Call Report for Banks – Recent Changes, Highlights, and Pitfalls
In December, 2015 the Agencies announced the deferred implementation of proposed changes to the December 2015 Call Report.
Proposed revisions to the December, 2015 Call Report will be effective no sooner than the March 2016 Call Report. The Agencies propose deleting certain items on RI related to Other Than Temporary Impairment, and items on schedules RC-C and RC-N related to certain restructured loans.
New thresholds are proposed for reporting on RI-E, RC-F, and RC-G, along with additional preprinted captions. In addition, the Agencies propose increasing the deposit size threshold from $100,000 to $250,000 on RI, RC-E, and RC-K.
The Agencies are considering a less burdensome version of the Call Report for institutions that meet certain criteria. The Agencies visited with a limited number of banks during third quarter 2015 to see how the banks prepare their call report and where a significant amount of time and/or manual processes are required.
Basel III risk-based capital changes became effective with the first call report filing in 2015. The line items related to the Capital Conservation Buffer will have to be completed in March, 2016. Clarifications on the risk reporting of loan categories, unused commitments, and interest rate locks will be reviewed.
We’ll review the proposed changes, along with updates on some of the RC-R risk-based capital items, and any other announced changes or updates due to revisions in accounting standards.
March 2016 Proposed Revisions:
- Eliminating certain items on Other than temporary impairment, certain restructured loans, certain assets covered by loss sharing agreements
- Increases in reporting thresholds from $25,000 to $100,000 on RI-E, RC-D, RC-F, RC-G, RC-Q
- Instruction updates on:
- Home equity lines that convert from revolving to non-revolving
- Securities for which a fair value option is elected
- Net gains/losses and OTTI on equity securities that do not have readily determinable fair values
- Increasing deposit size threshold used to report certain deposit information from $100,000 to $250,000 in RC-E, RI, and RC-K
- Adding contact information for CEO
- Adding additional preprinted captions in RC-F and RI-E
- Revision of statements used to describe audit work on RC M1
- Deleting RI 11, extraordinary items
RC-R Risk Based Capital:
- New line items must be completed in 2016 for the Capital Conservation Buffer
- Clarifications on risk weighting of loan categories, unused commitments, and interest rate locks
This update will benefit more experienced Call Report preparers, reviewers, and auditors. It will supplement annual comprehensive Call Report training recommended by bank regulators.
Ann Thomas has thirty years of experience in bank accounting and control. She received a BA in Accounting from the University of Houston in 1982. From 1982 through 1997 she worked with Judith Alexander Jenkins, as Alexander & Associates and subsequently Alexander & Leavelle, providing planning, financial reporting, regulatory reporting, and operational and compliance auditing services to over ninety independent banks.
In 1998, she organized Thomas Consulting. At Thomas Consulting she now prepares bank plans, monthly financial reports, performs regulatory compliance audits and training and internal control audits for several banks. Additionally, she prepares and reviews Call Reports for several banks. Ms. Thomas has taught numerous call report seminars for state banking associations.
She has presented the Call Report Seminar to and has responded to questions from thousands of bankers in over 16 states. Her experience in working with a broad range of independent financial institutions is of unique value in understanding Call Report questions and in communicating with bankers in their language.
Institute of Certified Bankers: Visit http://www.icbmembers.org/login.aspx for instructions regarding self-reporting. Estimated credits: 2.5 CE Credits
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