The crux of the burdens lie with the complexity and granularity of the reporting and the hurdles to understanding which data are properly placed in which line item. The proposal primarily serves as a much needed clean-up of the Call Report, an important prelude to even more meaningful relief.
The proposed changes would reduce the Call Report form from 85 pages to 61 as a result of removing 950 data items, or about 40% of entries on the current Call Report. They would also streamline how banks report on their complex activities, with existing schedules on complex or specialized activities being replaced with simple questions that ask whether banks engage in the activities and indicate specific data items to fill out if they do. Some schedules would also be filed on an annual or semiannual basis.
To further enhance effective reporting, ABA recommended that the agencies align the Call Report with financial accounting data, make the instructions more user-friendly, improve training and information provided to bankers, review the Call Report on a frequent basis and provide sufficient lead time for future Call Report changes. ABA also said the current proposal could be expanded to banks with up to $10 billion in assets with no loss to supervisory value.
The proposal in August came after ABA helped over the past several years to facilitate conference calls with community bankers and regulators to explain current Call Report burdens and offer suggestions for streamlining it. ABA anticipates future proposals related to Call Report reform in the future. If adopted, the new Call Report would take effect with the March 31, 2017, report date.
Read the letter.