CBA Joint Comment on Implementation Timeframe for Proposed “Call Report” Revisions

Gentlemen:
In February of this year, the Federal Deposit Insurance Corporation, the Office of the
Comptroller of the Currency and the Board of Governors of the Federal Reserve System (the
“Agencies”), in conjunction with the Bureau of Consumer Financial Protection, proposed
significant revisions to the Consolidated Reports of Condition and Income (“Call Report”), all
but one of which would be implemented as of June 30, 2013. In our joint comment letter, filed
April 22, 2013,1 the American Bankers Association2, The Financial Services Roundtable3 and the Consumer Bankers Association4 (the “Associations”) raised a number of important issues
regarding the proposed revisions.
Given that the proposed changes in the data requested to be added to the Call Report are so
significant, the proposed timeline for providing this new information is operationally
unworkable. We therefore respectfully request that the Agencies publicly announce – as soon as
possible – that the proposed revisions will not be implemented in the June 2013 Call Report.
Specifically, the proposed time frame at this late date is not sufficient to allow banks to modify
reporting systems or work with third party data providers to gather and submit the requested
information. Further, the proposal raises many technical interpretive questions that must be
addressed before the appropriate modifications can be finalized. That is to say, until there is
more clarity on several important points, banks cannot even design the systems to gather that
information and provide it as would be required.

We understand that, as discussed in our comment letter, we raise a number of issues that the
Agencies will wish to consider carefully, issues that we believe present fundamental reasons why
the Agencies would wish to take adequate time for their own purposes to consider and then
decide how best to address them. Therefore, it is in the interests of the careful consideration by
the Agencies as well as the operational demands upon the bankers that the Agencies should
announce that the June 30, 2013, deadline is suspended.
The Associations greatly appreciate the Agencies’ thoughtful consideration of this request.
Please do not hesitate to contact Alison Touhey (ABA), 202-663-5182, Rich Foster
(Roundtable), 202-589-2424 or David Pommerehn, (CBA), 202-552-6568, if you have any
questions or would like to discuss this matter further.
Sincerely,

Frank Keating
President & CEO
American Bankers
Association

Tim Pawlenty
President & CEO
The Financial Services
Roundtable

Tim Pawlenty
President & CEO
The Financial Services
Roundtable