Federal Regulators Announce 30-Day Call Report Grace Period

Summary

The Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation (collectively, the agencies) under the auspices of the Federal Financial Institutions Examination Council (FFIEC) today issued a press release recognizing that financial institutions may need additional time to submit certain regulatory reports in light of the coronavirus disease (also referred to as COVID-19). The agencies will not take action against any institution for submitting in good faith its March 31, 2020, Consolidated Reports of Condition and Income (or call report) after the official filing deadline, as long as the report is submitted within 30 days after the official filing deadline.

This grace period applies to submissions of all three versions of the call report (FFIEC 031, FFIEC 041, and FFIEC 051).

Highlights

  • The information reported in the call report provides mission-critical information to the agencies in assessing the overall health of the banking system. Understanding the condition of the banking system is even more important in times of stress for both the agencies and the public. As such, the OCC encourages institutions to file the March 31, 2020, call report by the filing deadline, if possible.
  • The OCC understands that COVID-19-related disruptions may cause delays in an institution’s March 31, 2020, call report submission or contribute to unintentional and incidental reporting errors. The OCC will not take action against institutions affected by COVID-19 for submitting in good faith the March 31, 2020, call report within 30 days of the filing deadline.
  • Institutions affected by COVID-19 that prepare and submit their March 31, 2020, call reports in good faith may amend the filing to correct for unintentional and incidental reporting errors within 30 days of the filing deadline without penalty.
  • Institutions affected by COVID-19 that expect a delay in their March 31, 2020, call report submission or anticipate challenges in obtaining director attestations before submission of the call report are encouraged to contact their supervisory office.
  • A bank will continue to be deemed notified of its capital category for purposes of prompt corrective action as of April 30, 2020, pursuant to 12 CFR 6.3(b)(1). Similarly, a bank’s lending limit for purposes of 12 CFR 32 will continue to be effective as of the earlier of the call report submission or April 30, 2020, pursuant to 12 CFR 32.4(b)(1).

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