OCC, FRB, FDIC Seek Comment on Proposed Changes to Call Reports

The OCC, FRB, and FDIC recently published a joint notice and request for comment on proposed changes to the information reported on the Consolidated Reports of Condition and Income (Call Reports) (FFIEC 031, FFIEC 041, and FFIEC 051) for banks and savings associations, with comments due by November 27, 2023.  In addition to proposed changes in how these institutions report loan modifications to borrowers experiencing financial difficulty, the agencies are proposing changes to reporting requirements for institutions on the websites and trade names they use to solicit deposits.

In the Call Reports, for the “URL of the reporting institution’s primary internet website (home page), if any,” institutions would not report URLs of affiliates that are not insured depository institutions.  For “URLs of all other public-facing internet websites that the reporting institution uses to accept or solicit deposits from the public, if any”, institutions would only report URLs of public-facing internet websites operated by the reporting FDIC-insured depository institution and not websites of any non-bank entity (including any third parties that accept or solicit deposits from the public on behalf of the reporting FDIC-insured depository institution).  For “Trade names other than the reporting institution’s title used to identify one or more of the institution’s physical offices at which deposits are accepted or solicited from the public, if any”, institutions would not report any non-bank affiliates or subsidiaries regardless of whether these entities solicit deposits.  In addition, FFIEC 051 filers would report on these items quarterly rather than semi-annually, matching the frequency for FFIEC 031 and FFIEC 041 filers.

Specific to these changes, the agencies are seeking comment on (1) whether the phrase “operated by” captures the appropriate population of URLs used by FDIC-insured depository institutions; (2) whether the proposed instructions clearly distinguish reporting deposit-accepting activities of the institution under its own websites and trade names while excluding URLs used by third parties that facilitate pass-through insurance; and (3) the additional burden, if any, from FFIEC 051 filers reporting on these items on a quarterly basis.