FFIEC 101 Reporting: A Three-Year Renewal With No Form Changes

On 16 October 2026 the OCC, the Federal Reserve Board and the FDIC published a joint Federal Register notice (91 FR 65843) stating that they will extend FFIEC 101 reporting for three years without revision and are sending the collection to the Office of Management and Budget (OMB) for review. The FFIEC 101, formally the Regulatory Capital Reporting for Institutions Subject to the Advanced Capital Adequacy Framework, is the quarterly report on which each advanced approaches institution files its regulatory capital data and on which top-tier advanced approaches and Category III organizations file supplementary leverage ratio (SLR) information. Comments on this second, 30-day stage must reach the agencies by 16 November 2026. The current OMB approval printed on the form expires on 31 December 2026.

No changes to the FFIEC 101 form are proposed as part of this three-year extension request. The agencies are submitting the existing collection to OMB for review and approval; the October notice does not itself constitute OMB approval of the extension. The same notice records two further points: the agencies are in the process of revising the capital requirements for advanced approaches institutions and may issue revised reporting requirements through a later Paperwork Reduction Act (PRA) notice, and the existing forms are likely to stay in use for a time after the expiry date. The larger change therefore sits in a separate rulemaking. The agencies’ March 2026 proposal for Category I and II banking organizations would eliminate the advanced approaches framework, and it says the related FFIEC 101 revisions would be addressed in separate Federal Register notices.

Related reading: FFIEC Call Report: Who Files 031, 041 or 051 for 30 September 2026

FFIEC 101 dates from the June notice to the OMB expiry

• 5 June 2026: the agencies publish the 60-day notice proposing to extend the FFIEC 101 for three years without revision (91 FR 34347).
• 4 August 2026: the 60-day comment period closes. The October notice records that no comments were received.
• 16 October 2026: the 30-day notice is published (91 FR 65843) and the agencies send the collection to OMB for review.
• 16 November 2026: comments on the 30-day notice must be received. Copies may also go to the OMB desk officers through reginfo.gov.
• 31 December 2026: the existing approval expires, the date printed beneath the three OMB control numbers on the cover of the 30 June 2026 report form.

The report dates themselves are fixed by the instructions: the FFIEC 101 is filed as of 31 March, 30 June, 30 September and 31 December. What varies is the due date, which depends on where an institution stands in the advanced approaches qualification process.

Legal basis: subpart E, the SLR rule and the statutes behind the form

The advanced approaches risk-based capital rule is subpart E of each agency’s capital rule: 12 CFR part 3 for the OCC, 12 CFR part 217 (Regulation Q) for the Board and 12 CFR part 324 for the FDIC. Subpart E is titled Risk-Weighted Assets: Internal Ratings-Based and Advanced Measurement Approaches, which is why the FFIEC 101 carries probability of default, loss given default and exposure at default for credit risk, and a separate operational risk schedule. The FFIEC 101 instructions call this rule the “advanced approaches rule” throughout.

The SLR sits in section 10 of the same rules. Under 12 CFR 217.10(a)(1)(v), advanced approaches and Category III institutions must maintain a supplementary leverage ratio of 3 percent. Section 217.10(c) defines the ratio as tier 1 capital over total leverage exposure, where the on-balance sheet component is the mean of the balances calculated as of each day of the reporting quarter and the off-balance sheet component is the mean of the amounts calculated as of the last day of each of the three months in the quarter. That averaging is why SLR Tables 1 and 2 cannot be filled from a quarter-end balance sheet alone. For how Basel’s leverage standard has been implemented differently across jurisdictions, see our leverage ratio RCAP assessment summary.

The October notice lists the statutes that make the FFIEC 101 mandatory: 12 U.S.C. 161 for national banks, 12 U.S.C. 324 for state member banks, 12 U.S.C. 1844(c) for bank holding companies, 12 U.S.C. 1467a(b) for savings and loan holding companies, 12 U.S.C. 1817 for insured state nonmember commercial and savings banks, 12 U.S.C. 1464 for federal and state savings associations, and 12 U.S.C. 1844(c), 3106 and 3108 for intermediate holding companies. Certain data items receive confidential treatment under 5 U.S.C. 552(b)(4) and (8).

