Notice of Proposed Call Report Changes

The FFIEC has issued a notice of proposed changes to the Call Report, see FFIEC Proposed Call Report changes
The changes are proposed to take effect December of this year!

Has anyone had a chance to read this yet and speak to how it might affect CRA?

First of all it seemed strange that this is still a proposal, but might take effect so soon.

At first glance, it looks like I am going to have to find a way to know when the repayment period starts and the call report code changes, on an existing loan. And I need to see how the consumer loan department is going to actually change the call report code. I can't think of an automated way to have our system do that.

Are others seeing it that way?

Still reviewing!

The main change to loans has no effect on small business/small farm reporting. It affects treatment of HELOCs that enter the repayment period FOR CALL REPORT PURPOSES ONLY (not Reg Z):

The Call Report instructions do not address the reporting treatment for a home equity line of credit when it reaches its end-of draw period and converts from revolving to non-revolving status. Such a loan no longer has the characteristics of a revolving, open-end line of credit and, instead, becomes a closed-end loan. In the absence of instructional guidance that specifically addresses this situation, the agencies have found "diversity" (read that as lack of consistency) in how these credits are reported in Schedule RC–C, Part I.

Therefore, the agencies are proposing to clarify the instructions for reporting loans secured by 1–4 family residential properties to specify that after a revolving open-end line of credit has converted to non-revolving closed-end status, the loan should be reported in Schedule RC–C, Part I, item 1.c.(2)(a) or (b), as appropriate.

In proposing this clarification, the agencies request comment on whether an instructional requirement to recategorize HELOCs as closed-end loans for Call Report purposes would create difficulties for institutions’ loan recordkeeping systems.

Not much else at all affecting lending.