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Banking Alert: Reduced Reporting for Covered Depository Institutions

June 26, 2019

By Charles V. Abraham

In June 2019, the Office of the Comptroller of the Currency (“OCC”), the Board of Governors of the Federal Reserve System (the “Board”), and the Federal Deposit Insurance Corporation (“FDIC”) (collectively the “Agencies”) issued a final rule (the “Rule”) to implement Section 205 of the Economic Growth, Regulatory Relief, and Consumer Protection Act (the “EGRRCPA”).

The EGRRCPA was enacted in May 2018. The Rule was published in the federal register on June 21, 2019 and will be effective on July 22, 2019.

In November 2018, the Agencies issued a proposed rule to reduce reporting for smaller non-complex financial institutions. The comment period on this proposal closed on January 18, 2019 with over 1,000 comments received. These ranged from statements that the proposed changes did not go far enough to reduce the regulatory burden; to concerns that this proposal would reduce the information available to analysts and the public. After considering the comments, the proposed rule was adopted as final by the Agencies.

What is a covered depository institution?

An institution that has less than $5 billion of consolidated assets (as of June 30th, of the preceding year); no foreign offices; is not an “advanced approaches” institution; and is not deemed to be a large/highly complex institution under the FDIC’s deposit insurance assessment regulations.

The fact that the asset threshold is measured based on the preceding year – provides a financial institution with time to transition if they fall above the threshold at June 30th, in any given year.

However, outside of the asset threshold, if the institution fails any other criteria, it becomes ineligible for reduced reporting as of the beginning of the quarter when it failed. The Agencies stated in the Rule, that this was not deemed to be of concern, because the other criteria would generally require significant planning, which would indicate that the transition time is built in already.

What does reduced reporting entail?

The Rule allows covered depository institutions to file their call report utilizing the FFIEC 051 form, which is the most streamlined version of the call report. In addition, the first and third quarter filing reporting for the FFIEC 051 report is further reduced in the supplementary information section (by changing certain quarterly data requirements to a semi-annual requirement). The Agencies estimate that 37% of quarterly data requirements have been reduced to semi-annual reporting.

Overall, the Agencies believe it will save nearly 13 hours per quarter for covered depository institutions between $1 billion and $5 billion in total assets. The reduced reporting would begin as of September 30, 2019 – and the asset threshold would be based on the total consolidated assets of the institution as of June 30, 2018.

If the institution that would fall under the reduced reporting requirements is not able to transition by September 30, 2019, they can continue to utilize the form they were previously utilizing for reporting, and transition to the reduced reporting at December 31, 2019.

Stay tuned for future updates on further implementations of sections of the EGRRCPA, any changes or amendments made, and the potential affect on financial institutions.

For more information contact Mazars USA’s banking practice at bankinggroup@mazarsusa.com.

 


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