Agencies seek comment on Call Report revisions for ROAD to Housing Act reciprocal deposit changes
On October 27, the OCC, the Fed and the FDIC requested comment on revisions to a proposal to revise and extend for three years the Consolidated Reports of Condition and Income (“Call Report”), currently an approved collection of information. The agencies are requesting comments related to an interim final rule that implements section 902 of the 21st Century ROAD to Housing Act (previously covered by InfoBytes here), which expanded the limited exception allowing qualifying “agent institutions” to exclude certain reciprocal deposits from treatment as brokered deposits under the FDI Act. Specifically, Section 902 broadened the CAMELS ratings that allow an institution to qualify as an agent institution and replaced the general cap with a tiered calculation based on total liabilities, which are changes the FDIC implemented through an interim final rule effective September 1 (covered by InfoBytes here).
After the agencies received emergency approval from the Office of Management and Budget on September 28, they revised the Call Report instructions for brokered and reciprocal deposit items in Schedules RC-E and RC-O and in the glossary entry for brokered deposits. The revisions applied to the September 30 report date. The agencies also created a new confidentiality exception for amounts reported as brokered reciprocal deposits in Schedule RC-O. They explained that comparing those amounts with publicly reported total reciprocal deposits “could reveal nonpublic supervisory information about an institution.” The agencies seek comment on whether the revised instructions accurately and clearly implement the amended exception. They also requested comment on the revisions to the collections of information, including whether they are necessary and have practical utility, the accuracy of the agencies’ burden estimates, ways to improve the quality and clarity of the data and to reduce reporting burden, and the estimated related capital and operating costs. Comments are due December 28.