Via Electronic Mail

Chief Counsel’s Office
Office of the Comptroller of the Currency
400 7th Street, SW, Suite 3E-218
Washington, D.C. 20219

Ann E. Misback, Secretary
Board of Governors of the Federal Reserve System
20th Street and Constitution Avenue, NW
Washington, D.C. 20551

Manuel E. Cabeza, Counsel
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, D.C. 20429

Re: Call Report and FFIEC 002 Deposit-Related Revisions

To Whom it May Concern:

The Bank Policy Institute, the Securities Industry and Financial Markets Association, and the American Bankers Association (collectively, the Associations)1 welcome the opportunity to comment on the proposal by the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency regarding revisions to the Consolidated Reports of Condition and Income (Call Reports) (FFIEC 031, FFIEC 041, and FFIEC 051).2 The Associations understand the agencies’ need to evaluate the behavior of sweep accounts in order to determine their appropriate treatment under liquidity regulations and are generally supportive of the agencies’ further research into and analysis of funding stability and the behavior of bank counterparties over time. However, firms have concerns with the proposed new reporting items, specifically that the revisions are duplicative of existing reporting requirements for many firms, as well as the proposed implementation timeline. On our other comments herein highlight areas of the proposal related to the reporting treatment of certain deposits consistent with changes in the brokered deposits final rule3 and definitions that require further clarification from the agencies.

I. Firms that report data on sweep deposits in the FR 2052a should not be required to provide comparable data in the Call Report.

In connection with the final rule implementing the Net Stable Funding Ratio4 and the Brokered Deposits Final Rule, the proposal would collect data on sweep deposits and on sweeps that received a primary purpose exemption under the recently modernized brokered deposit framework. Specifically, the proposal would add five memorandum items, regarding insured and partially insured sweep deposits, to Schedule RC-E, which is collected quarterly on the FFIEC 031 and FFIEC 041 and semiannually on the FFIEC 051. Additionally, four data items, related to sweep deposits for different types of counterparties, would be added to Schedule RC-E of the FFIEC 031 only and would be completed quarterly by institutions with $100 billion or more in total assets. Many of the firms to which
these proposed requirements would apply, are currently required to file the FR 2052a that provides the agencies with detailed liquidity data, including the critical data elements of these newly proposed memorandum items of the Call Reports. As a result, such firms already provide the agencies with data on sweeps deposits, on both a more frequent and a more granular basis than the proposed new items would require. Requiring those firms that are currently subject to FR 2052a reporting to also submit substantially similar data on the Call Reports would be duplicative and would create unnecessary burden for respondent firms.5