FFIEC Call Report Revisions: Comments Due 28 December 2026
On 27 October 2026 the OCC, the Federal Reserve Board and the FDIC published a joint Paperwork Reduction Act notice proposing to extend the FFIEC 031, FFIEC 041 and FFIEC 051 Call Report for three years, with revision. Comments are due by 28 December 2026. The FFIEC Call Report revisions in question are already live: OMB gave them emergency approval on 28 September 2026, and they took effect for the 30 September 2026 report date.
The comment window therefore covers instructions banks have already filed against. They carry section 902 of the 21st Century ROAD to Housing Act, as implemented by an FDIC interim final rule, into reciprocal deposit reporting, and the agencies added a confidentiality exception for Schedule RC-O, items 9 and 9.a.
Related reading: FFIEC Call Report: Who Files 031, 041 or 051 for 30 September 2026
The reciprocal deposit calendar, July 2026 to February 2027
| Date | Event |
|---|---|
| 11 July 2026 | The Housing Act becomes law; section 902 amends section 29(i) of the FDI Act |
| 1 September 2026 | FDIC interim final rule (approved 27 August) published and effective, 91 FR 56022; its comments closed 1 October |
| 28 September 2026 | OMB emergency approval of the Call Report revisions |
| 30 September 2026 | First report date under the revised instructions |
| 27 October 2026 | Joint PRA notice published, 91 FR 67650 |
| 28 December 2026 | Comment deadline |
| 30 January 2027 | Standard due date for the 31 December 2026 Call Report (30 calendar days after the report date). As 30 January 2027 is a Saturday, ordinary filers may submit on Monday 1 February 2027. A bank with more than one foreign office, other than a shell branch or International Banking Facility, has 35 calendar days under the General Instructions, which by calculation is Thursday 4 February 2027 |
After the 60-day period, the OCC says it will publish a second notice with a 30-day comment period.
What section 902 changed for agent institutions and the general cap
Section 29 of the FDI Act restricts institutions that are less than well capitalized from accepting brokered deposits. Reciprocal deposits obtained through a deposit broker generally must be reported as brokered unless an exception applies, and section 29(i) lets an agent institution exclude a limited amount. Section 902 changed that exception in two ways.
The agent institution test first. Its first prong required a composite condition of “outstanding” or “good”, which the FDIC read as CAMELS 1 or 2. It now requires a composite CAMELS rating of 1, 2 or 3 at the most recent examination, and the institution must still be well capitalized.
Then the general cap. It was the lesser of $5 billion or 20 percent of total liabilities. It is now a tiered sum:
| Slice of total liabilities | Share excepted |
|---|---|
| Up to $1 billion | 50 percent |
| Above $1 billion, up to $10 billion | 40 percent |
| Above $10 billion, up to $96,333,333,333 | 30 percent |
The interim final rule puts the ceiling at $30 billion, reached at $96.33 billion of total liabilities. Its example: $25 billion of total liabilities gives (0.5 times $1 billion) plus (0.4 times $9 billion) plus (0.3 times $15 billion), a general cap of $8.6 billion. On the old formula the same bank would have been capped at $5 billion, the lesser of $5 billion and 20 percent of $25 billion. The FDIC calculates the general cap from Call Report data, so reported total liabilities feed straight into the brokered deposit answer.
The special cap look-back still counts back to a CAMELS 1 or 2 quarter
The September 2026 instructions apply the special cap to an institution assigned a composite CAMELS rating of 4 or 5, or that is not well capitalized, and that has not obtained an FDIC brokered deposit waiver; Example 2 in the September 2026 instruction examples states that assumption (“has not received a waiver to accept brokered deposits”). The special cap limits the reciprocal deposits such an institution may receive while keeping agent institution status, and in no event can non-brokered reciprocal deposits exceed the general cap. An approved FDIC waiver is a separate route to agent institution status, subject to any conditions the FDIC attaches. The calculation keeps its old anchor: find the most recent quarter-end at which the institution was both well capitalized and rated CAMELS 1 or 2, then average total reciprocal deposits over that quarter-end and the three before it.