The form has three approvals behind it. The FFIEC 101 carries OMB control number 1557-0239 for the OCC, 7100-0319 for the Board and 3064-0159 for the FDIC, and the notice describes it as a currently approved collection for each agency. That is why the extension is a joint notice, and why the OCC asks commenters to quote 1557-0239. The instructions are also not self-contained: they state that the advanced approaches rule or other parts of the capital framework may be needed for detailed definitions and treatments.

Who files the full report and who files only the SLR tables

Two populations file, and they file very different amounts. Advanced approaches institutions complete the report. Category III classification alone does not require an institution to calculate risk-weighted assets under the advanced approaches. A Category III institution that is not independently subject to the advanced approaches reports only the applicable SLR information, with top-tier institutions completing Schedule A, SLR Tables 1 and 2. If a Category III institution elects to use the advanced approaches, it becomes subject to the corresponding FFIEC 101 reporting requirements, including the additional schedules applicable to advanced approaches institutions.

The advanced approaches population is defined by the applicability provisions in each agency’s capital rule: 12 CFR 3.100(b)(1) for OCC-supervised institutions, 12 CFR 217.100(b)(1) for Board-regulated institutions and 12 CFR 324.100(b)(1) for FDIC-supervised institutions. It covers a top-tier U.S. bank holding company or savings and loan holding company, not itself a consolidated subsidiary of a subpart E user, that is identified as a global systemically important bank holding company (GSIB) under 12 CFR 217.402, is a Category II banking organization under 12 CFR 252.5 or 238.10, or has a subsidiary depository institution required or electing to use subpart E. It also covers state member banks that are GSIB subsidiaries, Category II institutions, or subsidiaries of a depository institution or holding company that uses subpart E, and any institution that elects in. The Call Report instructions apply the same five-part definition to banks of every charter: a GSIB subsidiary, a Category II institution, a subsidiary of a depository institution or of a holding company that uses the advanced approaches, or an institution that elects to use them. For a depository institution assessed under the stand-alone Category II size tests, the thresholds are measured using the applicable four-quarter averages: at least $700 billion in total consolidated assets, or at least $100 billion but less than $700 billion in total consolidated assets together with at least $75 billion in cross-jurisdictional activity. Depository institution subsidiaries of Category II holding companies are covered under the applicable subsidiary provisions. The rules also provide measurement arrangements for newly reporting institutions and separate criteria for exiting Category II.

Category III status for a depository institution follows the applicable agency definition: 12 CFR 3.2 for OCC-supervised institutions, 12 CFR 217.2 for Board-regulated institutions and 12 CFR 324.2 for FDIC-supervised institutions. A bank may fall within Category III through the applicable subsidiary provisions or, where it is not a subsidiary of a depository institution holding company, through the stand-alone size tests. Those tests generally use averages over the four most recent calendar quarters: at least $250 billion in total consolidated assets, or at least $100 billion but less than $250 billion in total consolidated assets together with at least $75 billion in one of three indicators: total nonbank assets, off-balance-sheet exposure or weighted short-term wholesale funding. The definitions also prescribe measurement rules for newly reporting institutions and separate criteria for category exit. Those indicators are measured under the FR Y-9LP and FR Y-15 instructions; our FR Y-15 systemic risk report guide covers the underlying calculations. Holding companies are categorized under 12 CFR 252.5 and 238.10.

The Schedule A instructions add that a top-tier advanced approaches organization completes SLR Tables 1 and 2 regardless of parallel run status.

The opt-in route has a timing trap built into a footnote. An institution is deemed to have elected the advanced approaches on the date its primary federal supervisor receives a board-approved implementation plan. After that date it is required to report Schedule A, starting with the next calendar quarter, it can no longer apply the AOCI opt-out election, and it becomes subject to the SLR and its transition provisions. The capital consequences start before any model has been approved.

Category IV classification alone does not trigger FFIEC 101 reporting or the 3 percent SLR minimum. However, an institution classified as Category IV that elects to use the advanced approaches falls within the FFIEC 101 reporting scope and becomes subject to the corresponding SLR requirements. Section 217.10(a)(1)(v) specifies the 3 percent SLR minimum for advanced approaches and Category III institutions.

