The Temporary Asset Threshold Relief Expired: What Is the Impact on Regulatory Reporting?

The Temporary Asset Threshold Relief became effective in late December 2020 and applied to community banking organizations under $10 billion in total assets as of December 31, 2019. It allowed such organizations to use the total assets data as of December 31, 2019, to determine the applicability of reporting requirements during 2020 and 2021. The relief expired on December 31, 2021. Community banking organizations should now use total assets data as of June 30, 2021, to determine initial filings for the March 31, 2022, reporting period. This change may impact your organization’s reporting in three ways: the shift in Report Forms, the addition of Schedules and the addition of line items on Schedules.

With the temporary relief expiring for March 31, 2022, reporting, firms should review their total assets as of June 30, 2021, when considering shifting Report Forms:

• If a holding company files an FR Y-9SP Report and total assets as of June 30, 2021, exceeded the $3 billion threshold, the holding company should begin to file the FR Y-9C Report as of March 31, 2022, and discontinue filing the FR Y-9SP Report.
• Similarly, for the Call Report, if a bank files an FFIEC 051 Report and the total assets exceeded the $5 billion threshold as of June 30, 2021, the bank should begin to file the FFIEC 041 Report as of March 31, 2022, and discontinue filing the FFIEC 051.

Furthermore, exceeding report-defined total assets thresholds will trigger additional filing requirements for certain Schedules and line items on the Call Report and the FR Y-9C Report. While the General Instructions on pages 6 and 7 of the Call Report Instructions have outlined shifts in report status and additional requirements due to assets crossing, we have summarized the changes on the FR Y-9C based on different total assets thresholds:

• The $5 billion threshold requires the holding companies to report the following Schedules:
  • Schedules: HI-C Part I, HC-D, HC-P, HC-Q, HC-S and HC-V
• The $5 billion threshold requires the holding companies to report the additional line items on the following Schedules:
  • Schedules: HI, HI Memoranda, HI-B Part I, HI-B Memoranda Part I & Part II, HC-C, HC-C Memoranda, HC-K, HC-L, HC-M, HC-N and HC-N Memoranda
• The $10 billion threshold requires the holding companies to report the additional line items on the following Schedules:
  • Schedules: HI Memoranda, HC-B Memoranda, HC-L, HC-S, HC-S, HC-S Memoranda, and HC-R Part I & Part II

Review a complete list of FR Y-9C line items in the FR Register. 
 
If you have regulatory reporting questions, please reach out to your Central Point of Contact or Report contact at the Federal Reserve Bank of Richmond.