- Community banks that are highly rated and well capitalized should be permitted to file abbreviated short-form call reports with only key financial information for the first and third quarters of the calendar year. At mid-year and year-end, these banks would file the full form call report.
- The agencies’ proposal to implement call report relief for community banks as required S. 2155 fails to provide adequate relief and falls well short of congressional intent.
- Recent expanded use of the community bank call report as an information gathering tool for consumer protection regulation damages the effectiveness of the information provided and diminishes the use of the call report as an effective safety and soundness measurement metric.
- A short-form call report with basic schedules such as the income statement, balance sheet, and changes in shareholders’ equity in the first and third quarters will reduce the time required to meet call reporting obligations and will assist in reducing the overall regulatory burden faced by community banks, without negatively impacting effective supervision and examination.
- Efforts by the Federal Financial Institution Examination Council (FFIEC) to streamline the call reporting process by community banks, while appreciated and supported, will not provide meaningful regulatory relief for community banks without the elimination of entire reporting schedules. The banking agencies have not provided a rationale for requiring highly detailed and specific data in each and every quarterly report.
Community banks with less than $1 billion in assets must complete 51 pages of call report forms each quarter. Banks above this threshold must complete 80 pages of forms each quarter. Ever-expanding schedules fail to support the utility of the call report as a vital safety and soundness metric for prudential regulators. ICBA’s call report survey found that the annual cost of preparing the call report has increased for 86 percent of survey respondents over ten years. The call report now represents a significant regulatory burden that diverts critical staff from completing other important tasks within the institution. The introduction of Basel III regulatory requirements, which are inundating basic schedules with new data points, is a further strain on community banks.
With the passage of S. 2155, Congress recognized the unreasonable burden the call report places on community banks and directed the banking agencies to provide relief. Unfortunately, the agencies’ proposed implementation of S. 2155 call report relief failed to meet congressional intent and was a significant disappointment to community banks.
The most effective short-term solution to this problem is to permit highly rated and well-capitalized community banks to file a short-form call report for the first and third quarters of each calendar year with full call reports filed at mid-year and year end. The short-form call report would include the income statement, balance sheet, and statement of changes in shareholders’ equity, which provides the information needed by regulators to provide prudent oversight over such short reporting intervals. More importantly, implementation of the short-from call report would allow community banks to return critical staff resources to serving the needs of their customers and communities. In ICBA’s call report survey, 98 percent of survey respondents stated that a short-form call report would reduce their regulatory burden, with 72 percent of respondents describing the reduction as substantial.
The FFIEC recently implemented a community bank call report that includes the elimination of certain reporting elements generally not applicable to community banks. Additionally, the Council has flagged for removal certain data items that the banking agencies do not need to maintain their safety and soundness supervisory activities. While such endeavors are appreciated and supported by ICBA, the regulators should also focus their attention on the frequency of items reported by community banks and whether the reporting of certain schedules on a quarterly basis adds meaningful value in the determination of the safety and soundness characteristics of a community bank.
ICBA appreciates the willingness of the FFIEC to create the 051 reporting form for smaller institutions as well as continually review the quarterly call report for further reporting item reductions for community banks. However, as noted above, FFIEC’s latest proposal does not meet the intent of Congress to provide community banks with a short-form call report solution. Regulators must address this failure by providing real relief for community banks by adopting a true short-form call report.
Staff Contact: James Kendrick