Topic: Call Reports
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Based on a recent FDIC financial institution letter (FIL), can we no longer subtract collateralized amounts from our uninsured deposits?
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We do not believe that banks may reduce uninsured deposits to reflect collateralization of deposits by pledged assets when reporting estimated uninsured deposits on their Call Reports. If you have subtracted collateralized amounts from uninsured deposits on Call Reports in the past, we believe you must amend these Call Reports as advised in the FDIC’s…
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Can a money market account be the only account associated with a debit card? Also, would a money market account that has had its transaction limitations removed still be classified as a savings account? We have chosen to remove transaction limitations on such accounts, but we still have a minimum withdrawal amount.
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We are not aware of any law or regulation that would prohibit a money market account from being the only account associated with a debit card. Consequently, whether to offer debit cards for such accounts is a business decision for your bank. For Call Report purposes, whether to report a money market account that has…
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Our bank holding company is traded on the OTC Bulletin Board (OTCBB). OTC Markets Group has recently provided us with new disclosure guidelines informing us that to comply with new amendments to 17 CFR 240.15c2-11 (Rule 15c2-11) effective September 28, 2021, we will need to upload audited financial statements, a list of our directors, and other items, including “Call Reports or other Bank Regulatory Filings.” We will also be charged a fee. Is this a legitimate requirement, and is there anything else we should know about these new amendments?
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It appears that the OTC Markets Group’s disclosure requirements are legitimate, as they are related to the SEC’s Rule 15c2-11 amendments, and you will need to comply with their disclosure requirements and pay the requested fee in order to remain listed on your preferred bulletin board. However, we recommend asking OTC Markets Group about its…
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If we temporarily suspend the six-per-month limitation on transfers and withdrawals from savings accounts at our bank (as authorized under recent amendments to Regulation D), must these accounts be reported as “transaction accounts” for Call Report purposes? We have not changed our terms and conditions or account disclosures to reflect the temporary suspension of the six-per-month limitation. May we still refer to these accounts as savings accounts even if we must report them as transaction accounts on our Call Reports?
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Your bank may continue to report such accounts as nontransaction savings deposits for Call Report purposes; however, your bank has the option of reporting such accounts as transaction accounts if certain criteria are met. The December 2020 COVID-19 Related Supplemental Instructions for Call Reports state that when a reporting institution has suspended the enforcement of…
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The federal bank regulatory agencies recently issued a proposed rule to revise the definition of High Volatility Commercial Real Estate (HVCRE) exposures. The accompanying Financial Institution Letter from the FDIC stated that this proposed change is “applicable to all banks.” What does this really mean for a smaller community bank?
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The significance of the proposed changes to the HVCRE definition will depend on the amount of HVCRE exposure held by your bank. The proposed HVCRE definition would exclude several new categories of loans from the HVCRE definition, such as loans made before January 1, 2015 — generally resulting in a 100% risk weighting for such…
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We know that federal law requires us to retain Call Reports for five years. Our FDIC examiners told us to also check state law. Does Illinois law have a record retention period for Call Reports?
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No, we are not aware of any Illinois laws that specify a record retention period for Call Reports. While the Illinois Banking Act mandates the Commissioner of Banks to promulgate record retention rules, no such rules have been published. Consequently, we recommend following the FFIEC’s requirement to maintain Call Reports for five years after the…
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We want to offer a “sweep” agreement to some of our commercial customers. The customer would maintain a savings account or money market account and an interest-bearing investment vehicle in the form of a repurchase agreement (a “repo account”). When the savings deposit account balance reaches a certain threshold, we would sweep the excess funds into the repo account. In addition, if the savings deposit fell below a certain threshold, we would sweep funds from the repo account into the savings deposit account. Are these sweep transactions limited to six per month under Regulation D? We would classify the savings accounts as “savings deposits” for reserve requirements purposes but are not sure how to classify the repo accounts, which are reported on the Call Report separately from our transaction/non-transaction accounts.
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Because your institution is classifying the savings or money market accounts as non-transactional savings deposits for reserve requirements purposes, the accounts are limited to no more than six withdrawals per month, among other requirements in Regulation D. Consequently, the preauthorized sweeps from these accounts into the “repo account” would be subject to the six-per-month limitation…
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Our bank holds a few shares of Class A Farmer Mac stock (with a readily determinable value, not held for trading). Do we report this on Call Report Schedule RC-F (Other Assets) or RC-B (Securities)?
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We believe the appropriate place to list this stock is Schedule RC-B (Securities), Item 7. The FFIEC Call Report Instructions indicate that Farmer Mac Class A stock should be reported in Schedule RC-B (while Farmer Mac Class B stock is reported in Schedule RC-F (Other Assets)). In addition, note that if your bank has adopted…
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For our Fannie Mae loans, we place property insurance claim proceeds being held for future repairs in custodial accounts under our bank’s TIN (to avoid issues with the accounts showing up under the borrower’s TIN for data match and subpoena searches). We recently discovered that the Fannie Mae Servicing Guide requires us to pay interest on these funds, so we will have to move them into interest-bearing accounts. How can we properly report the interest earned on these accounts without making the funds susceptible to a levy or garnishment?
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As you noted, the Fannie Mae Servicing Guide requires servicers to place insurance loss proceeds that have not been disbursed to the borrower (or a contractor) in interest-bearing custodial accounts. We agree that you should continue to use the bank’s TIN on these accounts, in order to indicate they are custodial accounts that are shielded…
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We recently discovered that the Federal Reserve Board (FRB) has published our Annual Report of Holding Companies (FR Y-6) online. Can we request the FRB to keep this form confidential?
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Yes, you may request confidential treatment of your FR Y-6 form; however, you must make this request simultaneously with or within a reasonable time after submitting your form. The FRB rules and the FR Y-6 form instructions outline the specific steps for making a confidential treatment request, including submitting a letter identifying the specific items…