Entering the advanced approaches: implementation plan, parallel run, first filings

The qualification process in 12 CFR 217.121 (with parallel text in 12 CFR 3.121 and 324.121) runs on fixed clocks. An institution becoming subject to the advanced approaches through the mandatory applicability criteria must adopt a written implementation plan within six months of meeting the applicable criterion, with an explicit start date no later than 36 months after that trigger, subject to supervisory extension. An institution voluntarily electing the advanced approaches must also adopt a written implementation plan, but the six- and 36-month deadlines do not apply to that voluntary election. The plan, with the board minutes approving it, goes to the supervisor at least 60 days before the proposed start of the parallel run unless prior notice is waived. The parallel run itself lasts no less than four consecutive calendar quarters, during which the institution must meet the qualification requirements in section 217.122 to the supervisor’s satisfaction while its minimum ratios are still set under the standardized approach in subpart D. The supervisor then notifies the date from which the institution must use subpart E.

The FFIEC 101 follows that sequence. Schedule A, except for a few specific line items, starts with the calendar quarter immediately after the quarter in which the institution becomes an advanced approaches or Category III organization, or elects in. The remaining schedules start at the end of the first quarter of the parallel run. Throughout, the institution keeps filing the regulatory capital schedule in its Call Report (Schedule RC-R) or FR Y-9C (Schedule HC-R).

During the parallel run, three Schedule A lines are deliberately reported on the old basis: item 12 (expected credit loss that exceeds eligible credit reserves) is reported as zero, and items 50 (eligible credit reserves) and 60 (total risk-weighted assets) are completed under the standardized approach. The advanced approaches results go into memoranda items 86 to 90. Once the parallel run is complete, items 12, 50 and 60 switch to the advanced approaches rule.

Approval adds a calculation. Under section 217.10(d), an institution that has completed its parallel run and received notification under section 217.121(d) reports each risk-based ratio as the lower of its ratio under the standardized approach and its ratio under the advanced approaches. Both risk-weighted asset stacks stay in production for as long as the institution is in the regime.

What FFIEC 101 reporting contains, schedule by schedule

The report runs from Schedule A to Schedule S. The table below follows the instruction book’s own grouping.

Schedule A is mostly a restatement of the institution’s Call Report or FR Y-9C capital schedule in a Basel-style layout. Items 1 to 29 build common equity tier 1 capital, items 30 to 44 additional tier 1, and the schedule continues through tier 2 to total risk-weighted assets at item 60. Items 61 to 68 carry the three capital ratios and the buffer lines, including the capital conservation buffer, the countercyclical capital buffer and the GSIB surcharge, each reported as a percentage rounded to four decimal places. Items 69 to 71 are marked not applicable. Items 86 to 90 are the memoranda: expected credit loss over eligible credit reserves, advanced approaches risk-weighted assets taken from Schedule B item 36, and the three ratios calculated using the advanced approaches.

The cross-references carry a narrow trap. Schedule A item instructions point to Schedule RC-R and Schedule HC-R item numbers, and the instructions specify that those references are to Part I, not to Part II, of those schedules.

SLR Table 1 reconciles total consolidated assets in the published financial statements (item 1.1) to total leverage exposure (item 1.8), with adjustments for entities outside regulatory consolidation, derivatives, repo-style transactions, off-balance sheet exposures, tier 1 deductions, frequency calculations and qualifying central bank deposits of custodial banking organizations. SLR Table 2 builds the same total bottom-up from on-balance sheet exposures (items 2.1 to 2.3), derivatives (2.4 to 2.11), repo-style transactions (2.12 to 2.16) and off-balance sheet exposures (2.17 to 2.19), then reports tier 1 capital, total leverage exposure, the SLR at item 2.22 and, for holding companies subject to the enhanced SLR standards only, a leverage buffer at item 2.23.

Schedule B is the bridge between the exposure schedules and the capital number. Schedule B provides up to eight columns: weighted-average probability of default, balance sheet amount, total undrawn amount, exposure at default, weighted-average maturity, weighted-average loss given default after credit risk mitigants, risk-weighted assets and expected credit loss. The applicable columns vary by exposure category and line item. For example, operational risk is reported in column G rather than across all eight columns.

Rounding depends on size. An institution with total assets under $10 billion reports in thousands, while an institution at $10 billion or more may round to the nearest million. Weighted averages are reported to two decimal places unless stated otherwise, and exposure and risk-weighted asset amounts are consolidated on the same rules as the institution’s Call Report or FR Y-9C.