The interim final rule explains the mismatch. The Housing Act amended the first prong but left the “outstanding or good” wording in the special cap prong. Its example: a bank downgraded from 2 to 3 in 2026 and from 3 to 4 in 2030 bases its special cap on 2025 to 2026 holdings, well before the quarters preceding the downgrade to 4. A spreadsheet rebuilt from the RC-E examples can pick the wrong quarters for that history.
FFIEC Call Report revisions by schedule and item
The joint notice lists the revised instructions: Schedule RC-E, Memorandum item 1.b, “Total brokered deposits”; Memorandum item 1.g, “Total reciprocal deposits”; the RC-E Examples for Calculating the Special Cap; Schedule RC-O, item 9, “Brokered reciprocal deposits”; and the Glossary entry “Brokered Deposits”. The FFIEC’s September 2026 supplemental instructions confirm there are no new data items on any of the three forms, and direct institutions to complete RC-E Memorandum items 1.b through 1.d and RC-O item 9 and, if applicable, 9.a under the updated instructions. The same update aligned Schedule RC-R, Part I with the 8 percent community bank leverage ratio, covered from the holding company side in our FR Y-9C CBLR update.
The instructions tie the lines together. Every reciprocal deposit goes in Memorandum item 1.g, brokered or not. RC-O item 9 is reported on an unconsolidated single FDIC certificate number basis and should be less than or equal to item 1.g; item 9.a is fully consolidated and completed only by institutions that own another insured depository institution. An institution that fails the agent institution definition reports all its reciprocal deposits as brokered in Memorandum item 1.b and RC-O item 9, and keeps them in item 1.g.
Qualification is tested at quarter-end, without regard to status during the quarter, according to the interim final rule. A CAMELS rating takes effect on the date of written notification from the primary federal regulator or state authority; a capital category change takes its date from the prompt corrective action rules.
Why RC-O items 9 and 9.a dropped out of public data
The notice gives the reason for the new confidentiality exception: compared with the publicly available total in RC-E Memorandum item 1.g, the RC-O amounts could reveal nonpublic supervisory information. The interim final rule describes the mechanism. A well capitalized institution only loses the exception if it lacks a CAMELS rating of 1, 2 or 3, and losing it moves every reciprocal deposit into RC-O item 9, so that line can jump within a quarter while item 1.g typically changes far less. The September supplemental instructions confirm the item 9 and 9.a amounts will no longer be made available to the public on an individual institution basis.
Confidentiality covers public release only. The FDIC still uses RC-O item 9 for deposit insurance assessments: for established small institutions that are well capitalized and rated CAMELS 1 or 2, brokered reciprocal deposits are deducted from brokered deposits in the brokered deposit ratio.
What the agencies want comments on
The notice invites comment on every aspect and names six points: whether the revised instructions accurately and clearly implement section 902; necessity and practical utility; the burden estimates; quality, utility and clarity; ways to minimise burden, including automated collection; and capital, start-up and operating costs. The agencies also ask whether their instructions need further changes, and say they would modify the collection if the associated FDIC final rule is modified. Non-substantive updates to forms and instructions are open to comment as well.
Burden per quarter is estimated at 86.25 hours for the FFIEC 031, 55.56 for the FFIEC 041 and 34.99 for the FFIEC 051, and the agencies state the revisions have no material impact on those estimates. The same three-year renewal mechanism appears in our FFIEC 101 renewal note.
Comments can go to any or all of the agencies and are shared among them. The OCC wants “OCC” and “1557-0081” in the comment and prefers email to prainfo@occ.treas.gov; the Board takes comments identified by “FFIEC 031, FFIEC 041, and FFIEC 051” through its proposals website; the FDIC wants “Call Report Revisions” in the subject line of emails to comments@FDIC.gov. All three may publish comments without change. The notice’s confidentiality rationale is that RC-O amounts could reveal nonpublic supervisory information, so a comment that recites a bank’s own rating history would place information of that kind on a public record.
