For decades, ICBA has advocated for all regulatory requirements to be tailored to the size and complexity of the financial institution, and this includes the rules for how call reports are compiled.
“Community banks, with their smaller size and straightforward model, pose the least risk to the financial system—and their regulatory and supervisory requirements should reflect that low risk,” says Amy Ledig, vice president and safety and soundness regulatory counsel for ICBA. “Regulators’ expectations should be different than the expectations they have for the largest banks.”
Across Wipfli’s national financial services practice, lead partner Anna Kooi hears the same story in nearly every community bank her team works with. “The call report has quietly become one of the most expensive forms in banking,” she says. “ICBA’s own survey put it in black and white.”
According to the 2014 ICBA Community Bank Call Report Burden survey, community banks under $500 million in assets spend an average of 122 hours per year on call reports, and larger community banks average 274 hours. What’s more, 73% of bankers say that burden has only grown over the past decade.
“The FDIC, Federal Reserve and OCC opened a joint comment period in late 2025 to start chipping away at the burden, and that’s encouraging,” says Kooi. “But relief from Washington takes years, and the institutions we advise aren’t waiting.”
5 smart ways to streamline call reports
According to Kooi, community banks that are pulling ahead on call reports are doing five things differently.
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They’re treating call report preparations as a continuous discipline rather than “a quarter-end scramble” by building rolling tie-outs and reconciliations into the monthly close, so that 80% of the work is already done before the quarter ends, says Kooi.
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They are investing in data architecture, mapping call report line items directly to the general ledger, loan origination and deposit systems, so the data flows in clean rather than getting reassembled by hand every 90 days.
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“They’re standardizing workpapers and review trails,” Kooi says, “documenting not just the numbers but the ‘why’ behind every judgment call, which pays off the moment an examiner asks a question or a new preparer steps in.”
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They’re using software automation and AI selectively but aggressively for the schedules that “bankers consistently tell us are the worst offenders,” says Kooi. These include loan coding on RC-C and the regulatory capital math on RC‑R, where automated edit checks catch errors days before filing instead of weeks after. Emerging analysis suggests AI-enabled automation of regulatory data collection can cut compliance costs by 30% to 45%.
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They’re cross-training beyond the CFO’s desk, pulling credit, treasury and operations into the process so the institution, as Kooi says, “isn’t one resignation away from a filing crisis.”
“The real win isn’t just hours saved,” Kooi adds. “It’s giving community bank CFOs and controllers the capacity to serve their communities, sharpen their strategy and use call report data the way regulators always intended: as a lens on performance and risk, not a paperwork tax.”
Andrew Oster, principal for financial services at CliftonLarsonAllen LLP in Minneapolis, recommends community banks code loans at the outset during the underwriting or onboarding process, identifying them using a standardized loan coding hierarchy.
“That requires that everybody that does underwriting or onboarding understands the call report, but that could be a lot of people, so centralizing where that decisioning is made could be a way to standardize that process,” Oster says.
Regulatory changes could help ease call report compilation
According to Oster, one regulatory change that became effective on July 1 can ease the call report process for many community banks: The final rule lowers the community bank leverage ratio (CBLR) requirement from 9% to 8%.
“Lowering the CBLR requirement will make the election more broadly available and is intended to encourage more banks to make the CBLR election,” Oster says. “This should provide meaningful regulatory reporting relief as banks then wouldn’t be required to calculate and report risk-weighted assets on the call report in RC-R Part II, which can be one of the most time-consuming schedules.”
In addition, the FDIC, Federal Reserve Board and OCC are evaluating comments submitted on a proposal to modernize the regulatory capital framework by revising certain elements of the definition of regulatory capital and the calculation of risk-weighted assets under the standardized approach.
The agencies aim to promote mortgage origination and servicing by all banking organizations, including those subject to the CBLR framework “in a risk-conscious way,” Oster says. To accomplish this, regulators are proposing to remove the mortgage-servicing asset deduction from common equity tier 1 capital, as well as introduce an approach based on loan-to-value ratios for assigning risk weights to certain residential mortgage exposures.
Throughout regulators’ considerations to further ease the call report process, community bankers’ comments have focused on asking them what level of detail the agencies need for the primary purpose of call reports: to monitor the safety and soundness of individual banks between exam cycles, as well as the industry, Oster says.
“For certain schedules, bankers question whether certain data points are needed every single quarter from community banks,” he says. “Maybe semiannually or even annually for some, striking the right balance for oversight of safety and soundness.”