Deadlines: the 60-day window, then the Call Report or FR Y-9C date

The FFIEC 101 has two clocks, and an institution moves from one to the other when its parallel run ends.

In every case the report is due by the end of the reporting day, 5:00 P.M., on the submission date.

An SLR-only filer never gets the 60-day window. The instructions put institutions subject to the SLR only on the same submission date as their Call Report or FR Y-9C from the first report, so a newly Category III holding company files its SLR tables on the FR Y-9C clock described in our FR Y-9C reporting guide. The 60-day window belongs only to an advanced approaches institution that has not yet completed its parallel run.

Submission through Reporting Central, signature and five-year retention

All FFIEC 101 filers submit electronically through the Federal Reserve’s Reporting Central application, including national banks and FDIC-supervised banks, with questions routed to the Reporting and Reserves District Contact. That is a different channel from their Call Report, which the Call Report instructions require to reach the Central Data Repository (CDR). The FFIEC 101 instructions add that responsibility for reflecting each line item requirement fully and accurately cannot be transferred or delegated to software vendors, servicers or others outside the reporting entity.

The signature requirement is model-specific. A senior officer, who may be the chief financial officer, the chief risk officer or an equivalent, signs to attest that the risk estimates and other information meet the capital rules and the reporting instructions. The cover page serves as the attestation and is attached to the printout of the completed report kept in the institution’s files. The Legal Entity Identifier goes on the cover only if the institution already has one, and it must be current and valid; an institution without an LEI does not have to obtain one for this report.

Retention runs longer than for the Call Report. The FFIEC 101 instructions state that, in general, a reporting institution should maintain a signed and attested record of each completed report, including amended reports, together with related workpapers and supporting documentation for five years after the report date, unless applicable state requirements mandate a longer retention period. The Call Report instructions set three years.

The instructions describe verification as double-checking all entries and cross-checking totals and subtotals against the items they tabulate and the supporting materials. A reporting institution must file an amended report when it discovers significant errors or omissions, and failure to amend on a timely basis may subject it to supervisory action. Interpretive questions go to the primary federal supervisor, which may require a report to be prepared on its interpretation and may require amended filings for earlier reports.

What reaches the public, and what stays confidential

Public release depends on the parallel run. Before an institution completes it, Schedule A is public except items 78 and 79 (eligible credit reserves under the advanced approaches and the amount includable in tier 2) and items 86 to 90, and every other schedule is confidential. The advanced approaches ratios of an institution still in parallel run therefore do not reach the public through this report.

After the parallel run, Schedules A and B become public, except Schedule B items 31.a and 31.b in column D, and items 1 and 2 of Schedule S become public as well. Everything else stays confidential. SLR Tables 1 and 2 are public in full, for advanced approaches and SLR-only filers alike.

An institution can ask for confidential treatment of items that would otherwise be public, but the bar is written into the instructions. The request must be in writing before the electronic submission, identify the specific items, justify the request and demonstrate the specific harm; merely stating that competitive harm would result is not sufficient. The supervisor may approve such treatment only in limited circumstances, and may later release the information if it determines disclosure is in the public interest.

What the October 2026 extension notice means for FFIEC 101 reporting

The notice is the second step of a routine PRA renewal. Under the PRA, an agency may not conduct or sponsor, and a respondent is not required to respond to, an information collection unless it displays a currently valid OMB control number. Section 3506(c)(2)(A) of title 44 generally requires a 60-day Federal Register notice before an agency submits a proposed collection, including an extension, to OMB. The June notice was that step, and it said the agencies would then publish a second notice with a 30-day comment period and submit the final FFIEC 101 to OMB. The October notice records that no comments arrived and that the agencies will proceed with the extension without revision, as proposed.

The expiry date on the form cover refers to OMB’s approval of the collection. The October notice is the request to renew that approval for three more years, on the existing forms. It describes the collection as quarterly, under a regular review, with an affected public of businesses or other for-profit entities.

The burden section doubles as the agencies’ own headcount of filers. These are estimates, by agency and filer type.

Adding the lines gives 36 estimated respondents. The annual totals in the notice are 26,960 hours for the OCC, 2,696 for the FDIC and, for the Board, 10,784 for state member banks, 60 for SLR-only holding companies, 24,372 for other holding companies and 84 for intermediate holding companies. The Board’s line assigns all seven intermediate holding companies the same 3-hour figure it uses for SLR-only filers.

