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Q&A on the impact of COVID-19 on the call report

Apr 08, 2020

Due to COVID-19, federal officials are recognizing that financial institutions may need additional time to submit certain regulatory reports.

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.

Here are frequently asked questions and answers:

Q: Has the April 30, 2020, deadline for submitting the Call Report been extended?

A: Yes, Financial Institution Letter (FIL)-28-2020, issued on March 26, 2020, provides a 30-day grace period for banks with total assets under $1 billion. The grace period deadline would be May 30, 2020.

Q: Does this mean we can wait until May 30, 2020, to file the Call Report?

A: The official filing date has not changed. The 30-day grace period was established to address adverse effects of the COVID-19 response. If you are not able to file the Call Report by the official April 30, 2020, deadline, you should contact your analyst to notify them that you are anticipating a delayed filing.

Q: Have the Call Report revisions for the capital and certain other changes proposed on Oct. 4, 2019, that would implement the Community Bank Leverage Ratio (CBLR) been finalized?

A: Yes. The final rule was published on January 27, 2020. The changes will be effective March 31, 2020.

Q: Did the CARES Act have any impact on the CBLR Framework?

A: Yes. FIL-35-2020, Modifications to the Community Bank Leverage Ratio, published on April 6, 2020, included temporary changes to the CBLR Framework to comply with Section 4012 of the CARES Act that will be effective for the June 30, 2020, Call Report. The temporary changes are as follows:

  • Banks with a CBLR ratio of 8% or greater and that meet all other qualifying criteria may elect to use the CBLR Framework. The CBLR ratio will transition as follows:

    Date

    March 31, 2020

    June 30, 2020, through December31, 2020

    December 31, 2021

    December 31, 2022, and after

    CBLR minimum

    9%

    8%

    8.5%

    9%

  • The two-quarter grace period will remain; however, the bank will still be considered well capitalized provided the CBLR remains 7% or greater.
Q: Are updated instructions or forms for the March 31, 2020, Call Report available?

A: Currently, the final updated forms are available; however, the instructions are pending as of April 6, 2020. The draft instructions and forms were originally published in April 2019 and are available on the FFIEC website.

Q: How will the COVID-19 response impact the methods for calculating capital?

A: In the short term, the COVID-19 response should have minimal impact on electing to opt in to the CBLR or continuing to use the risk-based framework. Management should consider the bank’s capital plan, long-term strategies and capital ratio targets, as well as its current risk appetite. As we move into uncertain times, we are finding that some banks are more comfortable with having the detailed risk-based information provided by risk weighting assets on Schedule RC-R, Part II. Other banks, with a strong leverage ratio, are finding that the efficiencies gained by not completing RC-R, Part II are more valuable. Keep in mind, the bank does not have to make a commitment to one method. The bank can opt in or out of the CBLR Framework if it meets the qualifications.

Q: What do I have to do to opt in to the CBLR Framework?

A: When you update your call reporting software, there will be elections on the landing page. When you check the box to opt in to the CBLR Framework, the form will adjust to the CBLR version. Typically, the other areas are disabled.

Q: How will loan modifications and other relief loans get reported on the Call Report?

A: Loan modifications that fall within the COVID-19 response are not required to be reported; however, we recommend tracking these loans internally.  

Q: Is there a way to explain unusual amounts reported that were caused by the COVID-19 response?

A: Yes. The Bank can write a brief explanation, which will be available to the public on the Call Report, in the narrative statement section.

Q: How do I stay current with all of the changes related to the Call Report?

A: You can subscribe online to the FDIC to receive Financial Institution Letters (FILs) electronically and to access FDIC FILs.  

Q: What if the Call Report preparer at our bank is unable to complete the Call Report?

A: Contact your Wipfli relationship executive or visit wipfli.com/fi, and we will work with you to find a solution.

Author(s)

Heidemann_Danielle
Danielle M. Heidemann, CIA
Manager
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