These quarterly reporting requirements were established by the Federal Financial Institutions Examination Council (FFIEC) for banks that quality for and adopt the Advanced Capital Adequacy Framework or are in the parallel run state of qualifying for the framework.
The revisions to the FFIEC 101 report are limited to removing two credit valuation adjustment (CVA) items from the exposure at default (EAD) column on FFIEC 101 Schedule B, Summary Risk-Weighted Asset Information for Banks Approved to Use Advanced Internal Ratings-Based and Advanced Measurement Approaches for Regulatory Capital Purposes (items 31.a and 31.b, column D). These revisions take effect as of the September 30, 2017, report date. However, reporting entities would be advised that they may elect to adopt the changes by ceasing to report column D of items 31.a and 31.b on FFIEC 101 Schedule B as of the June 30, 2017, report date.
The agencies propose under the emergency clearance provisions of OMBâs regulations to revise the FFIEC 101 for the June 30, 2018, report date. The agencies have determined that (1) the collection of information within the scope of this request is needed prior to the expiration of time periods established under 5 CFR 1320.10, (2) this collection of information is essential to the mission of the agencies, and (3) the agencies cannot reasonably comply with the normal clearance procedures because an unanticipated event has occurred and the use of normal clearance procedures is reasonably likely to prevent or disrupt the collection of information.
These revisions arise from Congressional enactment of the EGRRCPA. Section 214 of EGRRCPA requires the agencies to revise the definition of HVCRE exposures that institutions use to calculate risk-based capital. This provision became effective automatically when the law was signed on May 24, 2018.
The agencies must receive data from the quarterly FFIEC 101 report to assess and monitor the levels and components of each reporting entityâs risk-based capital requirements and the adequacy of the entityâs capital under the framework. The next reports are due at varying dates through the end of August 2018, based on information as of June 30, 2018. In order for the agencies to implement Section 214 as required by law, the agencies cannot comply with the normal clearance process and still receive the June 30, 2018, financial data in a timely manner.
With respect to the HVCRE exposures that are the subject of this submission, Section 214 of EGRRCPA adds a new Section 51 to the Federal Deposit Insurance Act governing the requirements for certain acquisition, development, or construction (ADC) loans. The agencies may only require a depository institution to assign a heightened risk weight to an HVCRE exposure if such exposure is an âHVCRE ADC Loan,â as defined in Section 214 of EGRRCPA.
To avoid the regulatory burden associated with applying different definitions for HVCRE exposures across the FFIEC 101, Call Report, and FR Y-9C within a single organization, the agencies propose to allow an institution subject to the advanced approaches rule to estimate and report HVCRE exposures on Schedules B and G of the FFIEC 101 using the definition under Section 214 effective for the June 30, 2018, report date. Alternatively, institutions may report HVCRE exposures using the prior definition contained in the agenciesâ regulatory capital rules until the agencies take further action.
On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).
The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control number;
If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.
Form FFIEC 101 Advanced Capital Adequacy Framework Regulatory Reporting Requirments
SPST-0159 Advanced Capital Adequacy Framework FFIEC 101 073118.docx
Interagency Statement.pdf
Advanced Capital Adequacy Framework Regulatory Reporting Requirments