The notice also states how the agencies use the data: to assess and monitor the levels and components of each entity’s capital requirements and capital adequacy under the advanced framework and the SLR, to evaluate the framework’s impact on individual entities and the industry and its competitive implications, and to supplement on-site examination. The released data also inform other parties about these institutions’ regulatory capital.

The June notice anticipated separate future changes to FFIEC 101 reporting requirements through the PRA process. The October 2026 announcement confirms that the agencies are proceeding with a three-year extension request without revision and are submitting the existing collection to OMB for review. The current approval expires on 31 December 2026. No implementation date for subsequent FFIEC 101 reporting changes is established in the accessible official announcements.

The March 2026 re-proposal and the FFIEC 101 revisions it signals

On 19 March 2026 the agencies announced three capital proposals, one of them from the Board alone, published in the Federal Register on 27 March 2026 with comments due by 18 June 2026. The one that matters for the FFIEC 101 is the Regulatory Capital Rule: Category I and II Banking Organizations, Banking Organizations With Significant Trading Activity, and Optional Adoption for Other Banking Organizations (91 FR 14952). The proposal states that it would eliminate the advanced approaches framework and introduce in its place the expanded risk-based approach for Category I and II banking organizations, addressing what the agencies describe as challenges with the use of internal models for credit risk and operational risk capital.

The proposal’s PRA section is explicit about reporting. The agencies, under the auspices of the FFIEC, would propose related revisions to the Call Reports, the FFIEC 101 and the FFIEC 102, and those revisions will be addressed in one or more separate Federal Register notices. Elsewhere the proposal says that, ahead of the implementation of any final rule, the agencies plan to issue an update to the FFIEC 101 with reporting instructions for all items relevant to the calculation of operational risk-weighted assets, and that they plan to propose FFIEC 101 modifications so that all inputs to the business indicator would be publicly reported as separate inputs. For the Basel side of that story, see our Basel III implementation tracker.

The companion PRA notice published the same day (FR Doc. 2026-05958) dealt with different collections: the reporting, recordkeeping and disclosure requirements associated with the regulatory capital rules and with the market risk capital rules. The FFIEC 101 is not among the collections it lists.

The October notice is the latest FFIEC 101 notice in the sources reviewed, and it keeps the form unchanged while describing the advanced approaches revision as still in process. When the separate FFIEC 101 notice will appear, and what the replacement schedules will contain, remains open.

Frequently Asked Questions

Should every Schedule A line tie to our Call Report or FR Y-9C capital schedule?

Most capital component lines are defined by reference to a Part I item: Schedule A items 1, 2, 3 and 5 pick up RC-R or HC-R items 1, 2, 3 and 4, and items 8 to 11 pick up items 6, 7, 8 and 9.f. Beyond the parallel-run lines described above, the one to watch is item 27, deductions applied to common equity tier 1 because additional tier 1 and tier 2 are insufficient. Until the parallel run is complete it is the amount reported in RC-R or HC-R item 17; afterwards the instructions require it to be reported using the advanced approaches rule and no longer point to item 17.

Can an institution stop filing if it drops below the Category II thresholds?

The category definitions carry their own exit tests: under 12 CFR 324.2, for example, an FDIC-supervised institution that became Category II on its own size tests stays in that category until it has less than $700 billion in total consolidated assets and less than $75 billion in cross-jurisdictional activity for each of the four most recent calendar quarters, or less than $100 billion in total consolidated assets for each of those quarters. Advanced approaches status then follows the applicability criteria in 12 CFR 3.100(b)(1), 217.100(b)(1) and 324.100(b)(1), so an institution that leaves Category II remains subject only if it still meets another of those criteria, such as being a GSIB subsidiary or having elected to use the advanced approaches. If it is then a top-tier Category III organization, it still completes Schedule A, SLR Tables 1 and 2. The FFIEC 101 General Instructions still say that an advanced approaches institution remains subject unless its primary federal supervisor determines in writing that the rule is not appropriate, but the capital rules no longer contain that provision: the 2019 tailoring rule (84 FR 59230, effective 31 December 2019) removed it from sections 3.100, 217.100 and 324.100.

Did the 2026 enhanced SLR changes alter the FFIEC 101?