Custodial deposits run on a separate track
The joint notice covers section 902 and does not discuss custodial deposits. Section 901 of the Housing Act added a separate capped exception for custodial deposits of eligible institutions with less than $10 billion in total assets, effective on enactment on 11 July 2026. For the 30 September 2026 report, the supplemental instructions let eligible institutions either estimate on a best-efforts basis the deposits still brokered under the new law, or keep reporting custodial deposits under the pre-Housing Act instructions. The FFIEC anticipates further instructions once the FDIC adopts a final rule, and institutions may use them to amend reports filed from 30 September 2026.
Frequently Asked Questions
A deposit placement network rebalanced our reciprocal deposits while we were above our special cap. Does that disqualify us?
The interim final rule defines when a bank “receives” nonmaturity reciprocal deposits: only when they come back as a result of its own new covered deposit placement. Rebalancing or a change in underlying depositors that does not raise the aggregate amount leaves agent institution status intact. Placing any new covered deposit while above the special cap ends it, and renewing or rolling over maturity reciprocal deposits counts as placement and receipt.
How does an institution regain agent institution status?
It depends on the prong. A well capitalized bank upgraded from CAMELS 4 to 1, 2 or 3 qualifies under the first prong immediately on the upgrade’s effective date. Under the special cap prong, it requalifies on the date it reduces reciprocal deposits below its special cap. Under the waiver prong, it qualifies on the date of the FDIC’s written notice approving a brokered deposit waiver.
Related Articles
- FFIEC Call Report: Who Files 031, 041 or 051 for 30 September 2026: which banks file each form and the CDR deadline for the September 2026 report.
- FFIEC 101 Reporting: A Three-Year Renewal With No Form Changes: the advanced approaches capital report and its October 2026 extension notice.
- FR Y-9C Reporting: An 8% CBLR and a Four-Quarter Grace Period: the holding company Schedule HC-R update for the 30 September 2026 report.
Key Takeaways
- Before 28 December: test the bank’s RC-E and RC-O reciprocal deposit logic against the September 2026 instructions, then decide whether an instruction point is worth raising.
- Quarterly control: RC-O item 9 never exceeds RC-E Memorandum item 1.g.
- Two rating sets: CAMELS 1, 2 or 3 for the agent institution test; CAMELS 1 or 2 for the special cap anchor quarter.
- Public data: RC-E Memorandum item 1.g stays public; RC-O items 9 and 9.a do not.
- Custodial deposits: the statutory exception has been in force since 11 July 2026; keep it distinct from the transitional Call Report options for 30 September 2026 and from further FFIEC instructions expected once the FDIC adopts a final rule.
Sources and References
- OCC, Federal Reserve Board and FDIC, Proposed Agency Information Collection Activities; Comment Request (Call Report), 91 FR 67650-67653, 27 October 2026, FR Doc. 2026-21841: govinfo.gov (PDF) and govinfo.gov (HTML)
- 21st Century ROAD to Housing Act, Public Law 119-101, 11 July 2026, sections 901 and 902 (amending section 29 of the FDI Act, 12 U.S.C. 1831f): govinfo.gov (HTML)
- FDIC, Reciprocal Deposits: Implementing the 21st Century ROAD to Housing Act, interim final rule amending 12 CFR 337.6, 91 FR 56022, 1 September 2026, FR Doc. 2026-17865: govinfo.gov (PDF)
- FFIEC, Supplemental Instructions, September 2026 Call Report Materials: fdic.gov (PDF)
- FDIC, Current Quarter Call Report Forms, Instructions, and Related Materials (FFIEC 031-041 and FFIEC 051 instructions updated for 30 September 2026; FIL-62-2026): fdic.gov
- Comment channels named in the notice: Federal Reserve Board proposals and FDIC Federal Register publications
Before the 28 December comment deadline
The revised instructions already govern the Call Report, and the agencies have named this comment period as the route for further changes to them. Points on RC-E Memorandum items 1.b and 1.g, the special cap examples or RC-O items 9 and 9.a go to the OCC, the Board or the FDIC, written so that no institution-specific supervisory rating appears in the filed text. The deadline is 28 December 2026.
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