In a detailed comment letter, CBAI urged the regulators to provide additional Call Report regulatory relief by allowing well-capitalized and highly-rated community banks to file short-form versions of the Call Report in the first and third quarters and by increasing the asset threshold for community banks to file a streamlined version of the Call Report from $1 billion to a minimum of $10 billion.
CBAI was initially encouraged when the regulators announced proposed streamlined Call Report revisions that would be available for use by 90% of all filers and would reduce the number of data items by 40%. CBAI said it “will be carefully reviewing the 57-page proposal and provide our observations for recommendations for improvement.” However, after a thorough review CBAI has concluded that the current proposal will not result in meaningful regulatory relief for community banks. CBAI specifically noted that merely reducing the number of pages by removing data points for activities that are applicable only to large banks and schedules that are generally not applicable to community banks (such as securitization activities, loans to foreign governments, and other non-existing lines of business) does little to relieve regulatory burden.
The increased time spent completing Call Reports was consistently raised by community bankers as a significant regulatory burden at the EGRPRA hearings around the country. The regulators stated that, if they go through the decennial EGRPRA review process and do not make substantive changes to the regulatory burden, then the regulators will have failed. CBAI stated that Call Report regulatory relief is a litmus test to determine if regulators are indeed taking community banker concerns seriously and whether the EGRPRA process will be a success or a failure. Unfortunately, the proposed Call Report relief measures failed to provide meaningful regulatory relief for community banks. CBAI encouraged the regulators to go further by allowing a short-form version of the Call Report to be filed in the first and third quarters and by increasing the asset threshold for the streamlined version. Read CBAI Comment Letter to FFIEC.
October 17, 2016