The enhanced SLR final rule (90 FR 55248, 1 December 2025), effective 1 April 2026, revised the FR Y-9C instructions for the holding company leverage buffer requirement, which becomes 50 percent of the most recent method 1 surcharge, and said related Call Report revisions may follow in a separate notice. The FFIEC 101 is not among the collections its PRA section revises, and the page carrying SLR Table 2 item 2.23 on the 30 June 2026 form still shows a 03/2020 revision date. Depository institution subsidiaries of U.S. GSIBs report their leverage buffer standard and leverage buffer in Call Report Schedule RC-R, Part I, items 56.a and 56.b.

How should a comment on the 30-day notice be labelled?

Comments can go to any or all of the agencies and are shared among them. The OCC requires “OCC” as the agency name and “1557-0239” in the comment. The Board asks for “FFIEC 101” in the email subject line, and the FDIC asks for “FFIEC 101 Extension.” A copy can also go to the OMB desk officers: the collection appears on reginfo.gov among collections currently under 30-day review.

Does the FFIEC 101 capture market risk?

Largely no. Under 12 CFR 217.100(b)(2), a market risk institution excludes the risk-weighted asset amounts of all covered positions from its subpart E calculation, except foreign exchange positions that are not trading positions, OTC derivative positions, cleared transactions and unsettled transactions. Market risk has its own report, the FFIEC 102 (Market Risk Regulatory Report for Institutions Subject to the Market Risk Capital Rule).

Do public SLR Tables 1 and 2 satisfy the capital rule’s SLR disclosure?

The two are linked but sit in different places. The Schedule A instructions say SLR Tables 1 and 2 are required of an advanced approaches institution as described in section 173(a)(2) of the rule, the SLR disclosure provision, and that the SLR disclosures predominantly apply to advanced approaches institutions other than consolidated subsidiaries of covered parents and subsidiaries of non-U.S. organizations subject to comparable home-country disclosure. The public disclosure itself is Table 13 in sections 3.173 and 324.173, with a Part 1 reconciliation and a Part 2 calculation laid out much like the FFIEC 101 tables, and the Board’s rule extends the section 217.173(a)(2) requirement to Category III institutions that must disclose under section 217.172(d). The capital rules impose a public-disclosure obligation under 12 CFR 217.172(d) and 217.173(a)(2), including Table 13. The FFIEC 101 instructions separately require applicable institutions to complete SLR Tables 1 and 2 and confirm that those tables are publicly available. The instructions do not expressly establish whether publication of the FFIEC 101 satisfies the Table 13 disclosure obligation. Institutions should confirm the applicable disclosure arrangements with their primary federal supervisor rather than assume that an additional publication is always required.

Related Articles

• FFIEC Call Report: Who Files 031, 041 or 051 for 30 September 2026: which Call Report form a bank files, including the FFIEC 031 requirement for advanced approaches banks.
• FR Y-9C Reporting: The $3 Billion Line and the 40-Day Clock: the holding company report whose submission date an FFIEC 101 holding company filer inherits.
• FR Y-15 Reporting: The Fed’s Systemic Risk Report, Schedule by Schedule: the indicators behind the Category II and III thresholds and the GSIB method 1 score.
• FR Y-14A/Q/M Reporting: Three Filing Clocks, One $100 Billion Panel: the capital planning and stress testing data filed by the same large holding companies.
• COREP Reporting Explained: A Practical Guide to Prudential Reporting: the EU capital templates, the nearest European counterpart to Schedules A and B.

Key Takeaways

• Route the FFIEC 101 through Reporting Central even where the same bank’s Call Report goes to the CDR, and confirm access before the first Schedule A quarter.
• Until the parallel run is complete, Schedule A item 12 stays at zero and items 50 and 60 stay on the standardized approach; all three move to the advanced approaches rule once it ends.
• Assign every in-scope legal entity its FFIEC 101 role before quarter-end: full filer, top-tier SLR-only filer, advanced approaches subsidiary that files its non-SLR schedules and reports SLR data through RC-R or HC-R, or Category III subsidiary that files no part of the FFIEC 101.
• Diary the due date from status: 60 days only before the parallel run is complete; otherwise the entity’s own Call Report or FR Y-9C date, by 5:00 P.M.
• Hold the signed FFIEC 101 record and workpapers for five years after each report date, two years beyond the Call Report period.
• Treat the date a board-approved implementation plan reaches the supervisor as the opt-in date for Schedule A, the SLR and the end of the AOCI opt-out.
• Watch for the separate FFIEC 101 PRA notice the March 2026 proposal anticipates, including operational risk-weighted asset instructions and public business indicator inputs.

