small Farms from quarterly to semi-annually, and eliminating certain reporting requirements on derivative contracts reported on Schedule RC-L, Derivatives and Off-Balance Sheet Items.
Considerations for the New Form
The agencies are offering FFIEC 051 as an alternative reporting form to eligible small institutions that would otherwise file FFIEC 041. An institution's primary federal regulatory agency does reserve the right to require an institution to file the FFIEC 041 if the agency determines that the institution is significantly engaged in complex, specialized, or higher risk activities. If an institution chooses to adopt the FFEIC 051 form, the agencies expect the institution will continue to file that version of the report going forward as long as it remains eligible. Institutions considering adoption of the FFIEC 051 report should weigh the estimated time savings from using the new form with the one-time burden of switching to the FFIEC 051 form from the FFEIC 041 form.
The agencies are still engaged in the statutorily mandated review of the existing call report data items. The agencies are currently accumulating and reviewing data from additional surveys conducted as part of their burden-reduction efforts. Additional changes to the call report forms will be proposed in future Federal Register notices, with an anticipated implementation date of March 31, 2018.
Should you have any questions concerning the new FFEIC 051 form or any of the recently approved changes to FFIEC 031 and FFIEC 041, please contact your local Eide Bailly professional.