Joint Trade Letter on Deposit-Related Revisions to Call Reports and FFIEC 002

Chief Counsel’s Office
Office of the Comptroller of the Currency
400 7th Street, SW, Suite 3E-218
Washington, D.C. 20219

Ann E. Misback, Secretary
Board of Governors of the Federal Reserve System
20th Street and Constitution Avenue, NW
Washington, D.C. 20551

Manuel E. Cabeza, Counsel
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, D.C. 20429

To Whom it May Concern:

The Bank Policy Institute, the Securities Industry and Financial Markets Association, and the American Bankers Association (collectively, the Associations) welcome the opportunity to comment on the proposal by the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency regarding revisions to the Consolidated Reports of Condition and Income (Call Reports) (FFIEC 031, FFIEC 041, and FFIEC 051). The Associations understand the agencies’ need to evaluate the behavior of sweep accounts in order to determine their appropriate treatment under liquidity regulations and are generally supportive of the agencies’ further research into and analysis of funding stability and the behavior of bank counterparties over time. However, firms have concerns with the proposed new reporting items, specifically that the revisions are duplicative of existing reporting requirements for many firms, as well as the proposed implementation timeline. Our other comments herein highlight areas of the proposal related to the reporting treatment of certain deposits consistent with changes in the brokered deposits final rule and definitions that require further clarification from the agencies.

Download the comment letter to read the full text.