Sources and References

• OCC, Federal Reserve Board and FDIC, Agency Information Collection Activities: Information Collection Extension; Submission for OMB Review; Regulatory Capital Reporting for Institutions Subject to the Advanced Capital Adequacy Framework (FFIEC 101), 91 FR 65843, 16 October 2026: govinfo.gov
• OCC, Federal Reserve Board and FDIC, Agency Information Collection Activities: Information Collection Extension; Comment Request; FFIEC 101, 91 FR 34347, 5 June 2026: govinfo.gov
• Federal Reserve Board, Agency Information Collection (FFIEC 101) proposal page, comments due 4 August 2026: federalreserve.gov
• FFIEC, reporting forms and instructions (FFIEC 101 form and instruction book): ffiec.gov
• 12 CFR part 217, Capital Adequacy of Bank Holding Companies, Savings and Loan Holding Companies, and State Member Banks (Regulation Q), sections 217.2, 217.10, 217.100, 217.121, 217.122, 217.172, 217.173 and 217.402, 2026 edition: govinfo.gov
• 12 CFR part 324, FDIC Capital Adequacy, sections 324.2, 324.100, 324.121 and 324.173, 2026 edition: govinfo.gov
• 12 CFR part 3, OCC Capital Adequacy Standards, sections 3.2, 3.100, 3.121 and 3.173, 2026 edition: govinfo.gov
• 12 CFR part 252, Enhanced Prudential Standards (Regulation YY), section 252.5, categorization of banking organizations: law.cornell.edu
• 12 CFR part 238, Savings and Loan Holding Companies (Regulation LL), section 238.10, categorization of banking organizations: law.cornell.edu
• FFIEC 031 and 041 instructions, Schedule RC-R, Part I, September 2026: fdic.gov
• FFIEC 031 and 041 General Instructions, September 2026 (due dates, CDR submission, retention): fdic.gov
• Federal Reserve Board, FR Y-9C report page and General Instructions (submission dates): federalreserve.gov
• OCC, Federal Reserve Board and FDIC, Regulatory Capital Rule: Category I and II Banking Organizations, Banking Organizations With Significant Trading Activity, and Optional Adoption for Other Banking Organizations, proposed rule, 91 FR 14952, 27 March 2026: govinfo.gov
• Federal Reserve Board, joint press release, Agencies request comment on proposals to modernize the regulatory capital framework, 19 March 2026: federalreserve.gov
• OCC, Federal Reserve Board and FDIC, Proposed Agency Information Collection Activities; Comment Request, FR Doc. 2026-05958, 27 March 2026: govinfo.gov
• OCC, Federal Reserve Board and FDIC, Regulatory Capital Rule: Modifications to the Enhanced Supplementary Leverage Ratio Standards for U.S. GSIBs and Their Subsidiary Depository Institutions, final rule, 90 FR 55248, 1 December 2025: govinfo.gov
• OCC Bulletin 2025-41, enhanced supplementary leverage ratio final rule, 25 November 2025: occ.gov
• OCC, Federal Reserve Board and FDIC, Changes to Applicability Thresholds for Regulatory Capital and Liquidity Requirements, final rule, 84 FR 59230, 1 November 2019 (removed the former remain-subject paragraph from 12 CFR 3.100, 217.100 and 324.100): govinfo.gov

The 30 September 2026 FFIEC 101: the next filing under the current approval

The next FFIEC 101 is the 30 September 2026 report, due before the current approval’s expiry date. Applying the submission rules above to that report date gives 30 October 2026 for a bank on the Call Report clock, or 4 November 2026 for a bank with more than one foreign office, and 9 November 2026 for a holding company on the FR Y-9C clock. An institution still in its parallel run has until 30 November 2026, because the sixtieth day, 29 November, falls on a Sunday.

Disclaimer: The information on RegReportingDesk.com is for educational and informational purposes only. It does not constitute legal, regulatory, tax, or compliance advice. Always consult your compliance officer, legal counsel, or the relevant supervisory authority for guidance specific to your institution.